NEW RESEARCH · SUSTAINABILITY OPPORTUNITY DISCOVERY
Your company has a process for finding Sustainability Risks. Does it have one for finding Opportunities?
At a time when companies are struggling to translate sustainability into financial value, Opportunity receives far less attention than Risk, potentially weakening the very process through which sustainability creates value.
We counted every Risk and Opportunity disclosed by 70 European companies. Among 40 large mandatory reporters, the tally was 455 Risks against 196 Opportunities.
This paper explains why that imbalance exists, and sets out how to add a structured Opportunity search before your next materiality assessment, turning the work you have already paid for into something that contributes to commercial value.
455
RISKS DISCLOSED
Original research · 70 companies coded item by item · Dataset available on request · Cited with a DOI
196
OPPORTUNITIES
2.32:1
MANDATORY ESRS, N=40
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Your Sustainability process may be very good at finding Risk, and systematically weak at discovering Opportunity.
WHY THIS MATTERS
The problem is not that Risk and Opportunity should appear in equal numbers. They shouldn't.
The question is whether your organisation has given Opportunity a credible process for being discovered in the first place.
RISK
identify
>
assess
>
quantify
>
assign
>
monitor
>
report
>
govern
OPPORTUNITY
Rarely an equivalent systematic process.
The board may be seeing the downside more clearly than the upside
Transition Risk tells you what could destroy value. What about the Opportunities it creates?
A sophisticated sustainability assessment can give directors a detailed picture of exposure, dependencies and potential financial downside. But where is the equivalent process for asking what a sustainability issue could allow the company to do?
The issue is not whether your Risk numbers are right. It is whether your organisation has looked hard enough for the Opportunities.
New revenue?
Lower cost?
A stronger market position?
A new business model?
A competitive advantage?
A chance to get ahead of a transition rather than manage its consequences?
Could your organisation answer these three questions?
You can use them without downloading anything.
1
Who owns Sustainability Opportunity discovery, by name?
2
Where in the year does it happen, and who is in the room?
3
What evidence would show an assurer that it happened at all?
Ask the same three about Risk and the answers come back without a pause.
The pattern is bigger than one study
EFRAG
905 statements
KPMG
270 statements
Nemetan
Datamaran
304 companies
70 companies
Different datasets. Different approaches. But the same findings showing a persistent asymmetry toward Risk. The paper goes further: it asks why the imbalance persists, and what organisations can do about it.
THE FIX
Put discovery before assessment.
Double materiality should not be replaced. It should be preceded.
Add a structured Sustainability Opportunity Discovery stage before the assessment, designed specifically to identify candidate Opportunities that might otherwise never reach the table.
The aim isn't more Opportunities in the report. It's better Opportunities for the business.
The paper describes the process closely enough to run yourself.
What you'll take away
For Sustainability, ESG and reporting leaders, and the strategy and commercial teams who need sustainability information to do more than satisfy disclosure requirements.
A different way to see your materiality assessment
Why assessment and discovery are different jobs, and why that matters.
Evidence you can take into the room
The Risk and Opportunity count across 70 European companies, with the methodology and the limitations set out clearly.
A practical Opportunity-discovery stage
A structured process you can put before your next materiality assessment.
Three questions for your own organisation
A simple test of whether Opportunity discovery actually exists in your business.
Plus a two-page Executive Brief you can forward to your CFO, CSO, strategy team or board.
THE AUTHOR
Mike Kelly
Founder, Nemetan
Mike Kelly has spent more than 25 years building companies, and learning the same lesson each time. The best opportunities are usually the ones nobody thought to look for. He trained in disruptive innovation at MIT's Sloan School of Management, and in risk at board level as a Chartered Director with the Institute of Directors. He founded Nemetan to bring that same rigour to the Opportunity side of sustainability, a field where companies disclose their Risks two to three times as often as their Opportunities. A GRI-certified ESRS Professional and Certified Professional Banker holding the Chartered Banker Institute's Certificate in Green and Sustainable Finance, he holds a BSc in Management from the University of Dublin, Trinity College, and is completing an MSc in Sustainability Management at Erasmus University's Rotterdam School of Management.
CREDIBILITY
Why this research?
The research sits at the intersection of three things that are rarely brought together: board governance, sustainability reporting and systematic innovation.
Nemetan's question is therefore not simply whether companies disclose Opportunities. It is whether boards are being given a sufficiently complete view of the strategic implications of sustainability.
Find out what your Sustainability process may be missing
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Sustainability as ambition, not defence.
Kelly, M. (2026). The Opportunity Gap: Risk and Opportunity Asymmetry in European Sustainability Disclosure under ESRS and VSME (Version 1.0). Nemetan. doi.org/10.5281/zenodo.22124385