ESG Reporting Standards & Frameworks in Brightest

Brightest provides up-to-date reporting forms for major international ESG and sustainability standards and frameworks. Below is a list of the available standards and frameworks in Brightest. Some companies are required by law to submit certain ESG standards while others voluntarily follow ESG standards and frameworks.

To determine if you organization is required by law to submit a specific ESG report, we recommend reviewing the legislation and regulations in your reporting country or region.

List of ESG Reporting Standards and Frameworks

Canada S-211
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Disclaimer: Brightest is not directly affiliated with any of the standards entities mentioned in this summary. The content in this summary is for general informational purposes only and should not be construed as legal or financial advice.

Australia Sustainability Reporting Standards

Themes: Climate, biodiversity, water, risks and opportunities

Best for:

The Australian Government has proposed a phased approach for mandatory climate-related disclosures, starting in 2025, with three distinct reporting groups based on size and economic footprint:

Group 1 (Large Entities)

Start Date: Financial years beginning on or after 1 January 2025
Criteria (any of the following): Consolidated revenue ≥ $500 million; Consolidated gross assets ≥ $1 billion; ≥ 500 employees

Includes: ASX-listed companies; Large private companies; Registrable superannuation entities; Banks, insurers, and other financial institutions

Group 2 (Mid-sized Entities)

Start Date: Financial years beginning on or after 1 July 2026
Criteria: Consolidated revenue ≥ $200 million; Consolidated gross assets ≥ $500 million; ≥ 250 employees

Group 3 (Smaller Entities)

Start Date: Financial years beginning on or after 1 July 2027
Criteria: Consolidated revenue ≥ $50 million; Consolidated gross assets ≥ $25 million; ≥ 100 employees

Number of participants: Approximately 6,000 companies are expected to be subject to the ASRS, with reporting obligations phased in over three groups

Stakeholder audience: Investors and shareholders; customers and clients; regulators and government agencies

Background: The ASRS were developed by the Australian Accounting Standards Board (AASB) in response to growing demands for standardized sustainability reporting. The standards were finalized on September 20, 2024, following extensive consultation with stakeholders. They align with international frameworks, particularly the ISSB's IFRS S1 and S2, to ensure global comparability. The implementation of the ASRS is part of Australia's broader commitment to enhancing corporate transparency and accountability in sustainability matters.

B Corp

Themes: Governance, workers, community, environment, customers, accountability, transparency

Best for:

SMEs to mid-size companies with strong social and environmental missions.
Consumer-facing brands and purpose-driven companies seeking trust and credibility.
Companies wanting to differentiate in ESG performance or attract impact investors.California Corporate Climate Data Accountability Act (SB 253)

Number of participants:

7,500+ certified B Corps globally.
Active in 90+ countries, across 150+ industries.

Stakeholder audience: Consumers, employees, investors, partners, and communities seeking ethical, transparent businesses.

Background: Launched in 2006 by B Lab, a nonprofit. Certification is based on scoring 80+ points on the B Impact Assessment (BIA), which evaluates a company's impact. Requires legal accountability: B Corps must update governance docs to consider all stakeholders.

Requirements

Complete the B Impact Assessment (BIA) (free).
Score 80+ points out of 200 across five impact areas.
Provide documentation and undergo review by B Lab.
Update legal structure (depending on country).
Re-certify every 3 years and pay an annual fee based on revenue.

Brightest Sustainability Metrics

Themes: energy, water, waste, carbon emissions

Best for: all organizations

Background: The Brightest Sustainability Metrics report provides you an overview of your organization's sustainability metrics at a global level. Examples of metrics include scope 1, 2, 3 emissions; water; waste, energy usage.

Business Responsibility and Sustainability Reporting (BSRS)

Themes: ESG, ethics, sustainability, inclusivity

Best for:

Top 1,000 Listed Companies in India: Mandated to report under BRSR.
Investors and Analysts: Seeking standardized ESG data for informed decision-making.
Regulators and Policymakers: Monitoring corporate sustainability practices.

Number of participants:

Mandatory Reporting: Applicable to the top 1,000 listed entities by market capitalization from fiscal year 2022–23.
BRSR Core: Introduced for the top 150 companies from fiscal year 2023–24, expanding to 1,000 companies by fiscal year 2026–27.
Voluntary Adoption: Encouraged for other listed and unlisted companies.

Stakeholder audience: Investors and Shareholders, Regulatory Bodies, Customers and Clients, Civil Society and NGOs.

Background: The Business Responsibility and Sustainability Reporting (BRSR) framework was introduced by the Securities and Exchange Board of India (SEBI) in May 2021, replacing the earlier Business Responsibility Report (BRR). It aims to enhance the quality and quantity of ESG disclosures by companies, facilitating better decision-making for stakeholders. The framework is structured around the nine principles of the Nine Principles of the National Guidelines on Responsible Business Conduct (NGRBC) and is designed to be interoperable with global reporting standards. The introduction of BRSR Core further strengthens the focus on key ESG metrics, with a phased implementation plan extending to 2026–27.

Reporting requirements:

Reporting Format: Three sections—General Disclosures, Management and Process Disclosures, and Principle-wise Performance.
Essential Indicators: Mandatory disclosures on key ESG aspects.
Leadership Indicators: Voluntary disclosures showcasing best practices.
Assurance: Top 150 companies required to obtain reasonable assurance for BRSR Core disclosures.
Value Chain Reporting: Top 250 companies to disclose ESG footprint of their value chain from fiscal year 2024–25

California Corporate Climate Data Accountability Act (SB 253)

Themes: Greenhouse gas emissions reporting & reduction, corporate climate accountability, environmental impact disclosure

Best for:

Mandatory for all companies that meet the following requirements:

Over $1,000,000,000 (one billion dollars) in annual revenue
Operating or doing business in the state of California

beginning in 2026 based on their 2025 fiscal and operating year.

Number of participants: NA - take effect in 2026

Stakeholder audience: Large organizations doing business in California, Regulators

Background: On January 30, 2023, the US state of California (CA) announced two new corporate climate reporting laws, the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Disclosure Act (SB 261). The laws are part of a broader state climate accountability package introduced by the California Senate, designed to improve corporate climate accountability and environmental impact disclosure among large companies doing business in CA. The SB 253 law requires qualifying companies, both public and private, to:

Improve their corporate transparency on carbon and greenhouse gas (GHG) emissions, including disclosures on their Scope 1, 2 and 3 emissions
Standardize their corporate disclosures regarding GHG emissions
Deliver an annual emissions report to the California Air Resources Board (CARB) and the CA State Emissions Registry
Complete independent, third party emissions verification

The primary goal of the California Climate Corporate Accountability Act is to drive greater climate and GHG emissions accountability for large polluters.

CDP

Themes: Climate, Supply Chain, Forest Water

Best for: Medium to Large Companies

Number of participants: 18,700+ companies reported on climate change, water security and forests; 1,100+ cities, states and regions disclosed environmental information through CDP

Stakeholder audience: Investors, Supply Chain

Background: CDP (formerly the Carbon Disclosure Project) is a not-for-profit charity that is responsible for the global disclosure standard for investors, companies, cities, states and regions. The CDP standard offers a way for companies to measure, disclose and manage their environmental impacts. It covers a wide range of environmental issues, including climate change, water use, deforestation and waste management. The CDP standard can be used by investors, customers and regulators to assess the environmental risks and opportunities of companies as well as to identify and monitor improvements in environmental performance. The CDP standard is aligned with other environmental reporting frameworks like the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB). The CDP standard has four themes:

Climate Change - includes a company's greenhouse gas emissions, climate change risks and opportunities, and climate change mitigation and adaptation strategies.
Water - covers the company's water use, water risk and opportunities, and water management strategies.
Forests - covers the company's impact on forests, including deforestation, forest degradation, and forest conservation.
Supply Chain - covers the company's efforts to manage environmental risks and opportunities in its supply chain.

The CDP standard also includes a number of cross-cutting issues, such as biodiversity, circular economy, and human rights.

Companies can submit their annual CDP disclosures by completing any or all of the CDP questionnaires on climate change, forests, and water security. The CDP reviews the disclosure submissions and publishes the scores of reporting companies on its website.

Corporate Sustainability Due Diligence Directive (CS3D)

Themes: human rights, environmental due diligence, climate transition plan

Best for:

Large EU Companies: Entities with significant employee counts and turnover thresholds.
Non-EU Companies: Firms generating substantial turnover within the EU market.
Investors and Financial Institutions: Stakeholders interested in companies' sustainability practices and risk management.
Regulators and Policymakers: Authorities overseeing corporate compliance with sustainability obligations.

Number of participants: Approximately 5,500 EU companies and at least 1,000 non-EU companies are expected to fall within the scope of the CS3D.

Stakeholder audience: Investors and Shareholders, Consumers and Civil Society, Employees and Trade Unions, Regulatory Bodies.

Background: The Corporate Sustainability Due Diligence Directive (CS3D), adopted by the European Union in 2024, aims to foster sustainable and responsible corporate behavior by mandating companies to conduct due diligence on human rights and environmental impacts. This directive builds upon existing national laws in countries like France, Germany, and the Netherlands, and seeks to harmonize due diligence obligations across the EU. By integrating these responsibilities into corporate governance, the CS3D represents a significant step toward aligning business operations with the EU's broader sustainability and human rights objectives.

Requirements:

Preventive Measures: Implement measures to prevent or mitigate identified risks.
Grievance Mechanisms: Set up accessible channels for stakeholders to raise concerns.
Climate Transition Plan: Develop and implement a plan to align business operations with climate neutrality goals.

The European Commission's Omnibus Package, published on February 26, 2025, proposes significant amendments to the Corporate Sustainability Due Diligence Directive (CS3D). These changes aim to reduce compliance burdens, particularly for small and medium-sized enterprises (SMEs), while maintaining the directive's core objectives.

Key proposed changes to the CS3D include:

Narrowed Due Diligence Scope: Companies would be required to conduct due diligence primarily on their own operations, subsidiaries, and direct business partners. Due diligence on indirect partners would be necessary only under specific circumstances, such as when credible information suggests potential adverse impacts.
Extended Monitoring Intervals: The frequency for companies to review the adequacy and effectiveness of their due diligence measures would be extended from annually to every five years.
Revised Penalty Framework: The requirement for pecuniary penalties to be based on a minimum of 5% of net worldwide turnover would be removed, allowing for more flexible enforcement measures
Adjusted Climate Transition Plan Requirements: Provisions regarding the implementation of climate transition plans would be modified to reduce complexity.
Delayed Implementation Timeline: The initial application deadline for CS3D would be deferred from July 2027 to July 2028, providing companies with additional time to prepare.

Deutscher Nachhaltigkeitskodex (DNK)

Themes: Environment, Labor rights, Human rights

Best for: Businesses, Financial sector actors

Number of participants: 1,000+

Stakeholder audience: Investors, Employees, Suppliers, Customers

Background: The Deutscher Nachhaltigkeitskodex (DNK), or German Sustainability Code, is a set of voluntary guidelines for sustainability reporting in Germany. It was developed by the German Sustainability Council (RNE), a non-profit organization that promotes sustainability in Germany. The DNK standard is based on the Global Reporting Initiative (GRI) Standards and is in line with the UN SDGs and EU Corporate Sustainability Reporting Directive (CSRD).

The RNE developed the DNK standard to provide a framework for companies to communicate their sustainability performance in a clear and transparent way. The DNK standard is divided into three sections:

Principles - sets out the core principles of sustainability reporting, such as materiality, completeness, accuracy, and comparability.
Content requirements - specifies the information that companies are required to report on, such as their environmental impacts, social impacts, and governance practices.
Performance indicators - provides a list of indicators that companies can use to measure their sustainability performance.

Companies that participate in the DNK standard are required to submit their reports annually to the DNK database. The DNK database is a public website where companies can publish their reports and where stakeholders can access them. Companies that comply with the DNK standard are awarded the DNK seal of approval, a valuable asset for companies that want to demonstrate their commitment to sustainability.

Global Reporting Initiative (GRI)

Themes: General - Sustainability

Best for: Any type of organization, public or private

Number of participants: 10,000+

Stakeholder audience: All

Background: The Global Reporting Initiative (GRI) Standards are a set of guidelines for sustainability reporting, transparency and comparability. In 1997, Global Reporting Initiative (GRI) was created as the first global, third party sustainability and social impact measurement standards. The standards are designed to help an organization communicate their ESG impacts and show a holistic picture of their material topics, their related impacts and how they manage those topics and impacts. The report is divided into different sections. The Universal Standards section was recently revised to incorporate reporting on human rights and environmental due diligence. The new sector standards were created to enable more consistent reporting on sector-specific impacts.

GRI has no central oversight function – though companies can choose to make their reports available via a database on the GRI website. GRI recommends reporting for the same time period as your organization’s financial reporting.

Energy Savings Opportunity Scheme (ESOS)

Themes: Energy consumption, Energy efficiency, Energy cost-savings

Best for: Mandatory for large organizations in the UK that meet the qualification criteria. A large organization is defined as:

For the qualification date for the second compliance period (31 December 2018):

employed 250 or more people
annual turnover in excess of €50 million (£44,845,000), and an annual balance sheet total in excess of €43 million (£38,566,700)

For the qualification date for the third compliance period (31 December 2022):

employs 250 or more people
annual turnover in excess of £44 million, and an annual balance sheet total in excess of £38 million

UK registered establishments of an overseas company also must comply with the ESOS (regardless of their size), if any other part of their global corporate group activities in the UK meet the ESOS qualifying criteria.

Number of participants: 10,000+

Stakeholder audience: Large organizations, Government agencies. Lead (energy) assessors

Organizations that qualify for ESOS must carry out ESOS assessments every 4 years. If an organization qualifies for ESOS though is fully covered by ISO 50001, then that organization does not need to carry out an ESOS assessment. The organization only needs to notify the Environment Agency.

If an organization qualifies for ESOS though is not fully covered by ISO 50001, then the organization needs to carry out an ESOS assessment to determine what is needed to be compliant with ESOS. Steps in the ESOS assessment include:

Calculation of total energy consumption
Identify areas of significant energy consumption
Appointment of a lead assessor - internal or external, must be members approved professional body registry
Notify the Environment Agency
Keep records

European Sustainability Reporting Standards (ESRS) / Corporate Sustainability Reporting Directive (CSRD)

Themes: Environment, Social, Governance

Best for: Companies in the European Union, companies required to comply by law (including outside the EU, if they meet the requirements)

Number of participants: NA - estimated 50,000 companies to report in the first year

Stakeholder audience: Regulators, Investors, Customers, Employees, Suppliers

Environmental: greenhouse gas emissions, water use, waste management, and biodiversity
Social: employee health and safety, diversity and inclusion, and human rights
Governance: board structure and composition, risk management, and internal controls

Companies will be required to provide quantitative data and qualitative information on their sustainability performance. They will also be required to have their reports audited by an independent third party.

Over 250 employees
More than 40€ million in annual revenue
More than 20€ million in total assets
Publicly-listed equities and have more than 10 employees or 20€ million revenue
International and non-EU companies with more than 150€ million annual revenue within the EU and which have at least one subsidiary or branch in the EU exceeding certain thresholds

Voluntary Sustainability Reporting Standards for Small and Medium-sized Enterprises (VSME) under the Corporate Sustainability Reporting Directive (CSRD)

Themes: Environment, Social, Governance

Best for:

Non-listed SMEs: Particularly those with fewer than 1,000 employees, now outside the mandatory CSRD scope but interested in voluntary sustainability reporting.
SMEs in Large Company Supply Chains: Facilitates standardized ESG data sharing with larger partners required to report under CSRD.
SMEs Seeking Investment or Financing: Enhances transparency and credibility with investors and financial institutions.

Number of participants: While the VSME standard is voluntary, it's anticipated that a significant number of SMEs will adopt it to meet stakeholder expectations and facilitate business relationships, especially as larger companies may prefer or require ESG data from their suppliers.

Stakeholder audience: SME Owners and Managers, Investors and Financial Institutions, Large Corporations, Regulators and Policymakers

Background: Developed by the European Financial Reporting Advisory Group (EFRAG) at the European Commission's request, the VSME standard aims to provide SMEs with a proportionate and practical framework for sustainability reporting. The initiative responds to concerns about the administrative burden of ESG reporting on smaller companies and seeks to harmonize data collection processes across the EU. The standard was delivered to the Commission on December 17, 2024.

Requirements:

Voluntary Adoption: SMEs can choose to adopt the VSME standard based on their specific needs and stakeholder demands.
Modular Reporting:
- Basic Module: Focuses on key ESG indicators such as environmental impact, employee matters, and anti-corruption measures.
- Comprehensive Module: Includes additional disclosures for SMEs aiming for more extensive reporting.
Data Collection and Reporting: SMEs are encouraged to establish internal processes for collecting relevant ESG data and reporting it in a standardized format.

The European Commission's Omnibus Package, introduced in February 2025, proposes several changes affecting the VSME standard and its context within the CSRD:

Revised CSRD Scope: Raises the threshold for mandatory reporting to companies with more than 1,000 employees and either €50 million in turnover or €25 million in total assets, effectively exempting many SMEs from mandatory CSRD reporting.
Promotion of VSME Standard: Encourages voluntary adoption of the VSME standard by SMEs now outside the CSRD scope, facilitating consistent ESG data collection and reporting.
Limitation on Data Requests: Restricts larger companies from imposing extensive ESG data requests on SMEs, aligning such requests with the VSME standard to reduce administrative burdens on smaller firms.
Postponement of Reporting Deadlines: Delays the CSRD reporting requirements for large companies and listed SMEs to 2028, providing additional time for adaptation and implementation.

Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada S-211)

Themes: Human rights, forced labor & child labor prevention

Best for: Canadian companies

Number of participants: NA - takes effect starting January 2024

Stakeholder audience: Investors, Governments, Businesses, Consumers

Background: The Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada S-211) was first introduced in the Canadian Senate in 2021. It received royal assent on May 3, 2023, and will come into effect on January 1, 2024. The Act requires Canadian businesses with a total annual revenue of $20 million or more, or that have 500 or more employees, to report on the steps they have taken to prevent and reduce the risk of forced labour and child labour in their supply chains. The Act is the first law in Canada that specifically requires businesses to report on their efforts to prevent these abuses in their supply chains and gives the Minister of Public Safety and Emergency Preparedness the power to investigate and enforce compliance with the Act. The Canada S-211 standard covers the following themes:

Prevention: Businesses must take steps to prevent forced labour and child labour in their supply chains.
Reducing the risk: Businesses must reduce the risk of forced labour and child labour in their supply chains.
Reporting: Businesses must report on the steps they have taken to prevent and reduce the risk of forced labour and child labour in their supply chains.

Businesses that are required to comply with the Canada S-211 standard will need to submit annual reports to the Minister of Public Safety and Emergency Preparedness.

Global Real Estate Sustainability Benchmark (GRESB)

Themes: Environmental, Social, Governance (ESG) performance (water, energy, waste, community engagement, corporate governance)

Best for: Real estate companies

Number of participants: 9,000+

Stakeholder audience: Investors, Customers, Employees, Suppliers

Background: The Global Real Estate Sustainability Benchmark (GRESB) standard was developed in 2009 by the Global Real Estate Sustainability Council (GRESC), a non-profit organization that promotes sustainability in the real estate industry. The GRESB standard is based on the Global Reporting Initiative (GRI) Standards and is now the leading global benchmark for real estate sustainability performance. GRESB's assessments are based on a set of sustainability performance metrics:

Water: assessment of companies' water management practices, including water use, water efficiency, and water quality.
Energy: assessment of companies' energy management practices, including energy use, energy efficiency, and renewable energy.
Waste: assessment of companies' waste management practices, including waste generation, waste reduction, and waste recycling.
Community: assessment of companies' community engagement practices, including community relations, social impact, and diversity and inclusion.
Governance: assessment of companies' corporate governance practices, including board oversight, risk management, and ethics and compliance.

These metrics are developed by GRESB's technical advisory committee, which is made up of representatives from the real estate industry, investors, and other stakeholders.

GRESB scores companies on their sustainability performance on a scale of 1 to 100, with 100 being the highest score. The GRESB score is a valuable tool for investors, asset managers, and other stakeholders to assess the sustainability performance of real estate companies.

Companies that participate in the GRESB standard are required to submit their reports annually on the GRESB website. The GRESB website is where companies can publish their reports and are made accessible to the public. The submission deadline is July 1st and the portal opens April 1st every year. GRESB is constantly updating its assessments to reflect the latest sustainability trends and best practices.

International Sustainability Standards Board (ISSB - IFRS)

Themes: Environment, Social, Governance with a climate-focus.

Best for: Global public companies

Number of participants: NA - in draft phase, expected to be published end of 2023

Stakeholder audience: Investors and financial markets

Background: The ISSB was created in 2021 by the IFRS Foundation, the same organization that oversees the International Financial Reporting Standards (IFRS). The ISSB is responsible for developing a global set of sustainability disclosure standards that will meet the needs of investors and the financial markets. The ISSB standards will be part of the broader body of International Financial Reporting Standards (IFRS) and are to be known as IFRS-S (“S” for sustainability).

The ISSB will develop a set of sustainability disclosure standards that are aligned with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations and builds off of the Sustainable Accounting Standards Board (SASB) framework. The standards will cover a range of sustainability topics, including climate change, environmental, social, and governance (ESG) factors.

National Health Service (NHS) Evergreen Sustainable Supplier Assessment

Themes: net zero alignment, sustainability maturity scoring, standardized ESG reporting

Best for:

Current and Prospective NHS Suppliers: Especially those involved in NHS Supply Chain frameworks or NHS England Medicines tenders.
SMEs and VCSEs: Small and medium-sized enterprises and voluntary, community, and social enterprises seeking to demonstrate sustainability commitments.
Sustainability-Conscious Organizations: Companies aiming to benchmark and improve their ESG performance in alignment with NHS priorities.

Number of participants:

While specific participation numbers are not publicly disclosed, the NHS engages with approximately 80,000 suppliers. As of February 2024, submission of the Evergreen Assessment is mandatory for:

Suppliers on NHS Supply Chain Frameworks: Required to submit the assessment by February 1, 2024.
Bidders for New NHS Supply Chain Frameworks: Must include the assessment as part of the tendering process.
NHS England Medicines Tenders: All suppliers must submit the assessment from January 2024.

These requirements aim to standardize sustainability reporting across NHS suppliers.

Stakeholder audience: NHS Procurement Teams, Suppliers, Patients and the Public

Background: The NHS Evergreen Sustainable Supplier Assessment is a self-assessment and reporting tool developed by NHS England to support its net zero and sustainability ambitions. It enables suppliers to:

Engage with NHS Sustainability Goals: Understand and align with the NHS Net Zero Supplier Roadmap.
Benchmark Sustainability Practices: Assess current sustainability efforts and receive a maturity score indicating alignment with NHS priorities.
Facilitate Data Sharing: Provide a single route for sharing sustainability information with NHS procurement teams.

The assessment is part of the NHS's broader strategy to reduce its carbon footprint, with over 60% of its emissions attributed to the supply chain.

Requirements:

Annual Submission: Suppliers must complete the assessment annually, with the option to update it throughout the year as needed.
Carbon Reduction Plan (CRP): From April 2024, all suppliers are required to publish a CRP addressing UK Scope 1 and 2 emissions, and a subset of Scope 3 emissions.
Maturity Levels:
- Level 1: Public commitment to net zero and engagement with sustainability.
- Level 2: Comprehensive net zero targets and emissions reporting.
- Level 3: 2045 net zero targets independently validated.
- Level 4: 2045 net zero targets independently validated across the global organization.
Mandatory for Specific Contracts: Required for NHS Supply Chain frameworks and NHS England Medicines tenders

Norwegian Transparency Act (Åpenhetsloven)

Themes: human rights and decent working conditions, transparency and public access, risk-based due diligence

Best for: Large enterprises, supply chain partners

Number of participants: Approximately 9,000 companies are directly affected by the Transparency Act. This includes both Norwegian and foreign enterprises that meet the defined criteria.

Stakeholder audience: Regulators, Investors, Civil Society

Background: The Norwegian Transparency Act, effective from July 1, 2022, aims to promote transparency and accountability in business operations concerning human rights and working conditions. It aligns with international standards, including the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

Applicability

The Act applies to companies that:

Are resident in Norway or foreign companies offering goods or services in Norway and are taxable in Norway.
Meet at least two of the following three criteria:
- Annual turnover exceeding NOK 70 million.
- Balance sheet total over NOK 35 million.
- Average of 50 full-time employees during the financial year.

Obligations

Due Diligence Assessments: Conduct regular assessments to identify and mitigate actual or potential adverse impacts on human rights and decent working conditions throughout the supply chain.
Annual Reporting: Publish an annual report by June 30 detailing due diligence activities, identified risks, and measures taken. The report must be publicly accessible and approved by the company's board.
Responding to Information Requests: Provide information within three weeks to any individual requesting details on how the company addresses adverse impacts, unless exceptions apply.

Enforcement and penalities

The Norwegian Consumer Authority oversees compliance. Non-compliance may result in fines of up to 4% of annual turnover or NOK 25 million, whichever is higher.

Streamlined Energy and Carbon Reporting (SECR)

Themes: Energy use, carbon emissions

Best for: Large companies in the UK, 250+ employees, £36 million+ annual turnover

Number of participants: 10,000+ large organizations

Stakeholder audience: Organizations, investors, regulators

Background: In 2019, the Streamlined Energy and Carbon Reporting (SECR) standard was introduced in response to the UK government's commitment to reduce greenhouse gas emissions by 80% by 2050. The standard is part of a wider effort by the UK government to improve the environmental performance of large organizations looking at not only GHG emissions, but also efforts taken to improve energy efficiency. The SECR standard covers three main themes:

Energy use: Organizations must report their total energy use, as well as the energy use for different types of activities, such as heating, lighting, and transportation.
Carbon emissions: Organizations must report their total carbon emissions, as well as the carbon emissions for different types of activities.
Energy efficiency measures: Organizations must report on the energy efficiency measures that they have implemented, such as installing energy-efficient lighting or insulation.

Annual SECR reporting is mandatory for the following companies:

All quoted companies (i.e. companies listed on the public exchange), who are already required to comply with greenhouse gas reporting
‘Large’ unquoted companies that are incorporated in the UK
‘Large’ Limited Liability Partnerships (LLPs)

According to the Companies Act 2006, companies are considered ‘large’ if they meet at least two of the following criteria:

A turnover of at least £36 million
A balance sheet of at least £18 million; or
At least 250 employees

Exemptions include companies that use a low level of energy (40MWh or less per reporting period) as well as organizations and those undertaking public activities, such as charities, universities, hospitals and academies.

Sustainability Accounting Standards Board (SASB)

Themes: ESG Financial Risk

Best for: Large Companies

Number of participants: 4,000

Stakeholder audience: Investors

Background: In August 2022, the International Reporting Standards (IFRS) Foundation merged with the global non-profit Value Reporting Foundation (VRF) and assumed responsibility for the SASB standard. The IFRS Foundation created the International Sustainability Standards Board (ISSB) to respond to a demand for transparent financial-related sustainability disclosures by companies. The ISSB has committed to building on the work of existing investor-focused initiatives like the SASB standards and the TCFD (Task Force on Climate-related Financial Disclosures) recommendations into its standards. The ISSB has launched a draft IFRS Sustainability Disclosure Standards. The IFRS Foundation encourages companies to keep using the SASB standards which will help report preparers meet immediate needs of investors while laying the groundwork for adoption of the IFRS Sustainability Disclosure Standards in the near future.

The Sustainability Accounting Standards Board (SASB) provides non-financial, sector-specific sustainability reporting standards and is designed to help companies disclose financially-material sustainability information to investors. SASB identifies the subset of environmental, social, and governance issues most relevant to financial performance in each of its 77 industries including: consumer goods, extractives & minerals processing, financials, food & beverages, health care, infrastructure, renewable resource & alternative energy, and resource transformation.

Science Based Targets Initiative (SBTi)

Themes: Greenhouse gas emissions reduction, net-zero emissions

Best for: Companies, financial institutions

Number of participants: 2,000+

Stakeholder audience: Companies, Investors, Regulators

Background: The Science Based Targets Initiative (SBTi) call to action strives to show companies and financial institutions the urgency in the need to reduce their greenhouse gas emissions to avoid the worst impacts of climate change. By using the latest climate science, the SBTi aims to guide market participants in setting ambitious reduction targets on their way towards achieving net-zero. The SBTi is a partnership between CDP, the United Nations Global Compact, World Resources Institute (WRI) and the World Wide Fund for Nature (WWF). The SBTi defines and promotes best practice in emissions reductions and provides technical assistance to companies who set science-based targets in line with the latest climate science. The SBTi standard covers four main themes:

Ambition: Companies must set ambitious targets to reduce their greenhouse gas emissions.
Alignment: Companies must align their targets with the latest climate science.
Transparency: Companies must disclose their targets and progress in achieving them.
Accountability: Companies must be held accountable for their targets.

Participating companies and institutions submit annual progress reports to the SBTi.

Sustainable Financial Disclosure Regulation (SFRD)

Themes: Financial market - disclosure on environmental, social and governance factors in investment processes & products

Best for: Financial market participants that offer products or services , investment advice, portfolio management services

Number of participants: Estimated to apply to 10,000+ financial market participants in the EU

Stakeholder audience: Investors, clients, employees, regulators, and the general public

Background: The Sustainable Financial Disclosure Regulation (SFDR) was adopted by the European Parliament and the Council of the European Union in June 2020. The SFDR is intended to be a stepping stone towards a more sustainable financial system. Under the SFDR, financial market participants, including banks, investment firms, pension funds, and financial advisors are required to disclose how they incorporate ESG considerations into their financial products or advice services. The aim is to bring more transparency to investment products with sustainability-related claims, improve comparability and help investors understand the impacts of their investment decisions.

In April 2022, the European Commission adopted the Delegated Regulation, which is a complementary piece of legislation to the SFDR. Together, the SFDR and Delegated Regulation work to improve the transparency of sustainable investment products and services in the European Union. The SFDR sets out the general requirements for disclosure, while the Delegated Regulation provides more detailed guidance on how to comply with these requirements. Key provisions of the Delegated Regulation:

Definition of sustainable investment products - those that have a sustainable investment objective and that integrate ESG factors into their investment process.
Disclosure requirements for sustainable investment products - include information about the product's sustainable investment objective, the ESG factors that are integrated into the investment process, and the performance of the product.
Disclosure requirements for financial market participants - include information about their policies and processes for integrating ESG factors into their investment processes and products.

Financial market participants annually submit their SFDR disclosures to the national regulatory authorities in each member state of the European Union.

Swiss Ordinance on Climate Disclosures

Themes: climate transparency, double materiality, net-zero alignment

Best for: large public companies, financial institutions, investors and stakeholders

Number of participants: While exact numbers are not specified, the ordinance applies to companies that meet the following criteria:

Average of 500 or more full-time employees.
Either CHF 20 million in total assets or CHF 40 million in turnover.

This encompasses a significant portion of large Swiss enterprises and financial institutions.

Background: The Swiss Ordinance on Climate Disclosures was adopted by the Federal Council on 23 November 2022 and came into force on 1 January 2024. It mandates large Swiss companies to publicly report on climate-related risks, impacts, and their strategies to mitigate these effects. The ordinance aligns with international frameworks, notably the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). In December 2024, the Federal Council initiated a consultation to amend the ordinance, aiming to align it with evolving international standards, such as the European Sustainability Reporting Standards (ESRS) and the International Sustainability Standards Board (ISSB) guidelines. The proposed amendments also include requirements for companies to publish net-zero roadmaps and to report in machine-readable electronic formats.

Requirements

Applicability: Companies with 500 or more full-time employees and either CHF 20 million in total assets or CHF 40 million in turnover.
Reporting Obligations:
- Governance: Describe the organization's governance around climate-related risks and opportunities.
- Strategy: Disclose the actual and potential impacts of climate-related risks and opportunities on the organization's businesses, strategy, and financial planning.
- Risk Management: Describe how the organization identifies, assesses, and manages climate-related risks.
- Metrics and Targets: Disclose the metrics and targets used to assess and manage relevant climate-related risks and opportunities.
Transition Plans: Outline strategies to achieve net-zero greenhouse gas emissions by 2050, including interim targets and measures.
Publication: Reports must be published in both human-readable and machine-readable electronic formats and made available on the company's website.

Themes: Climate-related risks & opportunities

Best for: Large companies, complex organizations exposed to significant climate-related risks and opportunities

Number of participants: 1,400+

Stakeholder audience: Investors, Regulators, Policy makers

Background: The G20 Finance Ministers and Central Bank Governors asked the Financial Stability Board (FSB) to see how the financial sector could better incorporate climate-related issues. In response, the FSB created the Task Force on Climate-related Financial Disclosures (TCFD) to develop recommendations on the type of information that companies should disclose to help investors, lenders, and insurance underwriters appropriately assess and price risks related to climate change.

The TCFD recommends structuring disclosures around four thematic areas that represent core elements of how organizations operate: Governance, Strategy, Risk management and Metrics and targets - all from the perspective of climate-related risks and opportunities.

Themes: Nature, biodiversity, ecosystem degradation

Best for: All businesses and financial institutions of different sizes and across sectors and jurisdictions

Number of participants: NA - in draft phase

Stakeholder audience: Companies, Financial institutions, Investors, Regulators

Background: The Task Force on Nature-related Financial Disclosures (TNFD) was created in response to the growing need to consider nature-related risks and opportunities in financial and business decisions as well as to halt the acceleration of nature loss across the globe. In June 2021, TNFD was officially launched with support by financial institutions, corporates, governments and civil societies. The standard is based on the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, which are widely used by companies and financial institutions to disclose their climate-related risks and opportunities. The TNFD standard covers four main themes:

Nature-related dependencies: Focus on natural resources that companies and financial institutions rely on, such as water, land, and biodiversity.
Nature-related impacts: Focuses on the positive and negative impacts that companies and financial institutions have on nature.
Nature-related risks: Focuses on the risks that companies and financial institutions face from nature, such as climate change, biodiversity loss, and water scarcity.
Nature-related opportunities: Focuses on the opportunities that companies and financial institutions can seize from nature, such as sustainable agriculture, renewable energy, and ecotourism.

Transition Plan Task Force

Themes: Net zero, climate transition

Best for: business in the UK. Currently, only listed issuers and FCA (Financial Conduct Authority)-regulated asset managers and owners are mandated to disclose their transition plans. However, this requirement operates on a "comply or explain" basis, allowing these businesses to forego disclosing transition plans if they can provide a reasoned explanation.

Number of participants: NA

Stakeholder audience: Companies, Financial institutions, Investors, Regulators

Background: In a landmark move towards sustainability, the UK Transition Plan Taskforce (TPT) unveiled its transition plan disclosure framework at the London Stock Exchange on October 9, 2023. This framework is expected to be a game-changer, challenging businesses to move faster toward a low greenhouse gas (GHG) emissions economy.

United Nations Sustainable Development Goals (SDG)

Themes: Set of 17 goals designed to end poverty, protect the planet, ensure prosperity for all

Best for: All

Number of participants: 193 participating countries

Stakeholder audience: All - governments, businesses, civil society organizations, individuals

Background: The United Nations Sustainable Development Goals (SDGs) were created in response to the Millennium Development Goals (MDGs), which were a set of eight goals that were adopted by the United Nations in 2000. The MDGs were successful in reducing poverty and improving health and education. The SDGs expand upon the MDGs as a more ambitious set of goals that aim to address a wider range of issues. The SDGs are divided into three categories with a total of 17 interconnected goals due to be achieved by 2030 and are universal, applying to all countries regardless of level of development:

Economic goals - economic growth, employment, and infrastructure.
Social goals - poverty, health, education, and gender equality.
Environmental goals - climate change, water, and biodiversity.

SDG commitments are voluntary; the process and frequency for submitting SDGs varies depending on the report writer. Some organizations may choose to submit their SDGs annually, while others may choose to submit them biennially or even less frequently. Organizations can submit their SDGs to the United Nations Sustainable Development Solutions Network (SDSN). The SDSN is a global network of organizations that are working to achieve the SDGs. The SDSN provides a platform for organizations to share their SDG commitments and progress.

Governments can submit their SDGs to the United Nations High-Level Political Forum on Sustainable Development (HLPF). The HLPF is a forum where governments report on their progress in implementing the SDGs. Governments are required to submit their SDGs to the HLPF every four years.

United Kingdom Modern Slavery Act 2015

Themes: consolidation of offences, viticim protection, transparency in supply chains

Best for: large commercial organisations, legal and compliance professionals, investors and consumers

Number of participants: Approximately 17,000 UK companies are estimated to fall within the scope of the Act's reporting requirements. However, compliance rates have been inconsistent, with many companies failing to meet the Act's expectations.

Stakeholder Audience: UK Government and Regulator Bodies, Non-Governmental Organisations, General public

Background: The United Kingdom Modern Slavery Act 2015 was enacted to address the growing concerns of modern slavery and human trafficking. It consolidates previous offences and introduces new measures to enhance law enforcement capabilities, protect victims, and increase transparency in business practices. Notably, the Act's Section 54 requires large businesses to publish annual statements detailing steps taken to ensure slavery and human trafficking are not present in their operations or supply chains.

Requirements:

Applicability

The Act applies to commercial organisations that:

Operate in the UK.
Supply goods or services.
Have an annual turnover of £36 million or more.

Modern Slavery Statement

Organisations meeting the above criteria must:

Publish an annual statement within six months of the financial year-end.
Detail steps taken to prevent modern slavery in their business and supply chains.
Include information on:
- Organisation structure and supply chains.
- Policies related to slavery and human trafficking.
- Due diligence processes.
- Risk assessment and management.
- Key performance indicators to measure effectiveness.
- Training on modern slavery and trafficking.
Ensure the statement is approved by the board of directors and signed by a director.
Publish the statement prominently on the organisation's website

Enforcement

Currently, there are no direct penalties for non-compliance. However, the government has indicated intentions to introduce stricter enforcement measures, including potential financial penalties and a single reporting deadline, to enhance compliance.

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