Navigating the Evolving Landscape of ESG Reporting Requirements

October 26, 2023by Team IRIS CARBON0

In the world of investment, ESG (environmental, social, and governance) reporting is becoming more critical than ever. Companies worldwide see the value of addressing environmental and social issues, all while maintaining strong governance. This is not just because they want to; stakeholders are asking for it, and new rules, especially in EU the UK and the U.S., are making it a must.

In this article, we will guide you through the latest rules and regulations about ESG, mainly focusing on the EU, the UK, and the U.S. We’ll help companies understand and prepare for these changes. We’ll also talk about how ESG investments have been doing in the market and how investment managers can meet the growing demand while avoiding mistakes like Greenwashing.

The Global ESG Reporting Landscape – An Overview

In recent years, ESG (Environmental, Social, and Governance) reporting has gained significant traction in the U.S., with several draft rules and state bills aiming to make certain ESG aspects mandatory.

SEC Proposals on ESG Reporting

Draft Rule 87 FR 21334 (March 2022):

Purpose: Mandate including climate change-related risks in registration statements and periodic reports.

Key Provisions:

  • Disclosure of governance over climate-related risks.
  • Disclosure of potential material impact on the company’s strategy, business model, and outlook.
  • Disclosure of possible effects of climate-related events.
  • Requirement to incorporate this information into financial estimates.

After a phasing-in period, mandatory information on scope 1, 2, and specific scope 3 greenhouse gas emissions.

Status: The Climate Disclosure Rules were expected to be finalized by October 2023; however it is being delayed due to resistance in the Senate.

Draft Rule 87 FR 36654 (June 2022): 

Purpose: Address ESG disclosure obligations for investment advisors.

Key Provisions: Advisors must furnish additional information about their ESG investment practices, enhancing consistency and comparability for investors.

State Bills on ESG Reporting

State initiatives, mainly from California and New York, aim to bolster companies’ obligations concerning greenhouse gas emissions and associated risks.

California Senate Bill 253 (January 2023):

Purpose: Extend ESG disclosure requirements to private companies.

Key Provisions:

  • Mandatory disclosure of all scope 3 greenhouse gas emissions.
  • Verification of the disclosed information.

California SB 261 (2023):

Purpose: Strengthen climate-related financial risk reporting.

Key Provisions:

  • Annual publication of climate-related financial risk report.
  • Disclosure of measures taken to mitigate and adapt to climate-related financial risks.

Status: The California legislature passed this pair of climate disclosure bills into law in October 2023.

New York Bill 4123 (February 2023):

Purpose: Disclose all scope 3 greenhouse gas emissions.

Bills Opposing Mandatory ESG Reporting

While there’s a push for mandatory ESG reporting, some federal bills introduced in 2023 aim to counteract these efforts. These bills:

  • Propose to block provisions mandating disclosure of greenhouse gas emissions.
  • Seek to prevent the introduction of mandatory ESG disclosure requirements for federal contract recipients.
  • Target the prohibition of reporting on Scope 3 greenhouse gas emissions under securities law.

ESG Regulations in EU

Before 2018, the European Union’s member states had a patchwork of ESG regulations, leading to inconsistencies and fragmentation. The Non-Financial Reporting Directive (NFRD) brings uniformity to the ESG reporting landscape. However, variations in its implementation across countries resulted in challenges and ambiguities for businesses.

Introduction of the Corporate Sustainability Reporting Directive (CSRD)

In 2022, the E.U. took a significant stride in standardizing ESG reporting by adopting the Corporate Sustainability Reporting Directive (CSRD). Building on the foundation of the NFRD, the CSRD expanded ESG reporting requirements and extended its reach to include a broader range of companies.

Introduction of the Corporate Sustainability Due Diligence (CSDD)

The CSDD is another pivotal initiative by the European Commission to promote ethical and sustainable corporate practices throughout global value chains. It seeks to standardize due diligence practices, offering legal clarity for businesses and enhanced transparency for consumers and investors.

Key Provisions of the CSRD:

Mandatory Reporting: CSRD requires businesses to disclose their ESG activities, ensuring they are accountable for their sustainability practices.

Double Materiality: The directive necessitates companies to assess ESG issues from two perspectives: the business’s impact on sustainability and the repercussions of these issues on the industry.

Alignment with GRI and EU Green Taxonomy: CSRD aligns with the GRI Standards and integrates the EU Green Taxonomy, emphasizing transparency on human rights, environmental consequences, and climate change.

E.U. Sustainability Reporting Standards (ESRS): The ESRS provides businesses with guiding principles and specific metrics for reporting under the CSRD. It aims to offer stakeholders, from investors to consumers, a detailed and comparable view of a company’s sustainability performance, reflecting the European Green Deal’s goals.

Phased Implementation of the CSRD:

The CSRD will initially apply to companies within the E.U. beginning in 2024. By January 1, 2028, the directive’s scope will expand to encompass non-EU entities with significant operations in the E.U. Consequently, many global corporations, even those headquartered outside the E.U., will need to adhere to the CSRD by 2029 and consider its implications for their international operations.

With the introduction of both the CSRD and CSDD, Europe continues to pioneer and shape the ESG landscape, setting standards for companies globally.

ESG Reporting in the United Kingdom

The U.K. has historically been at the forefront of ESG considerations. With the Companies Act of 2006 laying the foundation for corporate disclosures, the U.K. has continually expanded its ESG reporting requirements, especially in the context of its commitment to net zero GHG emissions by 2050.

Companies Act of 2006 and Expanded Requirements in 2022

Purpose: Mandate sustainability and non-financial disclosures in annual reports for qualifying large companies.

Key Provisions:

  • Disclosure of strategy, processes, and due diligence regarding the environment, employees, social matters, human rights, and anti-corruption.
  • Climate-related disclosures, including risks, opportunities, governance, and strategy implications.
  • Alignment with the Task Force on Climate-Related Financial Disclosure (TCFD).

Streamlined Energy and Carbon Reporting

Purpose: Mandate disclosure of U.K. energy use and carbon emissions for qualifying companies.

Key Provisions:

  • Reporting on energy use and Scope 1 and 2 emissions within the U.K.
  • Applicable to companies with either £36 million annual turnover, £18 million balance sheet total, or 250 employees.

Introduction of Sustainability Disclosure Requirements (SDRs) in 2023

Purpose: Standardize and formalize ESG reporting, integrating the UK Green Taxonomy.

Key Provisions:

  • Provides a framework for companies to manage sustainability-related risks, opportunities, and impacts.
  • Setting of relevant ESG metrics and targets.
  • Expected full mandatory disclosure by 2025.

Other Key Reporting Obligations 

Various regulations and frameworks also shape the U.K.’s ESG disclosure landscape. Many requirements are found in the Companies Act 2006 and related regulations, like the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008. Listed companies also adhere to the Listing Rules and Disclosure Guidance and Transparency Rules. Additionally, corporate governance frameworks, such as the U.K. Corporate Governance Code, play a role in guiding companies on sustainability reporting.

Challenges in ESG reporting

As the world grapples with climate change and organizations align their investment management strategies to address environmental and social concerns, accurate and comprehensive ESG disclosure has become paramount. However, the path to robust ESG reporting is fraught with challenges. Here are the primary obstacles faced by companies:

Lack of Unified Reporting Frameworks

While frameworks like the Global Reporting Initiative (GRI) and the Sustainable Accounting Standards Board’s standards (SASB) are common, the absence of a unified standard especially challenges multinational organizations. Instead of a consistent report, companies are now leaning towards webpages that detail their ESG metrics alongside standard reports.

Navigating Complex Regulations

Regulatory requirements surrounding sustainability reporting are intricate. There’s a trend towards stricter regulations with detailed requirements backed by robust ESG disclosure. For instance, from 2024, global guidelines will aim to unify corporate environmental regulatory disclosures. Additionally, E.U. law mandates that significant corporations disclose data concerning risks and opportunities stemming from environmental and social issues.

Assessing ESG Initiatives’ Impact

The true power of ESG metrics lies in their potential to refine corporate strategy. But, many companies need help with siloed ESG data, making it hard to correlate ESG activities with financial outcomes. By integrating ESG reporting with budgeting, planning, and financial data, decision-makers can operate based on concrete insights rather than assumptions.

Quantifying ESG Risks

Unlike traditional risks, many ESG risks don’t lend themselves to straightforward currency-based calculations. This poses a significant challenge for organizations striving for transparency in their ESG investment and sustainable investing endeavors.

Benefits of robust ESG reporting

Far from a mere compliance exercise, robust ESG disclosure holds transformative potential for corporate strategy and stakeholder relations. Here’s a deep dive into the multifaceted benefits of thorough ESG reporting from the lens of investment, leadership, and strategic management:

Informed Decision-making for CEOs and CFOs:

Robust ESG reporting ensures financial leaders aren’t merely reacting to climate change implications but proactively shaping strategies to mitigate risks and seize opportunities.

Enhanced Investment Management: 

For investment managers, comprehensive ESG disclosure facilitates the identification of future-ready companies that have integrated sustainability into their DNA.

It offers a clear view of potential risks and rewards, allowing for more nuanced portfolio construction that aligns with financial objectives and ESG criteria.

Strengthened Stakeholder Relations:

In today’s informed world, stakeholders, from investors to customers, demand transparency. ESG reporting beyond regulatory requirements builds trust, showcasing an organization’s commitment to sustainable practices.

By actively combatting Greenwashing, companies can foster deeper stakeholder loyalty, protecting their reputation and brand equity.

Strategic Edge for Financial Leaders: 

ESG metrics, when integrated with core financial data, equip CFOs and other financial decision-makers with a more comprehensive risk assessment toolkit. This integration aids in anticipating market shifts, regulatory changes, and emerging trends in sustainable investing.

With a finger on the pulse of global sentiments around climate change and sustainability, financial leaders can spearhead initiatives that resonate with both market demands and ethical imperatives.

Mitigating Regulatory Risks: 

As global regulatory requirements around ESG disclosure intensify, companies with robust ESG reporting processes are better positioned to navigate these evolving mandates, ensuring compliance and avoiding potential penalties.

A proactive approach to ESG reporting signals to regulators a company’s commitment to transparency and ethical operations.

Driving Corporate Strategy with ESG Insights: 

CEOs and strategic decision-makers can harness ESG metrics to inform corporate strategy, ensuring alignment with global sustainability goals and stakeholder expectations.

Future of ESG reporting

The ongoing evolution of ESG investment and sustainable investing requires businesses to adapt to the rapidly changing landscape of regulatory requirements and stakeholder expectations.

Artificial Intelligence (A.I.) in ESG Reporting:

A.I. empowers companies to automate the acquisition and interpretation of ESG data from many sources, such as social media, news outlets, and IoT sensors. This automation facilitates the identification of pivotal ESG risks and opportunities, enabling a more refined corporate strategy.

Natural Language Processing (NLP):

Through NLP algorithms, vast amounts of unstructured data from diverse sources are processed, assessing a company’s ESG metrics and aiding investment management decisions.

Predictive Analytics:

A.I., through its predictive capabilities, deciphers historical data to identify trends in ESG performance. This understanding allows companies to predict potential ESG risks, such as climate change implications or the probability of resource shortages.

Deep Learning: Deep learning algorithms can discern intricate patterns within ESG data, revealing hidden relationships and trends, thus optimizing decision-making processes.

Use Cases of A.I. in ESG Reporting

Identifying ESG Hotspots: Leveraging data from IoT devices, A.I. can pinpoint environmental “hotspots,” such as areas experiencing significant pollution or biodiversity loss. These AI-derived insights are invaluable for investors and companies to enact proactive measures against potential pitfalls.

Utilizing Supplier Data: A.I.’s prowess in data analysis can highlight ESG risks within supply chains, such as environmental violations, paving the way for a more sustainable investing approach.

Benchmarking Performance: A.I. facilitates the comparison of ESG metrics across diverse parameters, enabling businesses to discern best practices and areas needing improvement.

Best practices for ESG reporting

In the evolving landscape of ESG reporting, businesses must adopt best practices to ensure accuracy, transparency, and effectiveness in their disclosures. Here are the recommended best practices for ESG reporting:

Identify the Audience and Stakeholders:

Understanding whom you’re reporting to is the foundation of effective ESG reporting. Businesses must recognize their primary stakeholders, whether they are investors, customers, employees, or the broader community. By identifying the audience, companies can tailor their ESG reports to address specific concerns, questions, and priorities.

Establish a Clear ESG Framework:

A robust ESG framework provides the blueprint for all reporting activities. It helps in defining clear metrics, setting benchmarks, and establishing the scope of the report. By having a standardized ESG framework, companies ensure consistency in data collection, analysis, and communication. This also ensures stakeholders receive a comprehensive view of the company’s ESG performance.

Collect and Manage Data Effectively:

Data drives ESG reporting. Companies must invest in reliable tools and technologies to gather, validate, and manage vast ESG data. Effective data management ensures that reports are accurate, timely, and relevant. It’s essential to ensure that the data collected aligns with the established ESG framework, ensuring that the insights derived are actionable and relevant.

Report and Communicate Progress:

Transparency is the cornerstone of ESG reporting. Companies must communicate their ESG performance, achievements, and challenges openly. Regular updates, annual reports, and stakeholder engagement sessions can provide insights into the company’s progress towards its ESG goals. Clear communication fosters trust and positions the company as a responsible and forward-thinking entity in the eyes of stakeholders.

Review Policies and Industry Practices Regularly:

The world of ESG is dynamic, with new developments, regulations, and best practices emerging regularly. To stay ahead, companies must review their ESG policies and procedures frequently. This includes benchmarking against industry standards, understanding emerging trends, and adjusting strategies to meet evolving stakeholder expectations.


In today’s rapidly evolving business landscape, ESG reporting is a pivotal tool for companies to demonstrate their commitment to sustainability, ethical operations, and stakeholder value. By identifying key stakeholders, establishing a clear ESG framework, and effectively collecting and managing data, businesses can communicate their progress transparently and confidently.

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