We are at the dawn of a new era in sustainability reporting and better ways of doing business for people and planet. Derarca Dennis and Nicola Ruane give their advice and insights on the road ahead for companies and accountants
There has been a significant shift from voluntary to mandatory sustainability or environmental, social and governance (ESG) reporting in recent years.
The European Commission’s Action Plan for Financing Sustainable Growth directly targets ‘Strengthening sustainability disclosures and accounting for rule-making,’ as one of 10 key areas of focus. This has resulted in the enactment of the Corporate Sustainability Reporting Directive (CSRD). In tandem with the trend towards mandatory ESG reporting, more and more companies are choosing to voluntarily disclose ESG information to satisfy stakeholder demands.
So, why is all of this so significant for the accounting profession? There are numerous reasons, all of them important, and outlined below:
Climate risk tops priorities
One of the key purposes of the CSRD is to curb ‘greenwashing,’ which is an attempt by a company or organisation to mislead the public about its level of positive ESG impact.
Mandating standardised reporting provides for increased comparability in the public domain. This means that organisations can be held accountable by their stakeholders.
Assessing the impact of climate change and broader ESG impacts on a company’s bottom line has become the remit of the International Financial Reporting Standards (IFRS) Foundation under its recently launched International Sustainability Standards Board (ISSB).
With the oversight of the IFRS Foundation, the relevant ESG reporting standards and frameworks are converging under the ISSB.
One specific issue the accounting profession should examine, in the first instance, is climate change and, specifically, climate-related financial risks.
This is particularly important right now because of the adoption of the Task Force on Climate-related Financial Disclosures (TCFD) across nations, with many opting to make it mandatory for companies to report how their operations are being impacted by our changing climate.
The TCFD requires four key areas to be addressed in relation to climate risk: strategy; risk management; governance; and metrics/targets.
Although this is not yet mandatory in Ireland, leading organisations are starting to actively manage and report both physical and transitional risks.
With climate risks and disclosures moving swiftly up the business agenda, it is becoming a part of everyone’s job in an organisation to integrate the relevant considerations into their function, be it procurement, marketing or finance.
There is a lot to think about, so where is the best place to start? When it comes to playing your part in tackling climate change, we recommend that you first ask these three questions—of yourself, your team, and the wider organisation:
Have we identified the climate change risks that may affect our revenue, P&L and balance sheet?
Do we have a strategy in place to manage and measure climate risks?
Do we need to report to investors or other stakeholder groups?
Climate change and financial statements
With the advent of the ISSB, we can expect the robustness of financial accounting standards developed over decades to become applicable to the measurement and disclosure of climate change risks.
One question our clients are asking is: ‘Should we be disclosing the extent to which climate change affects our financial statements under IFRS?’
Although there is, as yet, no single explicit standard on climate-related matters under IFRS, climate issues may impact several areas of accounting.
The immediate impact to financial statements may not at first appear significant from a quantitative point-of-view.
However, there is growing expectation among stakeholders that entities preparing financial statements must explain how climate-related matters are considered.
This expectation is such that climate-related matters can be viewed as material from a qualitative perspective. Significant effort and judgement will be required to assess them and we recommend that you read EY Global’s Applying IFRS — Accounting for Climate Change (Updated May 2022) for further guidance found at ey.com.
CSRD: what it means for your organisation
Some 49,000 companies will now be in scope for the mCSRD, up from the 11,600 that had been in scope under its predecessor, the Non-Financial Reporting Directive (NFRD).
One key shift worth noting from the NFRD regime to the CSRD concerns assurance. ESG reports must be certified by an auditor or independent certified assurance provider to ensure compliance with the framework. The timelines laid down are:
large corporates, currently subject to NFRD, to report in 2025 for 2024 data;
large corporates, not subject to NFRD, to report in 2026 for 2025 data.
For SMEs, requirements under the CSRD will not come into effect until 2026. There is an opt-out option to 2028. This is only applicable to listed SMEs across regulated European markets, however.
The Commission will make simplified reporting standards available to small companies in due course.
SMEs and reporting requirements
While there is strong consideration that SMEs are not subjected to adverse reporting requirements, a step change is needed to ensure that this community is supported adequately through the process of reporting on sustainability impacts.
Given the critical role SMEs play in bolstering the Irish economy and in helping to reach targets laid out in the National Climate Action Plan, it is important that ESG impact is considered and embedded throughout their operations without the requirement for undue or excess reporting.
Separate standards may be developed for non-listed SMEs. This option is currently under discussion and, if introduced, would be voluntary in nature, as per the current proposal.
For all SMEs, the guidance is to start small. Select a limited number of material metrics — say, three to five — to measure and report.
Our recommendation would be to span these metrics across different pillars of focus aligned to the World Economic Forum (WEF) Framework. Example metrics under each pillar include:
Prosperity: employment, economic contribution, tax paid;
People: diversity and inclusion, pay equity, training provided;
Planet: GHG emissions, climate risk (TCFD), water consumption; and
Governance: board composition, setting purpose, anti-corruption.
This framework will in time become the leading framework globally for measuring non-financial impact.
Pressures beyond regulation
Whilst the regulatory agenda is driving the need for greater transparency and focus on an organisation’s ESG impact, other drivers may emerge even sooner and from other sources. So, beyond regulation, what are the biggest drivers of ESG reporting?
The supply chain: customers and clients want to know what a company’s impacts are and whether it is building this into tenders with a view to including the relevant data in its own reporting. One example here is the Scope 3 Greenhouse Gas (GHG) emissions.
Talent: millennials and Generation Z candidates are more aware of ESG than previous generations and increasingly keen to work for, and buy from, companies that actively manage their climate impact.
The board: more and more ESG-competent boards are challenging management to produce non-financial data.
Capital providers: keen to meet green lending targets, capital providers are more likely to require suitable disclosures from their customers’ borrowing funds. One reason for this is so that they can aggregate this data, where applicable, into their own ESG reporting.
Four key steps in ESG reporting
Reporting is not just a data collection exercise, and it is vital to bear this in mind. Our experience with clients has shown us that there are four key components to consider.
While we might start with the end goal in mind — the ESG report — here are the steps needed to get there:
Research and select an appropriate framework, ensuring that due diligence discovers all mandatory disclosures;
Build an ESG strategy;
Measure performance and collect data;
Publish a transparent report combining qualitative with quantitative data and communicate with stakeholders.
To comply with the CSRD, companies will need to submit data digitally through a single access point. This is to deliver on the objective of the CSRD to standardise the data, enable comparability across companies and avoid ‘greenwashing.’
A true differentiator in business
ESG reporting can be viewed as a true differentiator for winning business. We expect publicly communicating ESG impact to become par for the course for businesses in the years ahead.
Another advantage is that it can support a company’s brand reputation as a leader. An organisation that is seen to be at the forefront of sustainability will be regarded as one that takes responsibility for minimising its negative impact, and actively fosters positive impact.
In summary, the accountancy profession is ideally placed to contribute to building a more holistic picture of an organisation’s performance and future potential.
Past performance is not a measure of future success, but, by marrying financial and non-financial performance, you will get a more accurate picture of an organisation’s potential future success.
The challenge for many businesses now is the transition they will need to make from the sustainability data processes and frameworks currently in use, to the higher and more rigorous standards the accountancy profession already adheres to for the reporting of financial data.
Accountants are crucial in the development of detailed sustainability reporting and the fight against greenwashing. As accountants, you can play a vital role in future-proofing your business through ESG reporting.
Derarca Dennis is Partner, Climate Change and Sustainability Services at EY Ireland
Nicola Ruane is a senior manager in EY Ireland’s Climate Change and Sustainability practice