Abstract

The Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRSs) fundamentally transform non-financial reporting in the European Union, yet empirical evidence on first-year compliance—particularly in Central and Eastern Europe (CEE) and in construction—remains scarce. This study provides a first, exploratory assessment of ESRS E1–E5 environmental disclosure compliance among Polish construction companies in the inaugural year of mandatory CSRD reporting. A structured content analysis of three purposively selected groups’ FY 2024 sustainability reports (Budimex, ERBUD, WPIP) applied a three-point scale (0–2) to a 39-item disclosure checklist, yielding 117 assessments. The compliance rate across the three groups studied was 73%, ranging from 86% (ERBUD) to 54% (WPIP). ESRS E5 (Resource Use and Circular Economy) proved most challenging (57%); recurrent deficiencies included missing CAPEX/OPEX allocations and unjustified omissions of anticipated financial effects. Distinguishing substantive disclosure from procedural responses (documented non-materiality, transitional relief, and exemptions) lowers this to 41% and reverses the ranking of the two mandatory reporters. This pattern is consistent with organisational decoupling, in that headline compliance figures systematically overstate the environmental information actually reported. Prior reporting experience was positively associated with compliance, although the small purposive sample precludes causal inference. The findings establish a baseline for monitoring ESRS implementation in the CEE construction sector.

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