The Danish FSA publishes observations on sustainability reports
Published 22 January 2026
Category: Impact and ESG
On 18 December 2025, the Danish Financial Supervisory Authority (the “Danish FSA”) published a report evaluating the sustainability reports of 21 financial companies in connection with their annual reports for 2024. The companies which were reviewed comprised of 8 pension and insurance companies along with 13 credit institutions.
The report sets out the Danish FSA’s observations regarding the companies’ double materiality assessments (“DMA”) and climate change reports. In addition, the Danish FSA conducted an in-depth review of the sustainability reports of five financial companies. The observations show that all companies identified climate change (E1), own workforce (S1), and business conduct (G1) as material. Overall, the companies identified between 5 and 7 of the 10 ESRS topic-specific standards as material. The report also notes that several companies have chosen to defer reporting in accordance with the ESRS standards where possible.
The full report presents the Danish FSA’s observations based on these examinations, which will be incorporated into future guidance for the financial sector. In 2025, the Danish Business Authority and the Danish FSA collaborated to provide guidance on helping companies comply with sustainability reporting rules. Due to the ongoing revision of the ESRS and the adoption of Omnibus I, the Danish FSA will prioritise providing guidance to the financial sector in the coming years. According to the report, the Danish FSA will take necessary supervisory action in cases of non-compliance with the rules on sustainability reporting.
The update from the Danish FSA can be accessed here (in Danish), and the full report by the Danish FSA can be read here (in Danish).
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