No. 213: Politics of Sustainability Reporting: Evidence from NGO Involvement

NGOs have become an increasingly important actor in the development of sustainability disclosure rules, and public consultations from 2016 to 2023 reveal how they engage in this process. But their participation remains far lower than that of corporate preparers, creating an imbalance in who provides input to emerging standards. Therefore, we analyze NGO involvement and their preferred reporting obligations using EU, EFRAG, and ISSB consultations, NGO statements, and interviews. We find that NGOs participate selectively but consistently advocate for broad, high-ambition disclosure requirements, especially for high-risk sectors and high-impact topics. Their positions often diverge from corporate preparers yet align with financial preparers. While some demands initially informed the CSRD, subsequent political changes, particularly the Commission’s Omnibus amendments, diluted key provisions and reduced NGOs’ willingness to invest their technical expertise in the standard-setting process.