What Actually Goes Into an ESG Report: A Section-by-Section Breakdown

Aug 17
11 min read

Open ten different ESG reports and you’ll find ten different documents. Different page counts, different section orders, different vocabulary, different things treated as central. That’s not sloppiness. It’s the system working as intended. There is no universal ESG report template. Reporting frameworks set disclosure requirements, but the report itself is shaped by the company’s industry, business model, materiality assessment, value chain, and which regulations actually apply to it.

This article walks through the anatomy that most real ESG and sustainability reports share, using three actual reports from three different sectors: an industrial technology group, a professional services firm, and a financial services and insurance group, to show how the same skeleton produces genuinely different documents. By the end, you should be able to open an unfamiliar 150 page report and know where to look and what each section is actually telling you. You’ll also see me use same template of explaining what is the thing were discussing, what will you actually see there, why is it there and what should reader look for.

The three reports used throughout:

Siemens, Siemens Impact 2025: industrial technology conglomerate (energy, automation, mobility)
KPMG Germany, Our Impact Report 2024: professional services (audit, tax, advisory)
Allianz, 2025 Sustainability Statement (published inside the 2025 Group Annual Report): insurance and asset management

1. Reporting Scope and Methodology

What is it? The fine print near the front, or in the annex, that defines what the report actually covers: which legal entities, which time period, and which standard it’s reporting against.

What will you actually see? A short note on consolidation boundaries, the reporting period, and the framework applied. Siemens states plainly that its 2025 report covers all Siemens affiliated companies, without Siemens Healthineers, and that 2025 was the first year it published a Sustainability Statement under CSRD, prepared in accordance with ESRS. Allianz discloses something structurally different: its CSRD Sustainability Statement is no longer a standalone document at all. As of 2025 it’s folded directly into the Group Annual Report, a scope decision that changes where and how a reader even finds it.

Why is it there? Because “the company” is rarely one clean legal entity. Subsidiaries, joint ventures, recently acquired units, and excluded divisions, like Siemens Healthineers, all affect what the numbers downstream actually represent.

What should a reader look for? Whether the boundary has changed since last year (a shrinking boundary can flatter emissions trends), and whether the report is standalone or embedded in a larger filing. That placement alone tells you how central sustainability reporting is to that company’s compliance structure.

2. Governance and Responsibilities

What is it? Who inside the company is accountable for sustainability performance, from the board down to the people who actually collect the data.

What will you actually see? Named roles and, often, named individuals. Siemens’ report is fronted by a joint statement from CEO Dr. Roland Busch and Chief People and Sustainability Officer Judith Wiese, and individual impact area sections are attributed to named heads, such as a Global Head of Sustainability or a Head of Climate. KPMG frames governance around its firm wide values and an “Integrity and quality” section tied to its own quality assurance system, reflecting the fact that in a professional services firm, governance is the core deliverable, not a supporting function.

Why is it there? Regulators and investors want to know sustainability isn’t a communications exercise. They want to see that specific people are accountable for specific numbers, the same way a CFO is accountable for financial figures.

What should a reader look for? Whether accountability sits at board or C suite level, or is delegated to a communications or CSR team several layers down. That placement is a strong signal of how seriously the target setting is taken internally.

3. Materiality / Double Materiality

What is it? The process the company used to decide which topics belong in the report at all. This is arguably the single most important section, because everything after it flows from this decision.

What will you actually see? Under the EU’s current ESRS framework, most reports show a double materiality assessment: evaluating topics from two directions at once, impact materiality (how the company affects people and the environment) and financial materiality (how sustainability issues affect the company’s own financial position). KPMG’s report shows this explicitly, mapping its own material topics, such as Business Conduct, Sustainable Supplier Management, Own Workforce, Climate Change, and Consumers and End Users, against both materiality dimensions and against specific ESRS topic codes. Allianz’s materiality process surfaced biodiversity as material specifically because of its proprietary investment and P&C insurance portfolios, a topic that would look completely out of place in a report from, say, a software company, and one Allianz backs with a dedicated biodiversity pilot assessment across three asset classes.

Why is it there? Because ESRS doesn’t require every company to report on every possible ESG topic. It requires companies to determine which topics are actually material to their business and stakeholders, then justify that selection. This article won’t go deep into how a double materiality assessment is actually run. That’s covered in a dedicated piece later in this series.

What should a reader look for? This is where the “no universal template” argument becomes concrete. Compare Siemens’ material topics (decarbonization, resource efficiency, cybersecurity) against Allianz’s (biodiversity in investment portfolios, insurance specific social topics) against KPMG’s (data protection, supplier management, business conduct): three completely different lists, each legitimately material to that company’s actual footprint and value chain.

4. Material ESG Topics

What is it? The output of the materiality assessment, translated into the actual topic sections that structure the rest of the report.

What will you actually see? Siemens organizes its entire report around three named “impact areas,” Decarbonization & Energy Efficiency, Resource Efficiency & Circularity, and People Centricity & Society, sitting on a stated foundation of ethics and governance. KPMG organizes around four pillars it calls Governance, People, Planet, and Prosperity. Neither of these structures is an ESRS requirement. They’re each company’s own strategic framing, with ESRS topic codes (E1, S1, S4, G1, and so on) mapped onto them afterward for compliance purposes.

Why is it there? This is the connective tissue between “here’s our materiality process” and “here’s our data.” It’s the company’s own narrative language for the topics regulators would otherwise label with codes like ESRS E1 or S1.

What should a reader look for? The company’s own framing labels (Siemens’ “DEGREE,” KPMG’s “Impact Plan”) versus the underlying ESRS codes. Learning to translate between a company’s marketing language and the standardized code is the single most useful skill for comparing two companies’ reports side by side.

5. Policies and Actions

What is it? What the company says it is actually doing about each material topic: policies, programs, partnerships, specific initiatives.

What will you actually see? This section tends to be the most narrative and least numeric part of the report, often illustrated with named customer or project case studies. Siemens fills much of its report with these: a case on Norwegian grid operator Elvia using Siemens software to increase grid capacity by up to 20%, a case on manufacturer Coherent cutting 264,000 metric tons of CO2e through an energy data partnership, a case on Siemens’ own Fürth plant tracking toward net zero by 2026. KPMG’s equivalent is its social engagement programs: pro bono consulting, mentoring initiatives like JOBLINGE, and an international “10by30” goal to economically empower ten million disadvantaged young people by 2030.

Why is it there? Numbers alone don’t explain how a target will be hit. This section is where a company makes its case that a target is credible, backed by an actual mechanism rather than just an aspiration.

What should a reader look for? Whether case studies connect back to the specific metrics in the next section, or whether they float free as feel good stories with no quantified tie back. The strongest reports tie every case study to a number that also appears in the targets table.

6. Metrics and KPIs

What is it? The actual quantitative data: emissions figures, workforce statistics, energy use, diversity numbers, usually the most information dense part of the report.

What will you actually see? Real, specific figures, not rounded PR numbers. Siemens reports a 66% reduction in Scope 1&2 emissions since a 2019 baseline, an 11% reduction in Scope 3, and 694 million metric tons of cumulative “Customer Avoided Emissions,” its own metric for emissions avoided by customers using Siemens technology, explicitly not a market standardized figure (Siemens says so directly, noting it follows WBCSD principles in the absence of one). KPMG reports concrete figures too: a global adjusted pay gap, donation totals down to the euro (EUR 1,707,994 in money and time donations for FY2024), and named percentage changes year over year.

Why is it there? This is the section investors, journalists, and rating agencies actually extract data from. It’s also the section most likely to get picked apart by fact checkers, because a specific number is a specific claim.

What should a reader look for? Whether a metric is standardized (Scope 1/2/3 emissions under the GHG Protocol) or company invented (like Siemens’ Customer Avoided Emissions or “DEGREE” targets). Company invented metrics aren’t inherently misleading, but they can’t be compared apples to apples against a competitor’s report, and a careful reader should notice which kind they’re looking at.

7. Targets and Progress

What is it? Forward looking commitments, almost always shown against a baseline year and a target year, with current progress marked against both.

What will you actually see? Progress bars and baseline, target, current triplets. Siemens’ target framework is unusually transparent about lagging targets, not just the ones on track. Its Scope 3 Upstream Emissions target, a 20% reduction by 2030 from a 2019 baseline, shows only 1% progress as of FY25, printed in the same table as targets running well ahead of schedule, like its 90% by 2030 Scope 1&2 target already at 66%. That kind of side by side honesty, strong progress next to stalled progress, in the same table, same font size, is a good signal of a target framework built for internal accountability rather than only external messaging.

Why is it there? A percentage reduction with no baseline year is unfalsifiable. This section is what turns a general commitment, such as “we care about the environment,” into an ESG style claim: a number, a baseline, a deadline, and a status.

What should a reader look for? Baseline years that keep moving, since a company quietly resetting its baseline can make stalled progress look like fresh progress, and whether underperforming targets are disclosed as openly as overperforming ones, in the same table, at the same level of detail.

8. ESG Data Tables / Indexes

What is it? A consolidated reference table, usually toward the back, listing every disclosed data point in one place, often cross referenced against ESRS, GRI, or other framework codes.

What will you actually see? A dense table, typically several pages, organized by topic with columns for target type, unit, baseline year, target year, target value, and current year value. Siemens’ annex is a clean example: a single “Sustainability target framework” table listing every DEGREE and further target across all four impact areas with baseline, target, and FY25 progress in one continuous list, the kind of table built specifically so a reader, or a rating agency’s algorithm, doesn’t have to hunt through 30 pages of narrative to find one number.

Why is it there? Rating agencies, index providers, and investors don’t read reports narratively. They extract structured data from tables like this. This section exists largely for that audience.

What should a reader look for? Whether every number claimed in the narrative sections earlier in the report actually reappears here. A genuine gap between narrative claims and indexed data is one of the more reliable tells of selective disclosure.

9. Assurance Statement

What is it? A signed statement from an independent third party confirming they’ve reviewed some or all of the disclosed data, a step beyond the company simply reporting its own numbers.

What will you actually see, and why does it vary so much? This is one of the clearest places where “no universal template” shows up in practice. Under CSRD, assurance is mandatory, starting at limited assurance with an eventual move toward reasonable assurance over time, but who provides it, and how prominently it’s presented, differs by company. Notably, in the KPMG report used for this article, no separate, clearly labeled external assurance statement appears in the document as published, worth noticing precisely because KPMG is itself one of the world’s largest providers of assurance services to other companies’ ESG reports. This article deliberately doesn’t go deep into how assurance actually works or what “limited” versus “reasonable” assurance means in practice. That’s the subject of a dedicated article later in this series.

Why is it there? Self reported ESG data without external review is essentially ungraded homework. Assurance is what gives a number the same credibility weight financial statements get from a statutory audit.

What should a reader look for, at minimum? Whether an assurance statement exists at all, who signed it, and whether it covers the whole report or only specific sections or metrics. Assurance scope is very often narrower than the report itself, and that narrowing is usually stated in small print near the statement, not advertised in the headline claims.

10. Methodology, Limitations, and Other Disclosures

What is it? The technical appendix: calculation methodologies, restatements, known data gaps, and caveats that don’t fit cleanly into any topic section.

What will you actually see? Footnoted methodology notes attached directly to specific metrics rather than gathered in one place. Siemens’ target table carries footnotes clarifying that two “Further target” figures, fleet electrification and renewable electricity share, are shown using a different baseline than the Siemens Group value reported elsewhere in its own Sustainability Statement, a small but telling example of how even a single company can report the same underlying metric two slightly different ways depending on which document you’re reading.

Why is it there? ESG metrics often rely on estimates, third party data, or evolving calculation methods. Customer Avoided Emissions is a good example, since Siemens states outright that no market wide standard yet exists for it. Disclosing the method is what allows a skeptical reader to judge how much weight a number can bear.

What should a reader look for? Restated prior year figures, a legitimate practice but worth noticing when it happens, and any footnote that quietly says a headline number and an annex number were calculated on slightly different bases.

A Note on the CSR Preis der Bundesregierung

Germany’s CSR Preis der Bundesregierung, the government’s CSR award, evaluates companies against categories like good business practices in supply chains, effective staff training on due diligence, climate and biodiversity protection, digital supply chain transparency, and stakeholder involvement. It’s a genuinely useful lens for understanding what “good” looks like in practice. The category descriptions read almost like a checklist of the behaviors a strong materiality assessment and policies and actions section should demonstrate.

But it’s worth being precise about what it isn’t: an award framework is not a reporting framework. The CSR Preis evaluates and recognizes standout practice through a competitive selection process. It doesn’t set mandatory disclosure requirements, doesn’t require standardized metrics comparable across companies, and doesn’t carry an assurance mechanism the way ESRS, GRI, or ISSB do. It’s a useful reference for what strong practice looks like narratively, but it can’t substitute for reading a company’s actual reporting framework disclosures if what you need is comparable, auditable data.

A Quick Note on the Frameworks Behind This Structure

The section order above is heavily shaped by ESRS, the EU’s CSRD linked standard, and to a lesser degree by GRI and the ISSB’s IFRS S1/S2. Two of the three reports used here, Siemens and Allianz, are reporting under the 2026 revised ESRS, the simplified version that followed the EU’s “Omnibus I” reform, which narrowed mandatory CSRD scope to companies above 1,000 employees and EUR 450 million net turnover, and cut mandatory ESRS data points by roughly 61% compared to the original standard. That’s a meaningfully different, and lighter, disclosure obligation than the ESRS version companies were preparing for as recently as 2024. This article deliberately doesn’t go deep into what each framework individually requires. That’s the subject of the next article in this series, GRI vs SASB vs TCFD vs ISSB vs ESRS: What Each Standard Actually Requires.

Putting It Together: The Anatomy of an ESG Report

Every report in this article follows roughly the same nine stage order: reporting context, governance, materiality, material topics, policies and actions, metrics and KPIs, targets and progress, data index, and assurance. But no two fill it in the same way, because the order is standardized while the content is a direct reflection of each company’s own materiality assessment, industry, and value chain. That’s the whole point. Once you know this skeleton, you stop being surprised when a 150 page report doesn’t look like the last one you read, and you know exactly which section to flip to for the question you actually came with.

References

Siemens AG, Siemens Impact 2025 (Sustainability Report / CSRD Sustainability Statement highlights)
KPMG AG Wirtschaftsprüfungsgesellschaft, Our Impact Report, Sustainability Report 2024
Allianz SE, 2025 Group Annual Report, Sustainability Statement, via allianz.com/en/sustainability
EFRAG, Technical Advice on the Draft Simplified ESRS, December 2025
European Commission / EUR Lex, Omnibus I simplification package and Directive (EU) 2026/470 amending the CSRD
Workiva, “What Is Double Materiality? Here’s What You Need to Know”
Bundesministerium für Arbeit und Soziales, CSR Preis der Bundesregierung, award category criteria