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The Opportunity Gap: companies disclose two to three Risks for every Opportunity
ESRS gives Impacts, Risks and Opportunities equal billing. Our research coded European sustainability statements item by item and found Risks outnumber Opportunities 2.32 to 1 among large ESRS reporters, widening to 2.93 to 1 among voluntary VSME reporters, where no mandate pushes companies to look.
What did the research measure?
Under ESRS, companies must identify, assess and disclose three kinds of material item: Impacts, Risks and Opportunities. We wanted to know whether Risks and Opportunities get equal treatment on the page. So we coded sustainability statements item by item, under one rule applied identically to both sides: did the company itself formally type the item as a Risk or an Opportunity?
What did the research find?
| Measure | Result |
|---|---|
| Large ESRS reporters | 2.32 Risks for every Opportunity |
| Voluntary VSME reporters | 2.93 Risks for every Opportunity |
| Wholesale and retail | Almost 5 to 1 (66 Risks to 14 Opportunities) |
| Topic assessments with Risks and no Opportunities | 37% |
| Large reporters disclosing more Opportunities than Risks | Fewer than one in five |
Independent figures point the same way. EFRAG's 2026 State of Play data shows 3.1 Risk items against 2.0 Opportunity items for climate (E1) across 905 assured statements.
Why does the gap widen without the mandate?
Corporate reporting at scale leans towards defence, because compliance and risk management drive most sustainability disclosure. Take the mandate away and companies lean further still. Without a structured requirement to look for Opportunity, they default to the familiar language of Risk.
That suggests Opportunity is surfaced when the reporting architecture forces it, not explored as a matter of strategy. One limit shapes all of this: we counted what companies disclosed, which is not the same as what they found.
What is the Stunted O?
It is our name for the pattern. Impacts, Risks and Opportunities are known as IROs, and the O is the one that never grows to full size. The double materiality assessment is meant to weigh all three alike; in practice, almost all the effort runs one way.
Where can you read the full report?
The full study, with the coding protocol, sector breakdown, a six-scenario robustness check and the limitations, is free and deposited with a permanent DOI: doi.org/10.5281/zenodo.22124385. The company roster, item-level dataset and coding log are available on request. Edition 2 follows in 2027, grounded in a year of real engagements.
How to cite: Kelly, M. (2026). The Opportunity Gap: Risk and Opportunity Asymmetry in European Sustainability Disclosure under ESRS and VSME (Version 1.0). Nemetan.
What this could earn you. Closing the gap is what Sustainability Opportunity Discovery is built for. A Taster runs it on one topic of your own evidence, and an Opportunity Challenge tests whether your materiality process gives Opportunity the same rigour as Risk.
Common questions
What is the Opportunity Gap?
The difference between how many Risks and how many Opportunities companies disclose in their sustainability statements. Nemetan's research found 2.32 Risks for every Opportunity among large ESRS reporters.
Why do companies disclose fewer Opportunities than Risks?
Sustainability reporting is driven mainly by compliance and risk management, so Risk gets structured processes and Opportunity rarely does. The gap widens where there is no reporting mandate.
Is the Opportunity Gap research free to read?
Yes. The full report is free to download and has a permanent DOI so it can be cited and checked.
Risk gets a chapter. Opportunity gets a paragraph. The research measured the gap, and Sustainability Opportunity Discovery is built to close it.