MEDIA KIT · NEMETAN
The Opportunity Gap: Media Kit
Everything a journalist needs to verify and write the story: the research, the method, and the numbers behind it.
The story in 30 seconds
Every large European company now reports its sustainability Risks and Opportunities. One list is consistently longer than the other. New research by Nemetan coded how 40 large European companies reporting under mandatory ESRS, and 30 mid-size voluntary reporters, disclosed sustainability Risks against Opportunities. Across the mandatory sample, Risks were named more than twice as often as Opportunities: 455 to 196, a 2.32 to 1 ratio. Among the voluntary reporters the gap was wider still, nearly three to one. ESRS asks for both to be identified with equal rigour, and its prudence principle forbids understating Opportunity as firmly as it forbids overstating Risk. The research tests whether that balance appears in actual reporting. It documents a disclosure asymmetry; it does not, by itself, establish why that asymmetry exists.
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"A board sees the whole downside and a pre-filtered upside, and nothing on the page tells it those are different kinds of information." said Mike Kelly, founder of Nemetan, a Chartered Director and GRI-Certified ESRS Professional.
Key findings
1. 455 Risks to 196 Opportunities (2.32 to 1) across 40 mandatory ESRS reporters.
2. 88 to 30 (2.93 to 1) across 30 voluntary reporters, with nearly three-quarters disclosing no Opportunity at all.
3. In more than one company-by-topic assessment in three (52 of 140, 37%), a company disclosed Risk and zero Opportunity.
4. The pattern holds under multiple sector-exclusion scenarios, staying in a narrow band around two to one.
5. It is not universal: 7 of the 40 disclosed more Opportunities than Risks, and 36 of 40 disclosed at least one. The research reports both.
Independent corroboration
This isn't Nemetan's number alone. EFRAG's own 2026 State of Play report, covering 905 assured Wave 1 ESRS statements, the largest dataset of its kind, found companies disclose an average of 3.1 Risks against 2.0 Opportunities within Climate Change, a 1.55:1 ratio. This study's own Climate-Change-only figure, computed independently, comes out to 1.89:1 — directionally consistent with a dataset roughly 13 times larger.
KPMG's own review of 270 first-wave sustainability statements found Impacts at 60% of all disclosed items, Risks at 26% and Opportunities at 14%, with 11% of companies identifying no Opportunity at all.
Downloads
The company roster, dataset and coding decision log are available to accredited journalists on request.
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Cite this research
The Opportunity Gap
Kelly, M. (2026). The Opportunity Gap: Risk and Opportunity Asymmetry in European Sustainability Disclosure under ESRS and VSME (Version 1.0). Nemetan.
DOI: 10.5281/zenodo.22124385
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Sustainability Opportunity Discovery: Definition, Scope and Method Requirements
Kelly, M. (2026). Sustainability Opportunity Discovery: Definition, Scope and Method Requirements (Version 1.0). Nemetan.
DOI: 10.5281/zenodo.22125068
Author: Mike Kelly
ORCID: 0009-0008-4522-1786
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Additional research profiles:
SSRN — Author ID 12937208
Methodology in brief
Sample: 40 large listed European ESRS filers and 30 voluntary VSME reporters, stratified across sectors and defined before coding.
Documents examined: each company's most recent published sustainability statement.
Coding: a protocol fixed in writing before any company was read; every disclosed Risk and Opportunity item coded and cross-checked against companies' own stated totals; AI-assisted extraction with human adjudication.
Definitions: Risk and Opportunity coded to the standard's own categories, with a documented rule for ambiguous items, and analyst-suggested items excluded.
Quality control: statements re-read page by page, page references corrected, and every scope call recorded in a decision log.
Limitations: observational and purposive, not a census. It measures how often each is disclosed, not how important each is, and documents an asymmetry, not its cause.
Data availability. The full study is deposited and permanently citable at https://doi.org/10.5281/zenodo.22124385. The company roster, item-level dataset and coding decision log are available to accredited journalists, researchers and reviewers on request. Every item in the register carries a page reference into the company’s own published statement.
FAQ
Is Nemetan commercially interested in the findings?
Yes. The research came first, and predates Nemetan's commercial launch. Nemetan was then founded to advise on identifying sustainability-related Opportunities, so post-research it has developed a commercial interest in the question. The methodology and data are documented so the findings can be judged independently of that interest.
Did you choose companies to produce this result?
No. The sample is a stratified, purposive selection of large listed European ESRS filers across sectors, defined before coding. Every included and excluded company is named in the dataset.
What counts as an Opportunity?
Each disclosed item was coded under a protocol fixed in writing before any company was read, using the standard's own categories. The definitions and the handling of ambiguous items are set out in the methodology.
Could this just reflect that companies report Risks more extensively?
That is part of the question. The research measures how often each is disclosed, not how important each is, and the standard asks for both with equal rigour, so a consistent gap in identification is itself the finding.
Does this prove companies are ignoring opportunities?
No. It documents a reporting asymmetry. It does not, by itself, establish why that asymmetry exists.
Is this peer reviewed?
No. It is deposited with a DOI in Zenodo, the repository operated by CERN, which makes it permanently citable, version-controlled and independently archived. That is not the same as peer review, and it is not claimed to be. What it does mean is that the study has a fixed address, a stated version, and a method you can check against the dataset, which is available on request. A second coder has not re-coded the sample; that check can be run on request too.
Can our readers test anything for free?
Yes. We provide an ungated, free test that scores one thing: whether their move to double materiality is genuinely surfacing Opportunity, or quietly stopping at Risk. We call it "The Transition Gap Check" and it can be accessed at:Â
https://www.nemetan.com/sustainability-opportunity-transition-tool
About the researcher
Mike Kelly is the founder of Nemetan, a research and advisory firm whose work sits where board-level judgement, sustainability evidence and systematic innovation meet. He is a Chartered Director with the Institute of Directors, a GRI-certified ESRS Professional, and a Certified Professional Banker holding the Chartered Banker Institute's Certificate in Green and Sustainable Finance. He holds a BSc in Management (Marketing) from Trinity College Dublin, studied Disruptive Innovation at MIT's Sloan School of Management, and is completing an MSc in Sustainability Management at Rotterdam School of Management. The Stunted O grew out of primary research during that MSc, when he found a marked imbalance in how companies disclose Risk and Opportunity under double materiality. Behind the qualifications sit more than 25 years building businesses across international markets.
ORCID: 0009-0008-4522-1786
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www.linkedin.com/in/sustainabilityopportunitydiscovery/
Media enquiries
Mike Kelly, Founder, Nemetan
mike@nemetan.com
www.nemetan.com