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FoSDA Report on Interoperability

Report on Interoperability

Lost in Translation

The case for a common understanding of sustainability-related disclosures

Foreword

Standardisation matters. It is a practical requirement for improving efficiency, promoting a common understanding and lowering costs. Standardisation of shipping containers, railway gauges and financial reporting all solved problems that had arisen over time when different devices were designed to achieve similar objectives, but their incompatibility exposed problems.  

Standardisation is still needed, including for sustainable data. The significant progress made in recent years to standardise sustainability-related disclosures around the world has created a sense of optimism that the preparation and use of sustainable data is set to become more efficient, more understandable and more comparable. But while sustainability disclosure standard setters are careful to address interoperability in principle as standards are developed, comparability can be lost in practice when details about reporting boundaries, periodicity and estimation approaches may be vague and differ.

Sustainability-related data can support the decision-making that drives investment, resource allocation and risk management. But the work required to normalise and standardise that data slows delivery, raises costs and creates scope for divergence. Greater harmonisation, supported by concordance and digital tagging, would improve compatibility, lower costs and enhance data quality, particularly for AI-enabled analysis. Harmonisation would bring benefits across the ecosystem – to reporting companies and to investors and other data users.

The Future of Sustainable Data Alliance (FoSDA) champions consistent, comparable and coherent sustainable data. With more robust sustainability-related disclosure standards being mandated or encouraged around the world, sustainable data availability and quality are set to improve. But comparability is likely to remain a challenge without further attention.

This report considers how increased interoperability could address practical issues across the sustainable data ecosystem, from companies and their supply chains to investors and other users.  

We are grateful to the many individuals and organisations that have contributed to this report, including FoSDA members and those we interviewed from investor and corporate bodies, accountancy firms, standard setters and digital reporting technology bodies, and to Hilary Eastman of Confluence Advisory for authoring it. We look forward to working with them and other stakeholders on enhancing interoperability in sustainability-related disclosure standards.

FoSDA members in the interoperability working group:

Mariem Berbiche,
Sustainable Finance Data & Regulations, Bloomberg L.P.

Tatiana Diaz,
Head of Policy Projects & Partnerships, CDP

Patricia Pina,
Chief Research Officer, Clarity AI, Inc.

Victoria Chartier,
Director of Public Affairs, EcoVadis Inc.

David Harris,
Head of Sustainable Finance Strategic Initiatives, LSEG (London Stock Exchange Group)

Simone Ruiz-Vergote,
Head of Sustainable Finance Policy Research, MSCI, Inc.

Alexie Duncker,
ESG Analyst, S&P Global, Inc.

Ozan Atak,
Lead Analyst, ESG Methodology, Sustainalytics B.V.

 

FoSDA publications are the work of the Future of Sustainable Data Alliance and might not exactly reflect the views of any individual FoSDA member.

 

Executive summary

Sustainability-related disclosures are becoming more standardised, but differences in the details reduce understandability, increase costs and limit comparability.

This report examines interoperability challenges in sustainability disclosure standards, the implications for market participants and the opportunities to enhance the consistency, comparability and usability of sustainability-related information by applying a precision focus to address the challenges. The report aims to encourage standard setters, policymakers, companies, investors and data providers to work together to improve sustainable data availability and quality.

Aiming for clarity and consistency

The International Sustainability Standards Board’s (ISSB) IFRS Sustainability Disclosure Standards (SDS) and the European Sustainability Reporting Standards (ESRS) are increasingly important disclosure regimes globally. Both can improve the availability and

quality of sustainability-related information, but differences in scope, application and jurisdictional adoption create comparability challenges.1 

These two disclosure regimes should improve sustainable data, including when combined with voluntary, often impact-driven, reporting frameworks such as the Global Reporting Initiative (GRI) Standards. However, despite high-level alignment and common core concepts, detailed differences create comparability challenges, especially as more jurisdictions adopt – and in some cases adapt – them.


Key terms used in this report

Comparability: Comparable disclosures allow market participants to assess performance, risks and prospects across companies. Data points do not need to be identical to be comparable; differences can enhance comparability when they are transparent and understood. Comparability is not the same as uniformity, although the concepts are often used interchangeably in discussions about interoperability.

Concordance: A structured technical mapping showing how disclosure requirements, data points or taxonomy elements correspond across reporting frameworks and precisely where they are identical, similar or different.

Digital tagging: The process of applying taxonomy-based, machine-readable labels to sustainability-related disclosures so that reported metrics and narrative information can be consistently identified, extracted, compared and analysed across companies, reporting periods and disclosure regimes.

Harmonisation: The process of minimising unnecessary differences between disclosure standards, while retaining differences needed for jurisdictional objectives.

Interoperability: The ability of different sustainability-related disclosure standards to be aligned such that reported information can be understood, compared, reconciled and used effectively, without unnecessary duplication, complexity or loss of meaning, even when differences in requirements exist.

Figure 1. The sustainable data ecosystem

In practice, limited interoperability fragments the flow of information used for capital and resource allocation creating costs for companies, investors and data providers through duplicated preparation, assurance, interpretation, analysis, normalisation and standardisation activities.

Data providers help deliver coherent, consistent and comparable sustainable data by collating, validating and standardising corporate data, filling gaps and estimating data points where needed.

Achieving comparable and understandable sustainability-related data

Three principles may help improve interoperability: a set of common disclosures; consistent terminology, definitions and methodologies; and digitalisation of data, supported by concordance and harmonisation.


Principle 1: A core set of common disclosures

A core set of agreed disclosures, including metrics, supplemented by jurisdiction-specific information, would improve comparability for the data points and narrative information most important to decision-making.


Principle 2: Consistent terminology, definitions and methodologies

Comparability depends on common terminology, definitions, scopes and measurement approaches, so users do not assume comparability where differences exist. Differences in materiality, reporting scope, reliefs and presentation should be minimised where they are not necessary.


Principle 3: Digitalisation of sustainability-related disclosures

Digital tagging and machine readability, supported by a concordance mapping framework, would improve comparability, enable more reliable data use and support AI-enabled analysis, supporting the prior principles.

Moving towards harmonisation

Interoperability should support better decision making through clearer, more comparable information. A coordinated concordance exercise could identify differences across regimes, assess their significance and support harmonisation where appropriate. A practical framework for doing this could include the following steps:


Framework for moving towards harmonisation of sustainability-related disclosure standards

Step 1: Analysis of what the differences are

Precisely map disclosure requirements across disclosure standards to identify where they are equivalent, similar, different or absent. This concordance exercise would cover both the content of disclosures and the structure of data, and include the respective digital taxonomies, so that differences are specific and visible and can inform future harmonisation efforts.

Step 2: Assessment of the significance of the differences identified

Not all differences will affect decision-making, so each difference should be assessed for whether it changes how information is understood, interpreted or used. Significant differences are likely to include situations when the same concept is described differently, when similar wording has different meanings or when requirements diverge altogether.

Step 3: Determination of the approach needed for resolving significant differences

Significant differences would then be grouped according to whether they should be eliminated, minimised or remain for jurisdiction-specific reasons. Where differences remain, the rationale should be clearly explained and common approaches developed for interpreting or adjusting the information to support comparability.

Implementation of such a framework would require input from stakeholders across the sustainable data ecosystem, including companies, assurance providers, investors and other sustainable data users, data providers and standard setters.

Continuing the discussion

Addressing the issues explored in this report requires engagement across the sustainable data ecosystem. The questions below are intended to build on ongoing discussions about interoperability and focus on what should happen next, including practical constraints and potential unintended consequences.

Question 1:
Could harmonisation lead to a set of common disclosures across standards? If so, how could common definitions, methodologies and terminology be agreed?

Question 2:
Would a concordance mapping framework support the sustainable data ecosystem? If so, how could it be developed?

Question 3:
Should structured disclosure formats and digital tagging be pursued to help improve machine readability, including for AI, and promote comparability across regimes, borders and companies?

 

Aiming for clarity and consistency

Sustainability factors can affect business performance and risk exposures, and companies and their capital and other resource providers increasingly recognise that they may need to be aware of and understand them. 

That recognition has led to the development of many sustainability reporting frameworks over time, but having multiple approaches has created comparability challenges.

“We believe our returns depend on sustainable development in economic, environmental and social terms. We need consistent, comparable, and reliable sustainability information to assess companies’ long-term prospects.”

– Norges Bank Investment Management 2

Global roll-out of sustainability-related disclosure standards

Mandatory sustainability reporting is now developing at an unprecedented scale. Although the trend has been growing for over two decades, jurisdictional requirements and voluntary frameworks were often inconsistent, prompting calls to end the so-called ‘alphabet soup’ and leading to the formation of the International Sustainability Standards Board in 2021.

The ISSB aims to establish a global baseline of high-quality, comprehensive and cost-effective sustainability-related financial disclosures focused on investors’ needs. Its standards address sustainability-related risks and opportunities that may affect a company’s cash flows, access to finance or cost of capital over time (that is, what is financially material to a company). Other standard setters, such as the European Financial Reporting Advisory Group (EFRAG) and the GRI, address other stakeholder information needs and take a double materiality approach (that is, also including the impacts a company has on society and the environment, some of which can be financially material).

Figure 2. The evolution of sustainability-related disclosure standards and frameworks

Many reporting frameworks and standards have developed over the years, giving rise to calls by companies, investors and others to minimise the so-called ‘alphabet soup’ that was created.

ESG Disclosure Pathway to Convergence

30+ years

Adapted from IFC, 2026

The first two IFRS SDS (also commonly referred to as the ISSB Standards), IFRS S1 and IFRS S2, cover general requirements and climate-related disclosures. They include requirements to disclose industry-specific metrics, supported by the Sustainability Accounting Standards Board’s (SASB) industry-based guidance. In addition to containing general requirements and reporting principles, IFRS S1 applies for sustainability issues beyond climate. The ISSB plans to publish proposals for nature-related disclosures later in 2026 (in the form of a practice statement3), with work on workforce-related issues
also underway.

ESRS, developed by EFRAG and adopted by the European Commission, are used for applying the EU Corporate Sustainability Reporting Directive (CSRD). They include two general and 10 topical standards, with a separate standard being developed for non-EU groups within the scope of CSRD (the ESRS-40a exposure draft).4

ESRS uses two materiality perspectives:

  • financial materiality, which focuses on effects on a company’s development, financial position, financial performance, cash flows, access to finance or cost of capital over time; and

  • impact materiality, which focuses on the positive or negative effects a company has (or could have) on the environment or society.

Some sustainability matters are material from both perspectives, which is referred to in ESRS as ‘double materiality’. The distinction between the two perspectives can blur when impacts can give rise to financially material risks or opportunities over time.

Together, IFRS SDS and ESRS are likely to improve corporate sustainability-related disclosures by adding clearer requirements, more granularity and more robust measurement approaches, while showing the link between sustainability and financial performance. 

Application of both IFRS SDS and ESRS is growing globally. As of July 2026, nearly 40 jurisdictions to-date are adopting, using or aligning their local reporting regime with IFRS SDS.5  The CSRD’s phasing in of in-scope European companies, and the forthcoming application by non-EU group parent companies, is increasing the number of companies applying ESRS around the world. IFAC’s latest The State of Play report found that about one-third of companies in their research mentioned their plans for the use or future use of the ISSB Standards, up from 16% in 2023. In addition, non-European companies mentioned the use or future use of ESRS, with most of those references coming from the UK (10% of UK companies examined) and South Korea (20% of South Korean companies examined).6


Assurance and market readiness

CSRD requires limited assurance over the information reported in ESRS sustainability statements.7 For IFRS SDS, assurance requirements, if any, are determined by each jurisdiction as they decide to adopt or otherwise use IFRS SDS locally.8  Decisions about assurance centre around the readiness of companies (including the availability of data and maturity of internal reporting and governance processes), assurance providers and regulators to prepare for, perform and enforce the requirements, respectively. This is balanced by the level of confidence investors and other stakeholders need to have in the reliability of the reported information. Regardless of formal assurance requirements, verifiability of sustainability-related information is embedded in the foundational principles of both IFRS SDS and ESRS.9

However, there is a risk that assurance requirements are introduced before the reporting requirements become more routinely applied and standardised across the board, constraining some of the clear benefits to having assurance over sustainability-related information. Such benefits include, from an interoperability perspective, improving consistency in interpretation and application and helping raise the bar for sustainability-related disclosures to be on par with the quality and robustness of financial disclosures. Therefore, while fragmentation in assurance requirements can hinder comparability, it is also important that each jurisdiction introduce such requirements only when their local market is ready for them.

Comparability challenges and the call for interoperability

While we have seen the potential these new standards have to improve data availability and quality, we’ve also seen comparability issues arise as companies apply (or prepare to apply) them.

The following situations can bring comparability challenges:

  • Companies in the same industry can apply IFRS SDS, ESRS or a voluntary framework, producing disclosures that are difficult to compare, especially beyond climate. Figure 3 below illustrates this situation.

  • A company subject to multiple requirements may need to reconcile IFRS SDS and ESRS (and potentially a voluntary framework), while keeping its reporting coherent and manageable.

  • A group with subsidiaries applying IFRS SDS differently across jurisdictions may need to reconcile those differences in its consolidated disclosures. 

Stakeholders have called for increased interoperability because divergent approaches can require reconciliation across IFRS SDS, ESRS, jurisdictional adaptations and voluntary frameworks such as the GRI Standards, the Taskforce on Nature-related Financial Disclosures (TNFD) and others.10 In addition, some major capital markets are developing their own mandatory frameworks. For example, China is developing its Corporate Sustainability Disclosure Standards for Business Enterprises based on IFRS SDS and using a double materiality concept aligned to ESRS. Although interoperability is now widely discussed in sustainability standard setting, it is not always clear what people mean by it or expect from it.11 Recent cooperation agreements and mappings aim to reduce duplication and improve clarity for companies, investors and other users. Examples include the EFRAG-ISSB joint interoperability guidance on climate-related disclosures,12 the memorandum of understanding (MOU) between GRI and the IFRS Foundation,13 the MOU between GRI and EFRAG14 and the mapping between the TNFD framework and ESRS.15

Recent European Commission and EFRAG comments reinforce the importance of keeping ESRS ambitious while improving interoperability with global sustainability reporting standards, including the ISSB Standards.16

“…it is equally important that the European framework remains ambitious but interoperable with the wider world, including with the ISSB standards. High-quality reporting should facilitate global investment and comparability, not create unnecessary fragmentation.”

– European Commissioner Maria Luís Albuquerque 17

These efforts help, but interoperability seems to be easier to achieve in principle than in practice. At a high level, IFRS SDS and ESRS both require climate-related disclosures and overlap on matters such as greenhouse gas (GHG) emissions, transition plans and remuneration  implications. In the detailed requirements, however, they diverge. As a result, applying multiple disclosure standards can be complicated and costly for companies, and the resulting disclosures can make it difficult for investors and other decision makers to compare companies within sectors and across markets. We see interoperability as necessary to clarify the meaning of sustainable data prepared using different standards so that it can be used effectively for decision making. Without that clarity, a metric’s understandability can be limited, it may not be clearly comparable and, as a consequence, it cannot meaningfully be used.

“The next phase of corporate reporting is about making the various disclosure frameworks speak to each other so that sustainability information, financial performance, strategy and risk form one coherent account of the company.”

– European Commissioner Maria Luís Albuquerque 18

Example 1. Effective mapping across transition plan disclosures requires a focus on the detail


The challenge

Different drafting styles and granularity can make standards difficult to map, even where they are broadly interoperable.

The situation

For transition plans, for example, IFRS S2 requires disclosure of information about the plan, key assumptions and dependencies.19 It has a separate dedicated technical guidance document based on the work of the Transition Plan Taskforce (TPT). ESRS is more granular than IFRS S2 (and less detailed than the TPT-based guidance), requiring specific details such as emissions reduction targets, decarbonisation levers, key actions, investments and funding needed to support implementation of the plan, approval of the plan by the relevant governance bodies and how the plan is embedded in and aligned with the overall business strategy.20

The consequence

This ‘one-to-many’ mapping is difficult to standardise and leaves room for interpretation. A common set of directly mapped disclosures (i.e., on a one-to-one basis) would help reduce the risk of misinterpretation and leave only necessary jurisdiction-specific gaps.

The costs of disclosure fragmentation

A lack of interoperability fragments information flows and creates financial and opportunity costs for multinational companies, investors and other users evaluating opportunities and comparing performance across markets.

Regulatory fragmentation can create costs through duplicative reporting, differing definitions and inconsistent interpretation or enforcement. Although earlier studies focused on financial  regulation,21 many of the same concerns now arise in sustainability reporting. 

Fragmentation also reflects differences in terms of which companies are required to report. In Europe, for example, the Omnibus I Directive narrowed the population subject to mandatory ESRS reporting, while a voluntary standard can be used by companies outside the scope of CSRD. As value chains increasingly contain information prepared using either mandatory ESRS, voluntary ESRS,

the forthcoming ESRS for non-EU groups, IFRS SDS or no formal framework at all, consistency across disclosure requirements and data points becomes more important to preserve comparability.

The role of data providers in the reporting ecosystem

A lack of interoperability affects not only companies and investors, but also the sustainable data providers in the reporting ecosystem.

“Standards and policies help create common definitions of ESG issues, including shared expectations of the metrics needed to measure sustainability performance.”

– OECD 22

Investors and other users get sustainable data either directly from companies or, more commonly, through data providers. These providers help deliver coherent, consistent and comparable data for capital market participants and to companies seeking to access and participate in financial markets (so that they can assess suppliers or respond to client data requests, including in procurement processes).

Data providers support decision making by collating, validating and standardising corporate sustainable data, filling gaps and making estimates where needed, improving the availability and understandability of disparate and sometimes incomplete data sets. IOSCO has observed that when corporate sustainability-related disclosures lack consistency, investors may need to rely more on ESG ratings and data products.23

Figure 3. How sustainable data travels through the ecosystem

Sustainable data starts from disclosure standards and frameworks. It moves through companies and their value chains to users of the data, either directly or via data providers. When companies, even in the same industry, follow different disclosure rules, structurally different data can reach investors and other sustainable data users, potentially weakening comparability and the decisions built on it.


The introduction of mandatory sustainability disclosure standards has the potential to significantly improve the quality and availability of corporate sustainable data – the starting point for the data reported in most providers’ platforms.


Comparable data ideally needs a consistent starting point

Standards-level differences 

Disclosure requirements need precise definitions, presentation units, boundaries and methodologies so users can understand what differs across regimes and map requirements appropriately. Differences also arise when one standard includes topics or data points absent from another, especially when they partially – but not precisely – cover the same data points. Assurance requirements also differ across jurisdictions.

Company application differences

Companies may make different judgements and interpretations (including about what is material), use different reliefs and apply requirements differently.24 The involvement of reporting software platforms can also influence companies’ application of the requirements. Transparency about choices, omissions, scopes, methodologies, underlying data and assumptions is needed to understand trends, targets and performance.25

As a result, structurally different data can reach sustainable data users, weakening comparability and increasing the risk that decisions rely on only an approximation of comparability.

Data providers need transparent, granular information, including calculation methods and assumptions, to validate, normalise and standardise corporate data, and to explain how they have done so. Published data points often combine reported corporate information with other sources, so clarity about inputs is essential.

IOSCO has observed that the quality of sustainable data depends on the quality of corporate disclosure, noting that users expect improvements in disclosure to improve the consistency of ESG ratings and data products.  Its workstream on sustainability-related disclosures for issuers sought “to drive much-needed international consistency and comparability in sustainability-related information…” as essential information for methodologies used in developing such products.27

Managing necessary differences

Although differences across disclosure regimes should be minimised, some will remain because jurisdictions have different environmental, economic and social priorities. For example, South Africa may need information on Black Economic Empowerment, while the EU requires information about impacts as well as risks and opportunities.

Because legal, cultural and regulatory issues affect companies’ risk exposures and prospects, jurisdictional requirements will legitimately reflect local:

  • sustainability goals and priorities
  • legal and regulatory framework 
  • cultural context, including stakeholder expectations
  • sustainable finance objectives.

Where priorities overlap, standard setters and regulators should minimise differences and ensure jurisdictional requirements work coherently alongside IFRS SDS without duplication and complex reconciliation. In IOSCO’s endorsement of the ISSB Standards, it suggested that its members “…consider ways in which [you] might adopt, apply or otherwise be informed by the ISSB Standards, within the context of [your] jurisdictional arrangements, in a way that promotes consistent and comparable climate-related and other sustainability-related disclosures for investors.”28

Example 2. Interoperability challenges when preparing local- and global-level disclosures


The challenge

Local reporting obligations often rely on highly specific definitions and methodologies that may align with the requirements in global or regional reporting frameworks.

The situation

When it comes to environmental disclosures, the following differences can arise:

  • GHG emissions: Regional differences in the emission factors used to convert activities into an estimate of the GHG emissions released can introduce complexity and reporting risk, such as when different countries require different sources of emission factors.
  • Volatile organic compounds: Country- and region-specific legislation can drive variation, including different calculation methodologies (e.g., using an invoice-based system versus a mass-balance approach).
  • Waste: Reporting is often driven by local regulatory requirements and guidance.
  • Water: Local expectations can introduce variation against ESRS and GRI definitions, especially regarding wastewater treatment.

Social disclosures also bring differences:

  • Workforce characteristics: Countries have differing definitions of management, remuneration and external workforce populations (e.g., a local definition of ‘women in management’ can be different from how a company defines it globally).
  • Health and safety: There can be different requirements for workforce safety reporting and calculation approaches.

The consequence

The practical challenges arising when meeting local legal reporting requirements while at the same time meeting global or regional sustainability disclosure requirements (which may also form part of legal or regulatory requirements) cause complexity and increase cost. The resulting disclosures risk reducing understandability and, therefore, usefulness for users of that information when there are different definitions and calculations for what seems to be the same metric reported on differently in various parts of the world.

ESMA made a similar point in assessing the revised ESRS, saying “…from the perspective of improving the usability of sustainability information for EU and international investors and as a burden reduction measure for internationally active issuers, the ESRS should be easily interoperable with international standards, whenever this is possible without undermining EU policy objectives and while retaining requirements that reflect EU specificities.”29

The ISSB has recently suggested the idea of a ‘passporting’ mechanism to achieve this. Passporting would allow “foreign private issuers and subsidiaries of international companies that operate in a domestic jurisdiction to report against the requirements in that particular jurisdiction using the ISSB Standards as issued by the ISSB. ISSB passporting facilitates trade and foreign direct investment by allowing use of the simplest, original language that was issued and declared fit for purpose by IOSCO when they endorsed the ISSB Standards.”30

It would be beneficial for any necessary differences to be explained clearly and assessed granularly so that users can understand precisely what differs, what overlaps and how this affects comparability. 

 

Achieving comparable and understandable sustainability-related data

Harmonised disclosure foundations could reduce today’s comparability challenges and improve users’ confidence in sustainable data for decision-making.

 
What sustainability reporting interoperability can learn from the history of financial reporting


As sustainable data users learn to translate between the disclosures prepared using different standards, informal adjustment methods will develop, as they have over time for IFRS and US GAAP accounting differences, such as inventory valuation methods and the treatment of research and development costs. Those methods will work better if the underlying disclosures are as clear and comparable as possible. Similarly, companies’ application of the materiality principle should develop over time and consistency in reported topics and information across industries, as we have seen for financial reporting, should emerge.

Three principles may help improve interoperability: (1) a core set of common, principle-based disclosures; (2) consistent terminology, definitions and methodologies; and (3) digitalisation of sustainability-related disclosures. Together, concordance and harmonisation can identify precise differences and remove unnecessary ones over time. In the section below on ‘Moving towards harmonisation’, we discuss some of the practical steps that could be taken to implement these principles.

Principle 1: A core set of common disclosures

A core set of agreed disclosures, jointly developed and maintained by relevant standard setters, would improve comparability for both data points and narrative information most important to decision-making.

This is more urgent now because two increasingly mandatory sustainability disclosure regimes are being applied by multinational companies and being used by global capital market participants.

As sustainability-related information becomes more decision useful, alignment on the most significant and broadly applicable data points becomes more important.

In practice, core disclosures could have consistent meanings and units of measurement and presentation across regimes, supplemented by jurisdiction-specific information. They could also be reflected in voluntary frameworks to support more consistent data across value chains.

A set of core disclosures, with common data points, could have the following characteristics:

  • Principle-based: They should be supported by application guidance to promote consistent measurement and presentation approaches and users’ confidence in the disclosures. Taking a principle-based approach also may reduce the need for amendments to the standards as reporting evolves and matures.

  • Clearly identifiable: They should be easy to find, with calculations, methodologies, judgements and policies
    explained clearly.31

  • Industry agnostic: They should focus on matters commonly relevant across companies, industries and jurisdictions. Industry-specific disclosures could be introduced separately so that all companies in an industry report a core set of the same information when that adds decision-useful detail. 

A core set of sustainable data would allow supplier, customer and company data to be aggregated on a like-for-like basis and help companies meet the requirements in multiple standards, supporting equivalence or passporting where relevant.32

Principle 2: Consistent terminology, definitions and methodologies

Comparability depends on common technical foundations in sustainability disclosure standards. Where standards share the same general objective (i.e., to result in the disclosure of material information that informs decision making), consistency in naming conventions, scopes and measurement approaches is needed to avoid assuming comparability where it does not exist.

“What we really need is plagiarism.
Regulators should copy each other’s work.” 

– Mardi McBrien, Senior Director at World Business Council for Sustainable Development (WBCSD) and former IFRS Foundation Chief of Strategic Affairs and Capacity Building 33


Terms used across regimes should have the same meaning, including measurement methodology, presentation unit and scope. If a data point means something different, it should use a different term. Common units of measurement are also needed. Standardisation is harder when equivalent data is reported in different units or calculated on different bases.34


Consistent meanings and units help understandability and comparability


Consistency in meaning: The meaning of commonly used and generally understood terms should be consistent regardless of the disclosure standard used. For example, a ton of carbon dioxide equivalent (CO2e) GHG emissions should have the same meaning across companies and borders; this is a physical and chemical amount. However, disaggregation into its component greenhouse gasses might be necessary in a jurisdiction that has an interest in particular component gasses given its sustainability priorities and its local industries.

Consistency in units: Without specific requirements about the units of measurement and presentation in the disclosure standards, adjustments are necessary and comparisons can become challenging. For example, some companies disclose energy usage data measured in Kilowatt hours while others report in Gigajoules. Similarly, companies use different bases for the ‘hours worked’ in their total recordable incident rate calculations. Both situations require estimates to put them on the same basis for comparison purposes.

“…[I]nvestors holding companies that use both frameworks [IFRS SDS and ESRS] cannot compare information presented in different formats like-for-like.” 

– Norges Bank Investment Management 35


Terms used across regimes should have the same meaning, including measurement methodology, presentation unit and scope. If a data point means something different, it should use a different term. Common units of measurement are also needed. Standardisation is harder when equivalent data is reported in different units or calculated on different bases.34

Example 3. Assessing sustainability-linked remuneration practices is challenged by inconsistent terminology and scopes


The challenge

Different terms and scopes can make standardisation difficult.

The situation

Both IFRS SDS and ESRS require disclosure of sustainability-linked remuneration, but they define the relevant population, metric and scope differently.

IFRS SDS requires disclosure of “the percentage of executive remuneration recognised in the current period that is linked to climate-related considerations”.36 ESRS requires disclosure of “the proportion of variable remuneration [of members of administrative, management and supervisory bodies] dependent on sustainability-related targets or metrics”.37

The consequence

The practical challenges arising when meeting local legal reporting requirements while at the same time meeting global or regional sustainability disclosure requirements (which may also form part of legal or regulatory requirements) cause complexity and increase cost. The resulting disclosures risk reducing understandability and, therefore, usefulness for users of that information when there are different definitions and calculations for what seems to be the same metric reported on differently in various parts of the world.

Transparency about what is reported, what the reported data represents and how it was calculated is essential for standardising and comparing information across companies, borders and time. 

“Ensuring that stakeholders, including data providers, have a common understanding of the different topics, and what performance against such topics means, is an important factor driving data comparability. Conversely, lack of consistency can result from diverging definitions… or diverging interpretations as to how performance should be measured…” 

– OECD 38

Without sufficient transparency, external users may be unable to make consistent adjustments. In some cases, data providers may prefer to omit a data point rather than risk mischaracterising it.


Common areas of difference across sustainability disclosure standards


Materiality: Each company needs to make its own determination of what is material, and this will necessarily create variation between companies even in the same industry. This can happen at the topic level or in the application of the disclosure requirements for a specific data point (such as identifying the relevant Scope 3 GHG emissions categories as described in footnote 25 on page 12). This materiality assessment process, along with whether that process focuses on risks, opportunities and/or impacts, has significant implications for what is reported. Consistent application guidance for identifying material sustainability matters would help companies within industries and across borders identify the same or similar issues, supporting comparability in disclosures. It would be helpful for this to include sector-specific guidance (using a single industry classification system) to help identify issues based on companies’ activities and their value chains.

Scope of reporting: Aligning the scope of sustainability-related disclosures with the scope for financial reporting is helpful for understandability and comparability. However, in a sustainability context there are circumstances when that scope might need to be modified to provide comprehensive information, such as for joint ventures, associates and leases. Consistency across disclosure standards for when such deviations from the financial reporting scope are necessary would aid comparability.

Temporary and permanent reliefs: Reliefs for initial application are helpful for giving companies the opportunity to enhance their data, systems and processes to improve the quality and completeness of their disclosures over time. Such temporary differences can be necessary given the readiness of companies, their service providers, regulatory bodies and others in a jurisdiction. Ongoing reliefs recognise practicalities that may not be resolved as practice develops. Because they are unrelated to a company’s or the market’s readiness, comparability would be improved if they were the same across disclosure regimes.

General presentation and other requirements: Differences in the restatement of comparatives and requirements for industry-based disclosures can make comparisons harder. A single report covering multiple requirements would reduce the costs of dual reporting and the likelihood that data users misinterpret disclosures prepared on different bases.

Principle 3: Digitalisation of sustainability-related disclosures

The growing volume of new sustainable data coming into the market and increasing use of artificial intelligence (AI) models make digital tagging and machine readability increasingly important.

Interoperable digital taxonomies, such as the IFRS Sustainability Disclosure Taxonomy and the ESRS eXtensible Business Reporting Language (XBRL) taxonomy,39 are critical for comparability, accuracy and machine readability. They also support Principles 1 and 2 discussed above.

An interoperable taxonomy would need an official concordance agreed by standard setters and embedded in reporting software platforms. This would show how data points and narrative information relate across standards and would support a roadmap for harmonisation.

Example 4. Machine readability is more consistent when standards use consistent terms


The challenge

Machine readability can be inconsistent without common terminology, even for familiar metrics.

The situation

A commonly encountered example is Scope 1 GHG emissions. Such emissions are described differently across ESRS (“gross Scope 1 GHG emissions”), IFRS SDS (“absolute gross Scope 1 GHG emissions”) and GRI Standards (“gross direct Scope 1 GHG emissions”).

The consequence

A human reader may recognise the terms as equivalent, but a machine may not, limiting reliable comparison across frameworks. A further complication is that companies often amend or write their own labels, resulting in more terms for users or AI models to try to align. Digital tags mitigate this because the machine label remains consistent regardless of the human label.

XBRL-tagged reports, covering numerical and narrative data would give companies greater confidence in the data they report across regimes, and would help users be confident in extracting that information. Digital tagging is also a step towards bringing sustainability reporting in line with the rigour and consistency of financial reporting.

Example 5. A single source of digitally tagged sustainable data can improve consistency across published documents


The challenge

Reconciling disclosures in a corporate social responsibility (CSR) report with those in the annual report.

The situation

Consider, for example, a company that publishes GHG emissions data in its CSR report and in its annual report. In the CSR report, the company reports a limited list of emissions that have higher (worst-case) values, while its annual report provides a more granular operation-by-operation breakdown with some lower values for overlapping pollutants. The two documents, published by the same company for the same period, do not agree with each other.

The consequence

To an outsider it is difficult to see what the real level of emissions is for such a company. If there was a single, digitally tagged authoritative disclosure, the company could have used the same emissions information in both reports, or at least could reconcile them.

AI could improve the scale of sustainable data analysis by helping identify, classify, benchmark and summarise disclosures across companies and jurisdictions, improving accessibility, generating insights, highlighting gaps and strengthening comparability. AI can also expand coverage by processing structured and unstructured information from company reports, regulatory filings and news. 

However, AI needs well-structured, well-defined data and transparent mapping methods, such as XBRL. Without them, models may misinterpret data and create only the appearance of comparability. Human analysts remain critical for exercising professional judgment, validating outputs and ensuring assessments reflect the context and materiality of sustainability matters.

Concordance therefore supports both human and machine readability by clarifying each data point and how it was calculated.

 

Moving towards harmonisation

Reporting will mature as the revised ESRS and IFRS SDS implementations progress. Some fragmentation will disappear over time, but some will remain where adoption methods, jurisdictional requirements and voluntary frameworks differ.

Interoperability is not the end goal; the aim is better decision-making about competing resource allocation opportunities through clearer, more comparable information. Interoperability between disclosure standards allows them to complement, not compete with, one another, to enable the flow of decision-useful information.

A coordinated concordance exercise could identify similarities and differences, followed by a process of harmonisation to remove or minimise unnecessary differences, while clearly explaining those that must remain.

A practical framework could include three steps:

Step 1: Analysis of what the differences are

  • Map all disclosure requirements to identify precisely which (a) appear to be the same or similar, (b) appear to be different and (c) exist in one set of standards but not another. Such an exercise would help identify where the differences exist and inform standard setters’ views about (and plans for) whether they should.

  • This exercise could build on the joint interoperability guidance on climate disclosures published by the ISSB and EFRAG in May 2024. Because that document will need to be updated following the recent revisions to ESRS, it could be used as a test case for a harmonisation process. This could also build on the work between EFRAG and GRI and the TNFD.

  • The output of such an exercise could be a technical mapping index – developed jointly by EFRAG and the ISSB – that matches data points in one set of standards with their equivalents in the other, clearly identifying which can be considered the same and which cannot be. Those that cannot be considered the same would be further assessed in Step 2.

  • Concordance at the level of the data structure is important for machine readability of the information. Therefore, the exercise should also map across the standards’ digital taxonomies, providing the input needed for digital tagging taxonomy development.

  • The exercise should consider both the detailed content area of the disclosure requirements (e.g., resilience, risk management processes, current/anticipated financial effects) and the type of data being reported for each (numerical, Boolean or narrative).

  • The understanding that comes from the output of the mapping exercise would help reduce the reporting burden for companies operating across multiple jurisdictions because it would identify what data can be captured once and used across multiple regimes’ requirements, without duplication.

  • The resulting mapping could help in identifying a core set of disclosures common across all regimes as set out in Principle 1, as well as the data structure needed for them as set out in Principle 3.

Step 2. Assessment of the significance of the differences identified

Some differences will not be significant enough to affect a user’s decision making. For those that are significant (i.e., those with the same meaning but using different words; those using the same or similar words but having different meanings; or being different disclosure requirements altogether), it is necessary to understand why those differences exist and how the resulting information is understood and interpreted in each regime.

Step 3. Determination of the approach needed for resolving significant differences

  • Group differences by which should be eliminated, which can be minimised and which should remain.

  • For differences to be eliminated or minimised, there are likely to be:

    • some changes that can be implemented almost immediately, perhaps with minor, targeted amendments;

    • some changes that could be addressed in the next amendment cycle (e.g., as part of a coordinated effort in the bodies’ respective post-implementation reviews); and

    • some changes that would take more effort and significant deliberations to reach an aligned position and therefore would take more time.

  • For differences that should remain, explain the rationale and develop standard ways of interpreting and adjusting for them so that data points from different regimes can be made comparable.

Implementation of such a framework would require input from stakeholders across the sustainable data ecosystem, including:

  • Companies: Interpretation, preparation and communication experiences, and where they find inconsistencies, overlaps and gaps

  • Assurance providers: Verification and assurance implications

  • Investors and other users: Understandability of the disclosures and their usefulness for decision making

  • Data providers: Common standardisation and analytical practices and how standard approaches could be developed to make interpretations more similar

  • Standard setters: What information can helpfully inform their monitoring of developments by other standard-setting bodies to assess whether amendments and/or additions to other bodies’ standards are relevant to their own, for putting in place joint projects where alignment is needed and for informing their post-implementation reviews and plans.

 

Continuing the discussion

Addressing the practical issues explored in this report requires engagement across the sustainable data ecosystem, including policy makers, standard setters, data providers, companies and investors.

The questions below are intended to build on existing discussions about interoperability and focus attention on what should happen next, including the constraints and potential unintended consequences that will need to be considered.

Question 1:

Could harmonisation lead to a set of common disclosures across standards? If so, how could common definitions, methodologies and terminology be agreed?

Question 2:

Would a concordance mapping framework support the sustainable data ecosystem? If so, how could it be developed?

Question 3:

Should structured disclosure formats and digital tagging be pursued to help improve machine readability, including for AI, and promote comparability across regimes, borders and companies?

Appendix 1: Glossary of acronyms

Appendix 2: Sources

In addition to input from FoSDA member firms, we interviewed representatives from investor and corporate bodies, accountancy firms, standard setters and digital reporting technology experts. We also referenced IFRS SDS and ESRS in effect as of July 2026.

Other sources referenced while preparing this report include the following:

 

References

1 Although this report focuses primarily on IFRS SDS and ESRS (because the current and growing mandatory nature makes the subject of interoperability most urgent), the challenges described also apply when using other sustainability disclosure standards and frameworks, such as the GRI Standards. The challenges also pertain to jurisdictions’ sustainable taxonomies, but these are not discussed in detail in this report.

2 Norges Bank Investment Management’s (NBIM) letter to the European Commission Consultation on the ESRS revisions dated 3 June 2026. NBIM manages Norway’s Government Pension Fund Global (GPFG), one of the world’s largest investment funds, and is one of the world’s largest single investors, with assets of approximately NOK 21.7 trillion (€1.9 trillion or US$2 trillion).

3 A practice statement is non-mandatory guidance issued on a sustainability topic that is not explicitly addressed by an IFRS SDS. In this case, it would accompany IFRS S1 for use by companies that identify nature-related risks and opportunities as being relevant to their cash flows, access to finance or cost of capital.

4 EFRAG, ESRS for Certain Non-EU Undertakings in Accordance with Article 40a of the Accounting Directive, July 2026. The ESRS-40a ED covers impact-related disclosures.

5 IFRS Foundation, Use of IFRS Sustainability Disclosure Standards by jurisdiction, last updated 16 July 2026.

6 IFAC, The State of Play: Sustainability Disclosure and Assurance (Six-Year Trends and Analysis, 2019-2024), June 2026. The 2026 research assessed the sustainability disclosure and assurance practices of companies from 2019 to 2024.

7 Limited assurance results in a conclusion about whether anything has come to the assurance provider’s attention that causes them to believe the sustainability information is materially misstated. The procedures are limited compared with those performed in a reasonable assurance engagement, which is a higher level of assurance (typically the level obtained over financial statements). See International Auditing and Assurance Standards Board, International Standard on Sustainability Assurance 5000, General Requirements for Sustainability Assurance Engagements, paragraph 18, November 2024. 

8 See IFRS Foundation, Use of IFRS Sustainability Disclosure Standards by jurisdiction, last updated 16 July 2026, for information about whether and, if so, how assurance requirements are being introduced in jurisdictions applying IFRS SDS.

9 In IFRS SDS and ESRS, “[v]erifiability means that various knowledgeable and independent observers could reach consensus, although not necessarily complete agreement, that a particular depiction is a faithful representation.” IFRS S1 paragraph D22; ESRS 1 paragraph QC14.

10 Application of voluntary frameworks is expected to continue, at least in the short to medium term. It is notable, however, that IFAC’s June 2026 The State of Play report, which assessed the sustainability disclosure and assurance practices of companies from 2019 to 2024, found that use of GRI Standards declined by 7% from 2023 and TCFD by 4%.

11 Additional interpretations aside from ours on page 4 include (non-exhaustive): aligned, being in common, using common language, comparable, compatible, complementary, consistent, converged, harmonised, homogeneous, reconcilable, uniform and universal. Specifically with regard to sustainability-related disclosure standards, ESMA defines interoperability as “substantial alignment or at least easy reconciliation”. In its assessment of the July 2026 ESRS revisions, ESMA used an approach that “… prioritises full alignment over easy reconciliation, where possible, as the most desirable situation to facilitate the reporting of undertakings wishing to comply with multiple sets of standards and is consistent with the EU broader ‘report-once’ principle.” (ESMA, Opinion of the European Securities and Markets Authority of 17 February 2026 on EFRAG’s technical advice on revised ESRS, 18 February 2026.) 

12 EFRAG and ISSB, ESRS-ISSB Standards – Interoperability Guidance, May 2024. The guidance “describes the alignment of disclosure requirements and information than an entity starting with each set of standards needs to know to enable compliance with both sets of standards, ensuring interoperability between them. Regardless of whether it starts with ESRS or ISSB Standards, an entity can comply with the climate requirements of both sets of standards by following the content of this interoperability guidance.” With the July 2026 revisions to ESRS and the December 2025 revisions to IFRS S2, it would be helpful for this document to be updated.

13 GRI and IFRS Foundation, GRI and IFRS Foundation collaboration to deliver full interoperability that enables seamless sustainability reporting, 24 May 2024.

14 GRI and EFRAG, EFRAG and GRI enhance collaboration with deeper ties, 30 November 2023. 

15 TNFD and EFRAG, TNFD-ESRS Correspondence Mapping, June 2024.

16 The July 2026 ESRS amendments “[took] account, to the greatest extent possible… interoperability with global sustainability reporting standards.” Commission delegated regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards, 3 July 2026.

17 From the Keynote speech by Commissioner Albuquerque at EFRAG’s annual conference: “25 Years of EFRAG: Leading the Next Era of Corporate Reporting”, 8 June 2026.

18 From the Keynote speech by Commissioner Albuquerque at EFRAG’s annual conference: “25 Years of EFRAG: Leading the Next Era of Corporate Reporting”, 8 June 2026.

19 IFRS S2 paragraph 14(a)(iv).

20 ESRS E1 paragraph 12.

21 OECD-BIAC and IFAC, Regulatory divergence: costs, risks, impacts, 2018. Suggested solutions included enhanced international cooperation among regulators, increased alignment in the rules, adherence to global standards and improved alignment in definitions.

22 OECD, Behind ESG ratings: Unpacking sustainability metrics, 2025.

23 IOSCO, Environmental, Social and Governance (ESG) Ratings and Data Products Providers, November 2021. IOSCO referred specifically to ‘ESG-focussed investors’, but more recently mainstream investors have also shown interest in using this data.

24 For example, ESMA’s 2025 enforcement priorities for sustainability reporting illustrate the variability in application across ESRS reporters. ESMA, Report on 2025 Corporate reporting enforcement and regulatory activities, 7 May 2026.

25 An example of this is Scope 3 GHG emissions disclosures, as observed by LSEG in their January 2024 report, Scope for improvement: Solving the Scope 3 conundrum. A company must determine which of the 15 categories is material to it but, without industry-specific guidance on which are likely to be material, similar companies in the same industry may include different categories, meaning their Scope 3 disclosures are not comparable. If the determination of what is material changes over time, it can be difficult to assess whether performance is from a reporting change or an operational or strategic change. This can reduce the usefulness of the data for investors and other data users, even without considering issues of changing data availability and integrity in the measurement of Scope 3 emissions.

26 IOSCO, Environmental, Social and Governance (ESG) Ratings and Data Products Providers, November 2021. 

27 IOSCO, Report on Sustainability-related Issuer Disclosures, June 2021.

28 IOSCO endorsement of the ISSB Standards for sustainability-related disclosures.

29 ESMA, Opinion of the European Securities and Markets Authority of 17 February 2026 on EFRAG’s technical advice on revised European Sustainability Reporting Standards (ESRS), 18 February 2026.

30 Emmanuel Faber’s speech at the 2026 Beijing International Sustainability Conference, May 2026.

31 Some have suggested that information that is financially material should be distinguishable from information that is material from an impact perspective. Others think that risks investors ignoring information about dependencies and impacts that are associated with or are likely to turn into risks or opportunities.

32 This is set to become more important for non-EU groups within the scope of CSRD. For such companies and groups, an equivalence mechanism that recognises IFRS SDS as an equivalent component of the revised ESRS, allowing the new non-EU group ESRS to be applied for impacts that are not also financially material (and thereby covered by IFRS SDS disclosures), could avoid dual reporting obligations without reducing the availability of impact-related sustainable data from third-country undertakings active in the EU. For jurisdictions adopting or otherwise using IFRS SDS with local variations, allowing companies to use IFRS SDS as issued by the ISSB (passporting) can support jurisdictional equivalence decisions, reduce preparation costs and improve the understandability of the resulting disclosures.

33 Remarks at the AFME European Sustainable Finance Conference in May 2026.

34 ESMA’s work in the development of the Regulatory Technical Standards (RTS) on European Single Electronic Format (ESEF) for sustainability reporting could provide useful input here. In assessing how various data types contribute to the level of comparability and usability for sustainable data prepared using ESRS requirements, ESMA found that numerical data types, such as monetary amounts, percentage values, GHG emissions, energy, mass and Boolean data, were highly comparable and usable, whereas narrative disclosures were medium or low in terms of their comparability and usability.

35 Norges Bank Investment Management’s letter to the European Commission Consultation on the ESRS revisions dated 3 June 2026.

36 IFRS S2 paragraph 29(g)(ii).

37 ESRS 2 paragraph 14(c).

38 OECD, Behind ESG ratings: Unpacking sustainability metrics, 2025.

39 Development of the ESRS XBRL taxonomy is now being taken forward by the European Single Markets Authority (ESMA) to be included in the Regulatory Technical Standards (RTS) on European Single Electronic Format (ESEF) for sustainability reporting. However, ESMA has paused development of digital tagging requirements for ESRS pending the revisions of ESRS, which were published in final form in July 2026. For more information, see ESMA’s Report on 2025 Corporate reporting enforcement and regulatory activities.

 
FoSDA Report on Interoperability (Executive Summary)
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FoSDA Report on Interoperability
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Questions & Answers

Foreword

Why does interoperability matter? Is interoperability between sustainability-related disclosure standards improving? What role do sustainability-related disclosure standards play in capital allocation?

FoSDA’s report on interoperability is an authoritative study based on input from specialists working on the comparability of sustainability data

Executive Summary

Why does interoperability matter?

Because differences in the details between sustainability-related disclosure standards reduce comparability and increase costs

What does the report examine?

Interoperability challenges and the implications for market participants

What is the report’s aim?

To encourage standard setters, policymakers, companies, investors and data providers to work together to improve sustainable data availability and quality

How are the ISSB and EFRAG working together on interoperability?

Are the IFRS SDS and the EU ESRS interoperable?

What is the definition of interoperability?

What is the definition of comparability in relation to interoperability?

What is the definition of concordance in relation to interoperability?

What is the definition of harmonisation in relation to interoperability?

What do we mean by digital tagging? Why does it matter?

How can we achieve comparable, understandable sustainability-related data? Three principles may help to improve interoperability: a core set of common disclosures, consistent terminology and digitalisation

How can we move towards harmonisation of sustainability-related disclosure standards?

By analysing the differences, identifying the differences that matter most and reducing these and finding common ways to interpret the differences that remain

What should happen now? What is the Future of Sustainable Data Alliance (FoSDA) going to do next?

Over the autumn, FoSDA is going to invite stakeholders to join a series of discussions around the potential for harmonisation, the possible role of a concordance mapping framework and the value of digital tagging

Aiming for clarity and consistency

How is sustainability reporting evolving?

Rapid progress is being made to establish a clearer set of disclosure standards.

Is a global baseline for sustainability-related disclosure standards emerging?

Yes, from the ISSB, but other standards such as the EU’s ESRS and the GRI will continue to play important roles.

What is the history of the development of sustainability-related disclosure standards and frameworks?

Many frameworks were launched in the past, leading to the development of the ISSB standards as a way to standardize these. See the graphic on page 7

What are the European Sustainability Reporting Standards? Are the European Sustainability Reporting Standards interoperable with the ISSB standards.

What are some of the challenges that arise for corporate reporters and investors from the lack of interoperability between different disclosure standards?

What are some examples of the challenges arising from the lack of interoperability?

See examples on pages 10, 13, 15, 16 and 17

What is the role of data providers in the sustainability reporting ecosystem?

Data providers support decision making by collating, validating and standardising corporate sustainable data, filling gaps and making estimates where needed, improving the availability and understandability of disparate and sometimes incomplete data sets.

How does sustainable data emerge through disclosure standards?

See Figure 3 on p 11

Why do differences across sustainability-related disclosure standards and their application by companies matter?

Because structurally different data can reach users, weakening comparability.

Are some differences between sustainability-related disclosure standards necessary?

Yes, because jurisdictional requirements may legitimately reflect local priorities, existing legal frameworks and stakeholder expectations.

Achieving comparable and understandable sustainability-related data

Why does harmonisation matter?

Because harmonisation could reduce comparability challenges and improver users’ confidence in sustainable data

What can sustainability reporting learn from the history of broader financial reporting?

That informal adjustment methods will emerge, but that the need for these will be reduced if the underlying disclosures are as clear and comparable as possible

What would improve interoperability across sustainability-related disclosure standards?

A core set of common disclosures, consistent terminology and digitalisation.

Why do common disclosures, consistent terminology and digitalisation matter and how can these best be achieved?

See text on pages 14-17

Why do consistent meanings and metrics matter in sustainability reporting?

See text in green box on p15

Are there common areas of difference across widely-used sustainability-related disclosure standards?

Yes, materiality, scope of reporting, reliefs and general presentation requirements

Moving towards harmonisation

Will reporting harmonise over time?

Yes, some fragmentation will disappear but there is a risk that more may remain due to jurisdictional and framework differences

How could we work towards interoperability?

Through analysing what the differences are, determining their relative significance and identifying how to address the most significant

How could analysis of differences between sustainability-related disclosure frameworks happen?

See text in yellow box on p18.

How could we determine the relative importance of differences between frameworks?

See text re Step 2 in yellow box on p19

How could we address the most important differences between sustainability-related disclosure frameworks?

By finding ways to interpret and adjust for them to make them comparable. See text at foot of yellow box on p19

Continuing the discussion

How does the Future of Sustainable Data Alliance intend to take this work forward?

We want to engage all stakeholders in a discussion around the steps towards harmonisation that we have identified, the potential role of concordance mapping and the importance of digital tagging.

Glossary of acronyms

Do you have a glossary of acronyms related to sustainability-related disclosure standards?

There are lots of acronyms relating to sustainability-related disclosure standards. These are listed and explained on p21

Sources

How have you developed this report?

We developed this report through extensive engagement with key stakeholders such as standard setters, data providers and trade bodies representing companies and investors. The direct reference material from which we have sourced content includes EFRAG, ESMA, the European Commission, the GRI, IFA, the IFRS Foundation, IOSCO, LSEG, the MSCI Institute, NBIM, the OECD, the PRI, TNFD and the WBCSD

Latest News

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The rapid expansion of mandatory sustainability reporting standards represents significant progress in the delivery of decision-useful data to investors, but the landscape remains fragmented. Despite standard setters’ work to improve interoperability across reporting regimes, comparability issues remain.

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