Sustainability Opportunity Discovery
The research and method developed by Mike Kelly at Nemetan
This page is the permanent record of where Sustainability Opportunity Discovery came from, what it means, and how it has changed. It is maintained as a reference rather than as a pitch. Every figure on it is traceable to a published, citable source, and every version of the work is listed at the foot of the page with its date.
The definition
What Sustainability Opportunity Discovery is
Sustainability Opportunity Discovery is the systematic search for candidate Sustainability Opportunities, conducted before and separately from any assessment of their materiality, and producing an auditable record of what was searched, what was found, and what was set aside.
Four things in that sentence carry weight. Systematic means a repeatable process with a stated scope, not a workshop or an away-day. Search means the output is a set of candidates, not a decision about which of them matter. Before and separately from assessment is the distinction the whole category turns on: a materiality assessment is built to weigh what is already in front of it, and nothing in it is designed to put anything there. Auditable means the search can be reviewed, repeated and improved, and can answer the only question that matters when an Opportunity is missed, which is whether anyone looked for it.
A Sustainability Opportunity is a course of action in which the business benefit and the sustainability benefit arise from the same decision. It is not a cost that buys goodwill, it is not a Risk avoided restated as a gain, and it is not compliance rebranded.
The pattern
The Stunted O
The Stunted O is the name given to the pattern this research measured. In sustainability reporting under ESRS, companies must identify, assess and disclose three kinds of material item: Impacts, Risks and Opportunities. The three are given equal billing in the architecture of the standard. They do not receive equal treatment on the page.
Opportunity is not missing. It is stunted: present, technically disclosed, and starved of the rigour, depth and ownership that Risk receives by default. The letter is there. The discipline behind it is not.
The evidence
The 2026 research
Mike Kelly coded the Impact, Risk and Opportunity disclosures of forty large European companies reporting under ESRS, from sustainability statements covering financial years 2024 and 2025, and thirty mid-size companies reporting under the voluntary VSME standard. Every item was coded under a single protocol applied identically to both sides of the ledger, on one rule: did the company itself formally type the item as a Risk or an Opportunity? The coding was AI-assisted, working to a human-authored protocol and cross-checked against companies' own stated totals where published. This is similar to the approach EFRAG took in its 2025 review of 656 sustainability statements.
Measure
Finding
Mandatory ESRS, pooled (n=40)
455 Risks to 196 Opportunities, a ratio of 2.32 to 1
Voluntary VSME, pooled (n=30)
88 to 30, a ratio of 2.93 to 1
Topic assessments carrying Risks and no Opportunities
52 of 140, or 37%
Companies disclosing at least one Opportunity (mandatory)
36 of 40
Companies disclosing more Opportunities than Risks
7 of 40
Climate-only ratio, this study
1.69 to 1
Under a mandate the gap is one of emphasis: nine in ten companies disclose at least one Opportunity, and the imbalance is in depth. Where reporting is voluntary the gap becomes one of absence, with nearly three-quarters disclosing no Opportunity at all. The direction is corroborated independently by KPMG across 270 statements, by Datamaran across 304 companies, and by EFRAG across 905 assured statements.
What this research does not show
This study counts what companies disclosed. It cannot see what they identified. A company may have found an Opportunity, assessed it, and be acting on it, without disclosing it. The gap could arise at the search, at what survived assessment, at what was carried into strategy, at what is being pursued, or at what was judged reportable. Only the last of those is observable here.
Nemetan sells services at the discovery stage, which means an unsupported claim that the problem lies in discovery would be an unsupported claim that happens to be commercially convenient. That claim is not made here.
The study is observational and descriptive. No significance testing was run, and neither sample was drawn through a statistically representative frame. The figures are directional. Extraction and item-level tagging were AI-assisted, working to a human-authored protocol and cross-checked against companies' own stated totals where published; the protocol, decision rules and adjudication of edge cases were human. No independent second coder re-coded either sample.
The method
Ground, SPARK, PROVE
GROUND
Start from matched real precedents, not a blank page.
SPARK
Five stages of structured discovery, with the ideation tool matched to the topic.
PROVE
Five validation moves that test whether a candidate is worth backing.
LOOK OUTWARD
Find who has already solved a piece of it before building.
SPARK runs in five stages: Spot the gap, Pose the question, Apply the tool, Refine, Keep. PROVE runs in five moves: Pre-mortem, Reverse the income statement, Obligations, Verify, Evaluate. Discovery and validation are deliberately kept as separate disciplines, because a promising idea and a fundable one are not the same thing.
The method is one implementation of the requirements set out in the definitional paper. Those requirements are stated functionally so that they can be met in more than one way, including by methods other than this one. A category that only one organisation can practise is not a category.
Authorship
Author and originator
Sustainability Opportunity Discovery was developed by Mike Kelly, founder of Nemetan. He is the author of the 2026 research on which it rests and of the definitional paper that sets out its scope and method requirements.
Mike Kelly is a Chartered Director with the Institute of Directors, a GRI-certified ESRS Professional, and holds the Chartered Banker Institute's Certificate in Green and Sustainable Finance. He holds a BSc in Management from Trinity College Dublin, where he specialised in marketing, studied disruptive innovation at MIT's Sloan School of Management, and is completing an MSc in Sustainability Management at Rotterdam School of Management. Behind the qualifications sit more than 25 years as an entrepreneur.
ORCID: 0009-0008-4522-1786
The record
The published record
Both works below are deposited in Zenodo, the repository operated by CERN, and carry permanent DOIs. Deposit is not peer review and is not claimed to be. It means each work has a fixed address, a stated version, and an independent archive.
The company roster, item-level dataset and coding decision log are available on request to journalists, researchers and reviewers. Every item in the register carries a page reference into the company's own published statement.
The Opportunity Gap: Risk and Opportunity Asymmetry in European Sustainability Disclosure under ESRS and VSME (Version 1.0, 2026)
Sustainability Opportunity Discovery: Definition, Scope and Method Requirements (Version 1.0, 2026)
The Stunted O: The Complete Method (Edition 1, August 2026)
Provenance
Version history
Date
Version
What changed
August 2026
Research, v1.0
First deposit of the 2026 study of 40 ESRS and 30 VSME reporters. DOI 10.5281/zenodo.22124385
August 2026
Definition, v1.0
First deposit of the definitional paper setting out scope, boundaries and method requirements. DOI 10.5281/zenodo.22125068
August 2026
The Complete Method, Edition 1
First edition of the practitioner guide
This framework is emergent and is expected to change. Where running the method in practice sharpens, complicates or contradicts what is published here, the work will be revised rather than defended. Each revision is deposited with its own version identifier beneath a permanent concept identifier, so any reader can see what changed, when, and in which direction. Findings that cut against the argument will be published on the same footing as those that support it.
How to cite this work
Kelly, M. (2026). Sustainability Opportunity Discovery: Definition, Scope and Method Requirements (Version 1.0). Nemetan. https://doi.org/10.5281/zenodo.22125068
Kelly, M. (2026). The Opportunity Gap: Risk and Opportunity Asymmetry in European Sustainability Disclosure under ESRS and VSME (Version 1.0). Nemetan. https://doi.org/10.5281/zenodo.22124385
Page first published 27 August 2026. Maintained as the canonical origin record for Sustainability Opportunity Discovery.