For a second consecutive year, Projective Group has completed an extensive analysis of non-financial risk disclosure in the market today. Our full dataset includes more than 1,500 disclosures, taken from the annual reports of 170 firms in multiple sectors associated with financial services. These companies, from 22 countries around the globe, include banks, insurers, asset managers, FMIs and law firms.
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DMA adoption accelerates and priorities shift
Striking findings include a 46% increase in the number of firms adopting Double Materiality Assessments (DMA) between 2024 and 2025. More than 70% of the organisations included in the dataset now disclose DMA findings, and that growth is not confined to Europe, indicating a global shift in transparency expectations. Forward-thinking companies are leveraging DMA frameworks not just for compliance, but as an intelligence tool to help them to achieve the competitive advantage.
Priorities are changing. Environmental risk is now identified as the fastest growing category. DEI disclosures fell 13% globally (there was a significant 33% drop in North America compared to 12% in Europe). The average number of disclosures by topic fell from 12 to 11 per organisation. This doesn’t mean they are paying less attention to risk, rather that they are becoming better at prioritising their concerns. Both climate adaptation and biodiversity concerns rose in the overall rankings.
Governance broadens as new risk areas emerge
Governance topics continued to account for a third of the 1,500 disclosures cited. This suggests companies are using DMA frameworks beyond mere regulatory compliance. However, the share of governance topics shrank slightly compared to 2024.
Companies are using DMA frameworks beyond mere regulatory compliance
Governance also had the widest diversity of topics. Many of these were not directly referenced by the CSRD but instead addressed by other regulations e.g. financial crime and sanctions, operational resilience, cyber security and AI. Our study anticipates continued growth in the disclosure of non-traditional ESG topics as material within DMSs, including financial crime, artificial intelligence, and cybersecurity risks.
References to demographic change doubled. In 2024, only Japanese firms focused on aging populations, since then European firms have added migration's impact on demographics and politics.
Emerging trends include a 300% increase in Whistleblower protection citations, driven probably by the EU Whistleblower Protection Directive. A higher overall ranking may be achieved when companies list this separately rather than under the umbrella of business ethics.
There is evidence of a substantial fall in the number of firms citing material opportunities from sustainability-linked products and services.
There is evidence of a substantial fall in the number of firms citing material opportunities from sustainability-linked products and services – this drop is most keenly felt in Europe, where the number of firms citing this opportunity dropped by 35% over the last 12 months.
European standards shape global benchmarks (but divergence remains)
Implications for the financial services sector include signs, evidenced by the huge increase in the adoption of DMA frameworks, that European standards are becoming the accepted benchmark for financial institutions worldwide. However, questions remain about whether financial services organisations, particularly in the US, will follow the legal industry's retreat from DEI and sustainability topics amid changing political pressures.
There are significant differences between legal and financial services firms in their approach to non-financial risk disclosure. Law firms lag considerably in DMA adoption, with only 36% publishing assessments compared to higher rates in financial services.
What Risk Teams must prepare for in 2025
Industry leaders and risk assessment teams should be ready to embrace DMA frameworks as they become a critical tool in the arsenal for risk assessment teams. There needs to be a sharp focus on key material risks in preparation for regulatory convergence as European standards influence global practices.
Emerging risks in technology, cybersecurity, and geopolitics need to be closely monitored. All of the above need to be achieved whilst both navigating the political sensitivities around ESG and DEI topics and maintaining stakeholder trust. Organisations that adapt thoughtfully to these changes will be better positioned to navigate an increasingly complex risk landscape while maintaining stakeholder confidence and developing greater operational resilience.
Organisations that adapt thoughtfully to these changes will be better positioned to navigate an increasingly complex risk landscape while maintaining stakeholder confidence and developing greater operational resilience.
Contact us to discover how leading firms in your sector are redefining their risk management approach and whether the opportunities lie for strategic advantage.
At Projective Group, our experts offer tailored benchmarking reports and one-to-one sessions with our non-financial risk team to help you understand how your company compares to your peers and to identify any blank spots in your materiality assessment.
About Projective Group
Established in 2006, Projective Group is a leading Financial Services change specialist.
We are recognised within the industry as a complete solutions provider, partnering with clients in Financial Services to provide resolutions that are both holistic and pragmatic. We have evolved to become a trusted partner for companies that want to thrive and prosper in an ever-changing Financial Services landscape.
