CSRD SOS: Whitepaper launch
An urgent call to action from
CSOs and practitioners
Download our new research paper
At SB+CO, we partner with a range of global companies as they navigate preparing for and disclosing against the Corporate Sustainability Reporting Directive (CSRD).
The cries of anguish, surprise, and frustration from our clients and other practitioners were coming in thick and fast - whether from carrying out double materiality assessments or trying to understand the gaps in their current data collection processes.
This pushed us to gather the experiences from more than 30 senior sustainability leaders from large corporates at various stages of grappling with CSRD. The insights from those conversations, along with subsequent working sessions with a larger group, form the basis of this new research paper.
“It feels like we’re trying to build the plane while we land it…”
“I thought my role was helping to redefine the strategy for the business. Now it seems as if the only focus is on compliance.”
CSRD is the most ambitious piece of sustainability-related regulation in the world. It marks a major step forward in putting non-financial data on the same footing as financial data.
But our conversations with clients told us that they were struggling not with the ambition of CSRD, but with its practicalities.
Our intention with this research is to highlight the very real concerns and challenges that sustainability practitioners are experiencing. We are fully supportive of the intent of CSRD. In our minds, the worst case scenario is that companies’ frustration with the early challenges associated with CSRD leads to poor implementation and the dilution of its overall ambition.
“Everything on its own makes sense; together it feels like a tsunami.”
CSRD is the most ambitious piece of sustainability-related regulation in the world. It marks a major step forward in putting non-financial data on the same footing as financial data.
But our conversations with clients told us that they were struggling not with the ambition of CSRD, but with its practicalities.
Our intention with this research is to highlight the very real concerns and challenges that sustainability practitioners are experiencing. We are fully supportive of the intent of CSRD. In our minds, the worst case scenario is that companies’ frustration with the early challenges associated with CSRD leads to poor implementation and the dilution of its overall ambition.
“The big four have huge incentives to make preparing for CSRD huge… It’s a feeding frenzy.”
“There’s a self-interest for consultancies to deem more issues material and secure bigger follow-on work.”
Practitioners pointed to seven key fault lines in the implementation of CSRD - their frustrations clear, and their calls for more pragmatism consistent. These fault lines range from the openness of the guidance related to materiality through to the incentives that the big four have to make the implementation process as complex (and expensive) as possible.
At the same time, practitioners called for six key course corrections that would help them with CSRD implementation. Most of these relate to guidance, communications, and timelines - with changes intended to enable more robust, more accurate disclosures.
Our strong view at SB+CO, based on the conversations we’ve had, is that the practitioner voice is not currently being heard strongly enough by EFRAG. A practitioner body to shape and refine guidance before publication could help to avoid further complications - and is our final recommendation.
“They haven’t thought about the reality of the application of any of this.”
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Phoebe Whittome
Sustainability Strategy Director
Nick Wyver
Consultancy Director
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