ZEISS under the ESRS lens
A voluntary first report, read for clarity, completeness and transparency, and benchmarked against EssilorLuxottica.
Move the pointer over the title to inspect it.FY 2024/25, published 30 Jan 2026. ESRS applied voluntarily. No external assurance.
FY 2024, URD chapter 6. Mandatory CSRD reporting. Limited assurance.
Sources: sustainability report and website, ESG rating providers, regulatory trackers, press and NGO searches. Evidence published after the reporting periods is marked “post-reporting”.
A foundation-owned optics group
Four segments
Vision care is the overlap with EssilorLuxottica.
Headquarters and ownership
- Oberkochen, Germany
- Wholly owned by the Carl Zeiss Foundation, unlisted
- Report approved by the CEO; same perimeter as the financial statements
Almost nobody outside ZEISS is checking
ESG rating · Sustainalytics risk score
The ZEISS Group is unlisted and unrated; the report cites no rating. The only proxy is Carl Zeiss Meditec: Medium risk, rank 351 of 588 in healthcare.
Proxy: Carl Zeiss Meditec AG, listed medtech subsidiary, 59.1% owned by Carl Zeiss AG.
Germany missed the July 2024 CSRD transposition deadline and faces an EU infringement procedure. ZEISS has no legal obligation yet.
No NGO reports or sustainability controversies found. Independent coverage is almost non-existent.
Value chains mapped per business unit
Step 1 of the materiality assessment covers
- Business models and activities
- Main products and services
- Key markets and customer groups
- Sites and headcount in scope
- Geographical, geopolitical and regulatory environment
Nature as a “silent stakeholder”
The environment is listed among the stakeholders whose interests count.
Experts speak for the stakeholders
“Stakeholders were not directly consulted, but their views were incorporated by internal experts.”ZEISS Sustainability Report 2024/25, p. 31
Indirect inputs used
Due diligence under the German Supply Chain Act (LkSG), sector studies and benchmarks, feedback from an external consulting firm.
Ongoing dialogue
Customers, suppliers, employees and investors are reached through ordinary channels, but none of them took part in the materiality assessment.
Readable results, hidden scoring
Material
Not material
Own operations shrank; the value chain did not
GHG emissions, tCO₂e, on one scale
Scope 1+2 down 68% against 2018/19. Scope 3 is reported one year behind. Climate is analysed for ZEISS only; the grid excludes it from the comparison.
Gaps
- Targets to 2024/25 were “not science-based”
- Scope 3 targets in the report are only qualitative
- No full ESRS transition plan
- No climate scenario analysis in FY 2024/25
- Result depends on green-power contracts and carbon credits
SBTi-validated targets, May 2026: Scope 1+2 −42%, relevant Scope 3 −25% by 2030.
ESRS adopted early, checked by nobody
Standards
- First report based on CSRD/ESRS, applied voluntarily
- Replaces the GRI Standards used in earlier reports
- No EU Taxonomy disclosure
Assurance
“The report is not subject to external assurance.”p. 7 · approved by the CEO only
A good-faith first step, but thin
Strengths
- Early, voluntary adoption of ESRS
- Clear, readable IRO tables by topic
- Measured Scope 1+2 cut: −68% against 2018/19
Areas for improvement
- No external assurance
- No direct stakeholder consultation
- Scales, IRO count and threshold not disclosed
Also: biodiversity excluded without a rationale · no climate scenario analysis · Scope 3 one year behind · offsets · no Taxonomy disclosure.
Same lens market, different pressures
| ZEISS | EssilorLuxottica | |
|---|---|---|
| Sector | Diversified optics; vision care is one segment | Pure eyecare and eyewear; about 18,000 stores |
| Headquarters | Oberkochen, Germany | Charenton-le-Pont, France |
| Ownership | Foundation-owned, unlisted | Listed on Euronext Paris |
| Regime | Voluntary ESRS, Germany not transposed | Mandatory CSRD, France transposed |
One asked the stakeholders, one did not
| ZEISS | EssilorLuxottica | |
|---|---|---|
| Context | Value chain per business unit; nature as silent stakeholder | Desk research, 16-peer benchmark, ESG risks from the risk register |
| Consultation | None; internal experts as proxies | Survey: 243 invited, 134 replies; 18 interviews, 5 workshops |
| External voice | Absent | 35% external response rate |
Simpler, but internal experts stood in for every stakeholder.
89 of 115
45 of 128
Same topics, one hidden funnel
EFRAG IG 1 · 4 steps
own method · 3 steps
Entity-specific topics
ZEISS: none · EssilorLuxottica: 3
vision-care access, local development, OneSight
Business conduct
G1 is material for EssilorLuxottica only. ZEISS reports it anyway.
Shared gap
Both exclude E4 biodiversity without a rationale.
One report was checked, one was not
| ZEISS | EssilorLuxottica | |
|---|---|---|
| Assurance provider | None: “not subject to external assurance” | Statutory auditors: PwC Audit and Forvis Mazars |
| Level | None | Limited, not reasonable |
| Scope | None | Materiality process · ESRS compliance · EU Taxonomy (Art. 8) |
| Conclusion | None | Unmodified |
| Caveats | None stated | First-year uncertainty; two late acquisitions excluded; some E2 metrics partial; no opinion on targets |
| Sign-off | CEO | Board, after Audit and Risk Committee |
Clearer to read, harder to trust
Click a grade to see the reason.
Where ZEISS leads
Clarity: a short report with readable tables.
Widest gap
Transparency: no assurance and no disclosed scoring.
Why
Obligation and investor pressure (slide 10) push EssilorLuxottica to disclose more.
Clarity good; completeness and transparency weak
ZEISS took a readable, voluntary first step. EssilorLuxottica is the stronger benchmark on disclosure. Both are typical of a first ESRS year.
Obtain limited assurance
Start with the materiality process, as EssilorLuxottica did.
Consult affected stakeholders
Survey and interview them directly, not through proxies.
Publish the scoring
Scales, IRO count, threshold, and why E4 is not material.
Thank you.Group 3 · Questions and discussion