
Impacts, Risks, and Opportunities (IRO) for CSRD Reporting
In this article, we’ll break down what IROs are, how to identify and assess them, and what CSRD requires in terms of disclosure.
ESG / CSR
Industries
ESG reporting has become a key part of how businesses operate - it's not just a way to showcase values but also to measure and communicate them. As investors, regulators, and customers increasingly expect transparency around how companies manage environmental, social, and governance risks, ESG reporting provides the framework for meeting those expectations.
ESG stands for Environmental, Social, and Governance. But it’s the reporting part that turns these broad themes into actionable insights, helping companies track progress, identify risks, and build trust with stakeholders.
As climate concerns, social expectations, and demands for corporate accountability continue to grow, ESG reporting has taken on a more central role. It’s now seen as a key marker of credibility and commitment.
In this article, we’ll delve into what ESG reporting requires, why it’s important for businesses, and what benefits it can bring.
The goal is to give stakeholders, including investors, regulators, customers, and employees, a transparent view of how the company is managing risks and opportunities linked to sustainability and ethical business conduct.
There’s no single universal standard for ESG reporting, but many companies use recognised frameworks like the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), or the Task Force on Climate-related Financial Disclosures (TCFD) to structure their reports.
The following table showcases some examples of ESG factors that fall under each category:
Metric | Description |
---|---|
Environmental Metrics | |
Carbon emissions | The total greenhouse gases produced directly and indirectly by a company. |
Product carbon footprint | The total emissions produced over the lifecycle of a product. |
Climate change vulnerability | The extent to which a company is exposed to the risks posed by climate change. |
Use of natural resources | The consumption of natural resources such as water, minerals, and fossil fuels. |
Waste management | How a company handles waste production, reduction, recycling, and disposal. |
Opportunities in clean tech and renewable energy | Investment and utilization of technology and energy sources that reduce environmental impact. |
Social Metrics | |
Labor management | Practices related to hiring, training, employee relations, and labor rights. |
Health and safety | Measures to ensure the safety and well-being of employees in the workplace. |
Product safety and quality | Standards and practices to ensure products are safe for consumers and meet quality criteria. |
Privacy and data security | Measures to protect customer and employee data from unauthorised access and breaches. |
Access to healthcare and finance | Availability of health benefits and financial services to employees and communities. |
Governance Metrics | |
Corporate governance | The system of rules, practices, and processes by which a company is directed and controlled. |
Board diversity | The inclusion of diverse members in terms of gender, ethnicity, and experience on the board. |
Executive pay | Compensation practices for top executives, including transparency and fairness. |
Business ethics | Adherence to ethical guidelines and standards in business operations and decision-making. |
Tax transparency | The clarity and openness in disclosing a company's tax practices and payments. |
ESG (Environmental, Social, and Governance) and CSR (Corporate Social Responsibility) often get mentioned in the same breath, and while they’re closely related, they serve different purposes.
CSR is about companies taking responsibility for their social and environmental impact. This often plays out through initiatives like ethical sourcing, community programmes, and charitable donations. The idea has been around for over a century, with early examples found in the philanthropic efforts of business leaders like Andrew Carnegie and John D. Rockefeller.
ESG, on the other hand, is a more structured evolution of CSR. While CSR is typically values-driven and focused on doing the right thing, ESG adds a measurable, reportable framework. It turns those good intentions into data, allowing companies to track progress and stakeholders to see the full picture.
For example, a tech company might commit (through CSR) to lowering its carbon footprint and supporting local communities. ESG reporting would then quantify that impact.
With hundreds of ESG frameworks in use around the world, it’s no surprise that many companies struggle to figure out which ones to follow. The landscape is fragmented, and different stakeholders often expect different things, making it hard to report in a consistent, meaningful way.
In response, some industries have started building more unified reporting frameworks. One example is the ESG Data Convergence Initiative, launched by the private equity sector to create a common set of ESG metrics and improve comparability across firms. But like many initiatives in this space, it’s voluntary, and private equity firms still have to navigate a patchwork of ESG expectations from investors, regulators, and other stakeholders.
Given the fragmented landscape of ESG standards, many companies choose to adopt established frameworks to bring structure and credibility to their reporting. These frameworks provide guidance on what to disclose, how to present it, and who the intended audience is, whether investors, regulators, or the general public.
Here’s an overview of some of the most widely used ESG reporting frameworks and what they focus on:
Framework | Focus | Key Features |
---|---|---|
Global Reporting Initiative (GRI) | Broad sustainability impacts | Covers economic, environmental, and social topics; modular and sector-specific; widely adopted globally |
Sustainability Accounting Standards Board (SASB) | Financially material ESG data for investors | Industry-specific standards; focuses on ESG factors that impact financial performance |
Task Force on Climate-related Financial Disclosures (TCFD) | Climate-related financial risks | Recommends disclosures on governance, strategy, risk management, and metrics related to climate |
Carbon Disclosure Project (CDP) | Environmental impact reporting | Companies disclose data on climate change, water security, and deforestation; data used by investors |
International Integrated Reporting Council (IIRC) | Integrated reporting | Integrates financial information with sustainability performance to offer a holistic view of the organisation’s value creation over time |
UN Global Compact (UNGC) | Corporate sustainability principles | Encourages adoption of ten principles on human rights, labour, environment, and anti-corruption; requires annual progress reporting |
EU NFRD / CSRD | EU sustainability reporting regulations | NFRD mandates non-financial disclosures for large public-interest entities; CSRD expands scope and depth of reporting |
Streamlined Energy and Carbon Reporting (SECR) | UK energy and emissions disclosure | Requires large UK companies to report on energy use, GHG emissions, and energy efficiency actions |
By aligning with one or more of these frameworks, companies can improve the clarity, reliability, and impact of their ESG reports while also staying ahead of evolving regulatory requirements. Choosing the right framework often depends on your industry, location, and the expectations of your stakeholders.
The short answer: it depends on where your company operates and what kind of organisation you are.
Let’s break it down by region.
The EU has introduced a comprehensive suite of regulations that make ESG reporting mandatory for a wide range of companies, both inside and outside the bloc. The Corporate Sustainability Reporting Directive (CSRD) is the cornerstone of this, replacing the older NFRD and significantly expanding the scope and depth of reporting obligations.
But CSRD is just one piece of a broader regulatory puzzle. Financial institutions must also comply with the Sustainable Finance Disclosure Regulation (SFDR), and new legislation like the Corporate Sustainability Due Diligence Directive (CSDDD) is pushing ESG responsibilities further into the supply chain. The EU Taxonomy, CBAM, and the Fit for 55 package round out the framework, all aimed at driving transparency and accelerating the green transition.
Here’s a summary of the major EU ESG-related regulations:
Regulation/Directive | Scope | Key Requirements |
---|---|---|
Corporate Sustainability Reporting Directive (CSRD) | Large EU companies, listed SMEs, and non-EU companies with significant EU activity | Detailed ESG disclosures using ESRS, to be included within management reports alongside financial statements; phased implementation through 2028. |
Sustainable Finance Disclosure Regulation (SFDR) | Financial market participants and financial advisors | Disclose how sustainability risks are integrated into investment decisions |
Corporate Sustainability Due Diligence Directive (CSDDD) | Large EU and non-EU companies with EU operations | Identify, prevent, and mitigate adverse environmental and human rights impacts |
EU Taxonomy Regulation | All companies under CSRD and SFDR reporting | Define and disclose environmentally sustainable activities |
Carbon Border Adjustment Mechanism (CBAM) | Importers of certain carbon-intensive goods | Report emissions from imported goods; comply with carbon pricing |
Fit for 55 Package | EU-wide climate policy package | Includes updates to ETS, CBAM, and other climate legislation to cut emissions 55% by 2030 |
The UK has taken a slightly more fragmented approach, with ESG requirements spread across several frameworks and departments. While there’s no single regulation equivalent to the EU’s CSRD, many companies - especially large ones - are subject to multiple overlapping obligations.
These include mandatory energy and emissions disclosures, climate-related financial reporting, and upcoming sustainability labelling rules to tackle greenwashing. NHS suppliers, too, are increasingly being asked to demonstrate sustainability performance as part of procurement requirements.
Here’s a summary of the UK’s current ESG reporting frameworks:
Regulation/Framework | Applies To | Key Requirements |
---|---|---|
Streamlined Energy and Carbon Reporting (SECR) | Large quoted and unquoted companies and LLPs | Disclose energy use, GHG emissions, and efficiency actions in annual reports |
FCA TCFD-Aligned Climate Reporting | UK-listed companies and FCA-regulated asset managers/owners | Annual climate disclosures aligned with TCFD |
Climate-Related Financial Disclosure (CRFD) | UK-registered companies with 500+ employees or £500M+ turnover | Disclose climate risks and transition strategies, based on TCFD approach; included in the Non-Financial and Sustainability Information (NFSI) section of the strategic report |
UK Sustainability Disclosure Standards (SDS) | All UK entities using sustainability-related terms in finance/marketing (expected by in 2025) | Sustainability Disclosure Standards (SDS) will align with the International Sustainability Standards Board (ISSB) – bringing the UK’s ESG reporting into line with global expectations while reducing greenwashing and improving consistency |
Energy Savings Opportunity Scheme (ESOS) | Large organisations meeting the qualification criteria | Conduct energy audits every 4 years across buildings, transport, and operations |
NHS Evergreen Sustainable Supplier Assessment | NHS suppliers (phased rollout) | Submit sustainability assessments tied to NHS contract eligibility |
In contrast to the EU and UK, ESG reporting in the US remains largely voluntary at the federal level, but that doesn’t mean companies can ignore it. Investor pressure, consumer expectations, and state-level legislation are all pushing businesses toward greater ESG transparency.
In 2024, the Securities and Exchange Commission (SEC) finalised a climate disclosure rule that would have required public companies to report detailed climate-related information in their filings. However, the rule was met with legal challenges, and by early 2025, the SEC signalled that it would no longer defend it in court, effectively stalling the effort.
That said, companies are still required to disclose material ESG risks in their SEC filings if those risks could impact financial performance. For many large businesses, this includes climate change, diversity and inclusion, or governance-related issues.
Meanwhile, several US states have taken matters into their own hands:
Large US companies are also often expected to report voluntarily using frameworks like TCFD, SASB, or GRI, especially if they have global operations or investor demand for ESG transparency.
Here are some of the key benefits:
Deciding to report on ESG is a meaningful step, but turning that decision into action takes planning, structure, and commitment. Here’s a step-by-step approach to building a reporting process that’s credible, useful, and aligned with your broader business goals:
Start by assembling a cross-functional ESG team with representatives from key departments, such as finance, HR, operations, legal, and sustainability. This group will be responsible for overseeing your reporting process, coordinating data collection, and ensuring your ESG efforts reflect your company’s values and strategic priorities.
Conduct a materiality assessment to determine which ESG topics are most relevant to your business and stakeholders. This involves speaking with employees, investors, customers, and suppliers, reviewing industry benchmarks, and analysing current and upcoming regulations. The goal is to focus your reporting on the issues that matter, not just everything that could be reported.
Once you’ve identified your material ESG issues, define specific goals to address them. Use the SMART framework (Specific, Measurable, Achievable, Relevant, Time-bound) to ensure your targets are realistic and trackable. These might include cutting emissions, improving supply chain transparency, or increasing board diversity.
Develop a practical roadmap that outlines how you’ll reach your goals. Include clear actions, responsibilities, timelines, and KPIs to track progress along the way. Your strategy should be ambitious but adaptable and able to evolve as your business grows or as regulations shift.
Accurate reporting depends on strong data. Implement tools and systems that make it easy to track ESG metrics across your operations. Ensure your data is consistent, verifiable, and regularly reviewed, especially if you’re reporting against frameworks like GRI, SASB, or TCFD.
Use recognised ESG reporting frameworks to structure your disclosures and ensure comparability. Communicate your progress and your challenges clearly. Whether you're publishing a formal ESG report or embedding disclosures in your annual report, transparency helps build trust with investors, customers, and employees.
For ESG to be effective, it can’t sit in a silo. Engage your broader team by weaving ESG values into everyday operations and decision-making. Offer training, set internal expectations, and recognise teams or individuals who contribute to your sustainability efforts.
Review your progress. Use data, feedback, and industry developments to assess what’s working and where adjustments are needed. ESG is not a one-off exercise but an evolving process of learning, adapting, and improving.
Perfection isn’t the goal - progress is. Start where you are, build strong foundations, and make steady improvements over time. The companies that get ESG right aren’t necessarily the ones with the flashiest reports, but those that stick with it and make it part of how they do business.
While ESG reporting offers significant benefits, implementing it effectively can be a real challenge, especially for companies just getting started. The process often involves new systems, cross-departmental coordination, and evolving regulatory expectations.
Below are some of the most common ESG reporting challenges and practical ways to address them:
Challenge | Description | Suggested Solutions |
---|---|---|
Data collection and quality | Difficulty in gathering accurate and complete ESG data due to fragmented sources and inconsistent standards | Invest in integrated data systems and conduct regular audits to ensure data reliability |
Lack of standardisation | No universal ESG reporting standard leads to confusion and inconsistency across frameworks | Use widely recognised frameworks (GRI, SASB, TCFD) to bring structure and comparability |
Resource constraints | High time, resource, and expertise demands can overwhelm smaller teams or companies | Prioritise key issues, automate processes, and seek external support where needed |
Stakeholder alignment | Conflicting expectations from investors, customers, and regulators can be difficult to manage | Engage stakeholders early and often to align ESG priorities and expectations |
Integration into corporate strategy | Resistance to embedding ESG within operations | Ensure leadership buy-in and provide ongoing education and internal communication |
Regulatory compliance | Keeping up with shifting regulations across jurisdictions adds complexity | Stay informed on regulatory updates; consult legal and ESG professionals regularly |
Ensuring data transparency | Reports must be credible and trustworthy; a lack of transparency undermines stakeholder trust | Adopt strong governance practices and consider third-party verification of reports |
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Greenly's comprehensive services and expert support can help your company effectively measure, manage, and report its ESG performance, driving towards a more sustainable future. For more information and to get started on your ESG journey, visit our website.