Comparison of Significant Sustainability-Related Reporting Requirements

After many years of voluntary reporting, various regulators and standard setters around the world have established requirements for disclosures of certain sustainability-related information. The most significant sustainability-related reporting regulations and standards are those established by the SEC and the state of California[1] in the United States, the European Union via the Corporate Sustainability Reporting Directive (CSRD), and the International Sustainability Standards Board (ISSB) within the IFRS Foundation. The landscape is evolving rapidly, as highlighted by the SEC’s recent withdrawal of its legal defense for its currently stayed climate rule and the European Commission’s (EC’s) proposed omnibus initiative that will delay and potentially modify certain reporting requirements of the CSRD and other E.U. sustainability reporting regulations.

This publication summarizes and compares the key sustainability-related requirements issued by those bodies. It is intended to help U.S.-based entities that might have to report under more than one regulatory framework as well as entities that were preparing to adopt the SEC’s climate disclosure rule or the CSRD and want to understand how to leverage such preparation when applying other sustainability requirements (e.g., those issued by the state of California or the ISSB). The complete requirements of each body are not summarized or analyzed; instead, this publication focuses on key similarities and differences between them. Note that although the disclosure requirements under various frameworks may overlap, the information an entity provides under one set of regulations may not necessarily be accepted as sufficient by other regulators. Thus, an entity should assess whether it has met the specific obligations of every framework under which it is required to report. In addition, certain standard setters have issued guidance to help entities prepare disclosures under multiple frameworks. For example, the interoperability guidance issued jointly by the ISSB, EC, and EFRAG summarizes interactions between the CSRD’s and ISSB’s requirements, although this guidance may need to be updated as a result of changes to the CSRD made by the EC’s proposed omnibus legislation (see the CSRD Requirements section below). For links to Deloitte publications that discuss these frameworks in greater detail, see the Other Resources section.