A PDF version of the full publication is attached here: Navigating the ESG landscape (PDF 498kb)

After years of increasingly vocal demand for enhanced transparency about ESG matters from investors and other stakeholders, sustainability reporting frameworks in the European Union (EU) as part of the Corporate Sustainability Reporting Directive (CSRD), internationally by the International Sustainability Standards Board (ISSB), and in the United States (US) by the Securities and Exchange Commission (SEC) - the “big three” disclosure frameworks — are all now final. While each requires expansive sustainability disclosure requirements, their scopes and other details vary. Further, reporting entities need to continue to consider developments in other jurisdictions, including new laws enacted in October 2023 in California which have broad applicability.

Given the geographic reach of these new requirements, and their potential to encompass a wide spectrum of value chain contributors, most companies are expected to be impacted in some way. Proactive companies are in the process of assessing the applicability so that they are prepared to meet potentially short reporting deadlines.

An SEC registrant that has a subsidiary listed in the EU, and a subsidiary in a jurisdiction that requires ISSB™ reporting, for example, may be subject to all three requirements, plus the new California bills. Standard setters and regulators have indicated a focus on interoperability among the standards and rules to enable companies subject to reporting in more than one jurisdiction to benefit from similar reporting requirements. None of the requirements to date, however, have specifically allowed equivalency — that is, permitting disclosures for one reporting framework to satisfy some or all of the requirements of another. Thus, companies operating in multiple jurisdictions have a vested interest in understanding differences among the reporting requirements.

Further, understanding where the frameworks align and diverge will help companies develop the requisite reporting strategy, data gathering processes, and related controls, providing for a streamlined process and effective deployment of resources.

This publication compares and contrasts key provisions among the European Sustainability Reporting Standards (ESRS), the standards issued by the ISSB, and the final SEC climate rules. It also provides select commentary on the California climate disclosure bills. By understanding the different requirements, preparers can develop a reporting strategy designed to capture the right data the first time.