June 1, 2023


Where Will We Find Corporate Sustainability Reports  as U.S. & E.U. Mandates Expand the Universe of Reports Published?


Making corporate reports accessible for public analysis has long been at the heart of G&A’s mission. With a new announcement from the EU, more companies than ever may be sharing their sustainability disclosures in a centralized way.


This summer, it will be 16 years since a small team of us launched Governance & Accountability Institute as a new consultancy specializing in helping clients achieve leadership in corporate sustainability and sustainable investing. Carrying on some of the work of our former crisis management consultancy, we gathered and analyzed all types of corporate reports.


Our library room had shelves bulging with full-color annual reports and special reports on topics of interest to investors and other stakeholders. A small special section we began in the early 2000s slowly filled up with reports on corporate environmental performance. The earliest of these followed the initial guidelines (G1) of the then-new Global Reporting Initiative. In 2000-02 there were at most a few dozen such “GRI Reports.”


The pace rapidly picked up and by 2010 our team was gathering a dozen or two new “ESG” or “sustainability” or “responsibility” or “corporate citizenship” reports each week. We hunted them down and featured each week’s new reports in this newsletter. The job of gathering was not easy; many companies simply published their sustainability or CSR reports with little fanfare, not even a news release.


As our database of this new type of report grew, and we shared our analysis of them, GRI invited G&A Institute to be its data partner for the United States, the United Kingdom, and the Republic of Ireland. We gathered the corporate reports published in these countries, conducted deep-dive analysis, databased the results, and shared top-line results publicly via GRI’s global database of reports. We did that for over ten years, until GRI ended its data partner program in 2020. Our internal work in gathering and analyzing corporate reports continues, however.


The universe of reports that we have gathered over the years – numbering in the thousands now – are important internal resources for the G&A team as we serve our corporate clients, especially in helping firms create their own award-winning sustainability reports that capture wide attention. We are still at it, gathering dozens of new reports every week and building superior corporate reporting and disclosure databases.


We were reminded of the absence of another central resource for corporate reports by the EU’s announcement last week that an agreement has been reached to establish an online European Single Access Point (ESAP) for all European corporate disclosures.


This is moving forward under a Capital Markets Union Action Plan to be agreed by the 27 member states of the EU, each of which has its own country-focused plan for managing reporting standards. The European corporate reports will be structured to respond to the forthcoming CSRD (Corporate Sustainability Reporting Directive), the SFDR (Sustainable Finance Disclosure Regulation), and the EU Taxonomy Regulation.


Attorney Jon McGowan, writing about the agreement in Forbes, explains that the ESAP will be rolled out in stages, as is happening with EU regulations for expanding corporate ESG/sustainability disclosure and reporting.


In the U.S., will the Securities and Exchange Commission develop a similar system to capture and share corporate sustainability disclosures? If the SEC releases its Final Rule on corporate disclosure of climate-related financial reporting, will it similarly require all reporters to provide their published results to a central database?


McGowan posits that while the SEC rule is expected to focus on disclosures related to the sustainability actions of a publicly-traded company, with the information designed to better inform investors, the European model for capturing and sharing corporate reports could lead the way to a user-friendly interface in the U.S. as well – helping companies to share their reports broadly to their stakeholder constituencies.


We’ll be watching the European ESAP rollout of ESAP in the coming months for signals of coming changes for U.S. companies as well.

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