EU’s Sustainability Reporting Rule: Affecting Everyone, Everywhere, All At Once
New research from Refinitiv this week revealed that more than 10,000 non-EU companies will be affected by the EU’s new sustainability reporting rule, the Corporate Sustainability Reporting Directive (CSRD) - about 30% of them American companies and 10% Canadian.?
Most US-based public companies have been following the new climate disclosure rule from the Securities and Exchange Commission (SEC), expected to be finalized this month. While there is no way to predict the content of the SEC’s final rule, it is certain to be tied up in court for some time.?
By the time the courts sort out the SEC rule, thousands of US companies will have to report even more ESG information in Europe. The reason? Like many EU policies, the CSRD applies to non-EU companies if they do business in Europe over certain thresholds (e.g., EU revenue of more than €150 million/year).?
Even more interesting, the rule requires companies to report on a new set of standards that cover far more than the climate impacts in the SEC proposal. The EU standards delve into areas such as biodiversity, social issues, and supply chain management - requiring disclosure of more than 100 key performance indicators.
The EU adopted “double materiality” as the basis for their standards - which encompasses both ESG impact on financial performance as well as the impact of the company's operations on the environment and society.?
The new rules are coming quickly. After being approved in January, the first wave of companies will need to collect information next year for their 2025 reports. And all of these new disclosures must be integrated into the company’s assured financial statements.??
ISSB Slows
Sticking with the disclosure theme, most ESG reporting requirements outside of Europe refer to the new standards from the International Sustainability Standards Board (ISSB). This week the ISSB decided that their disclosure standards would focus on climate for the next year before expanding to other sustainability issues - such as biodiversity.??
Two ISSB disclosure standards, a general sustainability standard, and a climate-related standard, are set to be released at the end of Q2. The decision to lead with climate disclosures was taken to reduce the demand on companies as they transition to the new disclosure approaches. ISSB Vice Chair Sue Lloyd said, “One of the reasons we are proposing this is because we know there is quite a bit of work to do .”
The decision means companies are expected to start reporting climate metrics in 2025 and other sustainability metrics in 2026. ISSB board member and former World Bank Vice President Jingdong Hua said the one-year delay “may accelerate the speed of adoption .”
Bringing Integrity to the Carbon Markets
The voluntary carbon offset market is central to many companies' emissions reduction schemes. However, it has been plagued by claims of impropriety. The newly published Core Carbon Principles from The Integrity Council for the Voluntary Carbon Market (ICVCM), a group headed by former SEC Commissioner Annette Nazareth, hopes to add more validity and value to the market.
The Core Carbon Principles provide a framework and benchmark that every carbon credit should meet before becoming an offset. The ICVCM acts like a regulator for the market; ICVCM Chair Annette Nazareth said, “Building a widely shared understanding of what high integrity means for carbon crediting... is a pre-condition for the development and growth of a viable and vibrant VCM .”
The new principles were praised by Julia (Osterman) Strong, from NCX, a developer of forestry offset projects - "There’s a lot of hope riding on it .” Credit buyers and sellers wait with bated breath to see if the new principles can accelerate the market.?
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Funding Drying Up for Oil and Gas
This week, investors in the $11 trillion Net Zero Asset Owners Alliance (NZAOA) - a subgroup of the Glasgow Financial Alliance for Net Zero (GFANZ) - released their position on the oil and gas sector . In summary, their position is that no new upstream oil and gas fields “should be financed, built, developed, or planned” and that only limited investments should be made in current fields and infrastructure development.?
NZAOA Chair and Allianz SE Board Member Günther Thallinger said, “How energy is provided and consumed must, therefore, dramatically change. This includes the need to phase out non-renewable sources like oil and gas in many, if not most, of its current uses.”
Insurance Defections?
While one GFANZ group made progress, another suffered some public defections. The Net Zero Insurers Alliance lost two of its founding members in as many weeks . Zurich Insurance Group was the latest defection joining Munich Re in exiting the alliance. Munich Re claimed antitrust concerns led to its decision. Zurich did not comment on antitrust issues - which are at the center of the ESG backlash in the US - instead saying, “Withdrawing from the NZIA will not change the Group’s commitment to sustainability."
Climate campaigner Peter Bosshard said: "With Munich Re and now Zurich leaving the alliance, insurers have an even bigger direct responsibility to align their businesses with a credible 1.5C pathway."
From Droughts to Floods
With summer quickly approaching in the North, the threat of climate change-related droughts and flooding looms large. Catalonia in Spain is already suffering from record-breaking droughts, and Tunisia is resorting to water rationing to combat its fourth consecutive dry year.?
Conversely, recent rains in California have soaked the long-parched state and replenished reservoirs to almost 100% . But the rains brought other problems: when the record snowpacks inevitably melt; there will be a much higher risk of spring flooding .
The views expressed on this website/weblog are mine alone and do not necessarily reflect the views of my employer.
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Notable Podcasts
Global Head of Public Policy at BDO
1 年Tim's updates are a great way to keep up with this fast moving area especially for me on #SustainabilityReporting developments. Andrew Buchanan Marc Priestley
Co-Founder and Chief Development Officer
1 年Thanks Tim - great insight, as always
https://greenfue.com/
Engage for Sustainability - had the privilege to lead the SAP EMEA North team
1 年Pedro S. Pereira 10.000 non EU companies this is may be an angle to explore for LAC.
Climate-Smart Agribusiness and Environmental Governance Consultant at Success in Agriculture
1 年Transparency has been the biggest challenge and moving goal posts.