Research Projects

1 December 2025

Europe’s largest companies are strengthening their AI disclosure, narrowing the gap between strategy and governance reporting, according to new research by the Corporate Governance Lab at Trinity Business School, FTI Consulting, Inc. and Mason Hayes & Curran.

The 2025 Decoding AI Disclosure Report, now in its second year, shows significant improvements in reporting practices when compared to 2024. This indicates that companies are responding to growing scrutiny and demonstrating greater sophistication in navigating the risks and opportunities associated with AI. This development coincides with the implementation of the EU AI Act, which has reshaped expectations regarding transparency, accountability and the responsible use of AI.

The report is a comprehensive analysis of the AI-related statements in the annual and sustainability reports of Europe’s 50 largest companies in the STOXX Europe 50 Index — a blue-chip index comprising sector leaders in Europe. The study examined the companies’ AI statements across 10 categories, including AI Policy, Board Oversight, Senior Leadership, Knowledge Development, Audits, Strategy, Risk Management, Key Performance Indicators (“KPIs”), AI Usage and AI in Chair or CEO Statements.

In 2024, most companies focused on describing their AI strategies and use cases, but provided limited information on critical governance metrics, such as AI policies, oversight mechanisms, risk management, audits and KPIs. The 2025 research reveals clear progress: companies are now providing significantly more detail on their AI governance frameworks. As a result, the gap between high-level AI strategy disclosure and detailed governance reporting is beginning to narrow, reflecting a more accountable approach to AI management across industries.

Strategy remains the category with the highest frequency of disclosure, while the most significant progress was seen in the reporting of KPIs. This trend reflects stronger measurement practices and a clear shift from broad commitments toward a more strategic and evidence-based approach to managing AI-related risks and opportunities. Reporting on KPIs increased by 162%, from 13 companies in 2024 to 34 in 2025.

The number of companies reporting on at least eight of the 10 assessed disclosure categories increased from eight in 2024 to 17 in 2025. As practices have improved, the threshold requirement for Top Disclosers has been increased and now recognises disclosures in nine or more categories. 

The Top Disclosers of 2025 are: GSK, HSBC Holdings, L’Oreal, National Grid, Prosus, SAP, Schneider Electric, Siemens, UBS Group, Unilever and Zurich Insurance Group. With the exception of GSK, Prosus, and Zurich Insurance Group, all are new entrants to the list. Each company expanded their disclosure by at least two additional categories compared to 2024. 

Reporting on Policy, Board Oversight, Knowledge Development and Risk Management all increased by about 50%:

• The number of companies citing an AI policy increased from 19 to 28;
• The number of companies disclosing proof of board-level AI oversight increased from 23 to 34;
• The number of companies referencing knowledge development initiatives increased from 26 to 37; and
• The number of companies describing processes to manage AI-related risks increased from 20 to 30.

“Accurate disclosure on AI improves transparency and confirms accountability, two fundamental principles of corporate governance,” said Daniel Malan, Director of the Trinity Corporate Governance Lab. “We are particularly pleased with the improved disclosure in the area of KPIs, which suggests a level of disclosure maturity. However, much work remains to be done in terms of standardisation of reporting frameworks to ensure comparability.”

“From a governance perspective, it is encouraging to see that more than two thirds of companies now have established board-level oversight of AI, ranging from dedicated AI committees to evidence of AI-related discussions at board and committee level,” said Arnaud Cave, a Director in the Strategic Communications segment at FTI Consulting. “This growing focus on oversight reflects not only a deepening understanding of AI-related risks and opportunities, but also the influence of emerging regulatory frameworks such as the EU AI Act, as well as increased investor pressure, prompting organisations to strengthen accountability and governance structures.”

While the report shows disclosure levels are rising, many organisations are still introducing AI initiatives without establishing adequate governance structures. The Organisation for Economic Co-operation and Development highlights that effective AI governance requires an integrated set of technical, organisational and ethical measures to manage both opportunities and risks across the AI lifecycle.

Key steps that companies can take to improve transparency and governance include:

• Integrate AI policies into business strategy and reporting
• Enhance board oversight and transparency
• Clarify senior leadership responsibilities
• Invest in training and collaborations to build knowledge
• Disclose risk management methodologies and mitigation plans
• Report on audit processes and results
• Provide a balanced set of KPIs demonstrating AI’s impact

2025 Decoding AI Disclosure Report

2024 Decoding AI Disclosure Report

For more information, contact daniel.malan@tcd.ie 

Not many people know that Ireland was the first country in the world to have a national code of corporate governance. More information is provided in this piece by Stephen Davis and Daniel Malan that was published by the Harvard Law School Forum on Corporate Governance. The two documents mentioned in the piece can be downloaded below:

IAIM Statement of Best Practice

IAIM Comments on Cadbury

For more information, contact Dr Daniel Malan.

A research project funded by the European Research Council (ERC) to establish the responsibility of firms, to explore the sources of their immorality, and to chart a path for their improvement. 

For more information, contact Dr Kenneth Silver. A short video about this project and Dr Silver’s views on the value of philosophy for management is available here.

This project explores how firms can successfully manage the complexities and tensions associated with adopting sustainability as a strategic priority at the core of the organisation.

The Trinity Corporate Governance Lab was delighted to invite everyone to a special webinar celebrating the publication of the latest special issue of Business Ethics Quarterly (Vol. 33, Issue 1, 2023) “The Challenges and Prospects of Deliberative Democracy for Corporate Sustainability and Responsibility”. A recording of the online event can be found here.

For more information, contact Dr Maximilian Schormair.  A short video about Dr Schormair’s research interests, the BEQ edition and his work in executive education is available here.

Dr Ulrich Leicht-Deobald is an associate professor at Trinity Business School, and a participant in this project that is funded by the Swiss National Science Foundation. The aim of this interdisciplinary project is the development of a methodology for the design of fair AI applications. The methodology will help guide stakeholders when considering the usage of AI in a socially responsible way, and will make it possible to train software developers in ethical topics.

For more information, contact Dr Ulrich Leicht-Deobald.

Appropriate governance oversight frameworks are critical to support the effective governance of universities. This has been confirmed by the Irish Higher Education Authority (HEA) Act 2022.  In collaboration with the Office of the Secretary of the College & Director of Governance of Trinity College Dublin, the Lab will investigate best practice in third level governance in Ireland and abroad.

For more information, contact secretar@tcd.ie.