How fashion brands are approaching ESRS disclosures

The textile ecosystem has one of the most globalised value chains, making it susceptible to social and environmental risks at all levels, from production to distribution. 

Over 70% of fashion products sold in the EU are imported, making human rights violations in producing countries across the Global South a pressing issue. The mass production of fast fashion has also driven excessive waste and environmental challenges which are shouldered by “end-of-line countries” like Ghana, Kenya and Uganda.

Disclosing these challenges helps to untangle environmental, social and governance (ESG) risks in the fashion industry. Under the EU’s Corporate Sustainability Reporting Directive (CSRD), double materiality assessments (DMA) ensure companies disclose their sustainability-related impacts in a comparable and transparent way.

We reviewed 11 sustainability statements published by major fashion companies in 2025 to identify the most commonly reported ESRS topics, gaps in coverage and standout practices.

Companies analysed include: Adidas, Brunello Cucinelli, CCC, Hermès, Inditex, Kering, LPP, LVMH, Pandora, Puma and Salvatore Ferragamo. 

Assessment index

Four out of the ten topics under the European Sustainability Reporting Standards (ESRS) were consistently identified as material by all companies, as seen below. At first glance, there is a strong focus on environmental topics, with more variation across social and governance topics.

Strong focus on environmental topics 

Overall, companies focused most heavily on environmental standards. With the exception of Pandora, all identified the five environmental topics as material. All companies consistently disclosed sub-topics for climate change, with detailed coverage of greenhouse gas (GHG) emissions, energy consumption and transition plans.

For the remaining environmental topics, the depth of disclosure varied. Pollution was limited to microplastics and hazardous substances, with no details on air or soil impacts. Similarly, under disclosures for water and marine resources, most companies reported on consumption and withdrawals, but the level of detail differed. For example, LVMH provided ESRS-structured disclosures with policies, actions, targets and metrics, whereas CCC only listed water as a concern without specific data or strategy in place.

Most companies also did not offer concrete disclosures for biodiversity. Biodiversity was generally addressed at a conceptual level rather than through actionable commitments as required by the ESRS. For example, the majority of reports (seven out of eleven) highlighted positive and philanthropic initiatives towards biodiversity, but failed to include transition plans. 

A social blind spot 

Affected communities had the weakest coverage among the four social topics. It was omitted by LPP and Pandora, and unassessed by Puma. This is notable given that fashion’s environmental impacts are closely tied to social issues, particularly for communities living near production and waste sites. 

The EU exports the majority of its second-hand textiles to regions across Africa and Asia. These flows of textile waste create high environmental costs for many communities, reinforcing the importance of economic, social and cultural rights as a material topic for fashion brands. 

Stand-out companies

Although Pandora did not report on three material topics mentioned by all other companies – E2 Pollution, E4 Biodiversity and ecosystems and E5 Resource use and circular economy – they introduced three custom environmental topics related to their business practices: environmental impacts of mining, environmental impacts of materials and environmental impacts of indirect procurement.

The ESRS allows companies to add entity-specific topics when the standards do not fully capture their impacts. Of the 11 reports, Pandora was the only company to make use of this option, showing a strong example of how the ESRS can be used to tailor a report to a company's unique business, rather than only following standard topics.

LVMH stood out for integrating its LIFE 360 programme into its DMA. LIFE 360 was launched in 2021 as a sustainability roadmap to 2030, with targets on biodiversity, climate change, circular economy and product traceability. LVMH integrated sustainability impacts directly to executive accountability: up to 15% of long-term bonus share awards (LTIPs) depend on meeting LIFE 360’s non-financial goals. This kind of accountability is a rare practice in the fashion industry. It shows that the company's goals are not just separate initiatives, but are considered fundamental to both its business and its sustainability strategy.

Industry outlook 

Fashion companies are disclosing widely on environmental issues, but social impacts on affected communities remain underdeveloped. Biodiversity and community issues are often framed through narratives and initiatives rather than measurable targets or transition plans. 

Although Pandora and LVMH stand out for their unique approaches, the broader challenge for the industry is to move from simple acknowledgement of material topics to structured disclosures that fully meet the ESRS requirements.