Levelling Up Sustainability: Wooga’s Journey Through the CSRD Challenge

by
January 30, 2025

Maike Steinweller is Director of Communications at Wooga, who joined Playing for the Planet as the Alliance's 50th member last year. Here, she shares about the journey the studio has been on to report against the European Union's new Corporate Sustainability Reporting Directive, which is beginning to impact games industry studios and publishers around the world as implementation rolls out across the EU.

Back in 2022, when looking for an external sustainability consultant, I first became aware of what is known as CSRD, the EU’s Corporate Sustainability Reporting Directive. This directive introduces new rules concerning the social and environmental information that companies have to report under EU law. To some, this may have seemed fairly self-explanatory, just some new guidelines to follow, right?

As the search developed though, it became abundantly clear to me that access to extensive knowledge and knowhow in this field was going to be critical for us to successfully comply. To meet disclosure requirements, we began Wooga’s journey towards levelling up our sustainability reporting. 

What does CSRD really mean?

Let’s start this post by understanding exactly what CSRD requires from businesses, as well as its purposes…

The EU’s CSRD, in force since January 2023, represents a major step in advancing transparency around sustainability practices. As part of the European Green Deal’s goal for climate neutrality by 2050, the CSRD expands on the prior Non-Financial Reporting Directive (NFRD) by significantly broadening the scope upon which companies are required to report. Companies like Wooga, need to publish reports for the 2025 financial year in 2026.

Beyond expanding its reach, the CSRD mandates detailed disclosures aligned with European Sustainability Reporting Standards (ESRS). These standards require companies to assess and report on both their societal and environmental impact (impact materiality) and how sustainability issues affect their financial performance (financial materiality). To put it simply: sustainability reports will be equally important than financial reports and also published as such. 

For businesses, and therefore Wooga, these changes mean more extensive data collection and cross-departmental collaboration to comply with the stricter requirements. As well as increasing accountability, the CSRD offers companies a chance to enhance their sustainability strategies, build trust with stakeholders, and align with global sustainability efforts—preparing them for a more transparent and sustainable economy.

How did Wooga respond to this? 

Once the search for a sustainability consultant was complete by early 2023, our first step was to carry out a general assessment of our sustainability practices to see where our baseline was. The first major revelation to come out of this was actually that our understanding of sustainability could be more holistic in our approach to business practice, incorporating all facets of sustainability, rather than exclusively the environmental side. 

As we delved deeper into CSRD preparation, the enormity of the task became clearer. A major milestone was conducting a materiality assessment before the regulation came into place, which involved evaluating and prioritising the issues most relevant to our business and our stakeholders. Sounds simple enough, right? Wrong.

Materiality assessments are intricate and require the evaluation of sustainability matters and their respective impacts, risks and opportunities. Determining what’s material was a monumental challenge in 2024. Not only the amount of sustainability matters that need to be considered but more importantly making deliberate decisions about what aspects to label as material. We invested significant time and effort into developing a transparent methodology with clear thresholds to guide our decisions. This approach ensured a balanced selection of material topics, avoiding overpromising while still maintaining the rigor required to satisfy auditors.

Our process became more structured in early 2024, setting the goal to complete the materiality assessment by the end of the year. That way, in 2025 we can focus on closing potential gaps we’ve identified, finding the right reporting tool and collecting the needed data to be ready to report. 2024 was also the year when we started documenting all steps along the way, because the devil is in the detail.

Auditors might ask detailed questions about our thought process for including one topic while excluding the other. Which actually was the toughest part of the process. Without established industry benchmarks, decisions sometimes felt subjective. For instance, was this issue ranked as  a “2” or a “3” in terms of financial impact? The lack of consistent guidance made these judgments tricky, so we leaned heavily on feedback from external stakeholders to validate our assumptions.

Progress… At last

By late 2024, things began to click. Completing the materiality assessment felt like a turning point, not just because it was a huge task but because of what we learned along the way.

We discovered that, of the four material topic standards we identified, three had positive implications for our business and a positive impact on employees and also players—only climate change mitigation presented a somewhat negative impact. That was an encouraging realisation: sustainability wasn’t just about minimising harm; it could also open doors to opportunity and innovation.

Hearing stakeholder feedback reinforced that we were on the right track. People inside and outside Wooga started to grasp the importance of the materiality assessment, and conversations about sustainability became more nuanced and productive. By this point, even terms like “double materiality” weren’t greeted with puzzled looks anymore.

Perhaps the most rewarding part of all of this was seeing how this effort positioned us to exchange ideas with peers in the industry. As more companies undertake CSRD compliance, a shared understanding is beginning to emerge. This dialogue is invaluable as we all work to close gaps, set benchmarks and sustainability targets, as well as build a more sustainable future together.

What Could Have Made It Easier?

Looking back, a few things could have helped us; notably, earlier industry collaboration. While the feedback we received through Playing for the Planet was invaluable, perhaps connecting with other companies in our space earlier in the process to understand the journey they have been on would have made rating material topics feel less arbitrary. Together, we could have started building industry-wide benchmarks sooner, thus simplifying the process, and I know this is something that Playing for the Planet will explore in their plans for the coming year. Clearer guidance would have also improved the process significantly.

For example, the lack of standards for certain gaming-specific topics left us guessing at times, but discussions with other partners in Playing for the Planet have - I hope - opened up a chance for more systemic discussions around the issues of marketing metrics in Scope 3 which for the gaming industry can follow a different rubric. Moving forward, ongoing collaboration within the industry will be key to addressing these gaps.

Key tips I would give to ourselves if we had to start over again

Today, we feel more confident, not because it will be easy, but because we’ve laid a solid foundation. Sustainability reporting is no longer an abstract concept; it’s something we live and breathe. Key learnings from our CSRD journey include:

  • Giving yourself enough time to approach the process thoroughly as rushing will only create more challenges later.

  • Documentation is absolutely critical. Don’t overlook it, as auditors will scrutinise every detail.

  • Striking the right balance between too many and too few material topics is essential; be comprehensive but realistic in your assessments. 

  • Importantly, not all material topics need to be negative and many can highlight positive opportunities for your business and your stakeholders.

  • The absence of industry benchmarks certainly made the rating process more difficult, underscoring the need for collaborative efforts to establish shared standards and the suggestions from other studios in Playing for the Planet were really helpful. 

  • Finally, investing time in choosing the right reporting tool is vital, as it will be the backbone of your sustainability reporting process.

To anyone starting this journey: lean into the complexity, embrace collaboration, and don’t be afraid to ask questions. The road ahead might feel daunting, but it’s also an opportunity to rethink your business and make a lasting impact.

If Wooga’s experience has shown us anything, it’s this: sustainability is not just a requirement, it’s a chance to lead.

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