Comparing the Implementation of the EU Non-Financial Reporting Directive

52 Pages Posted: 4 Jan 2018 Last revised: 15 Oct 2018

Date Written: November 28, 2017

Abstract

The paper analyses the implementation of the EU Non-Financial Reporting Directive in four European Member States: UK, Germany, France and Italy.

The first part reviews the main trends, key differences and potential difficulties or unexpected consequences of the Directive. The paper then explores in more detail key substantive elements of the Directive, and how these have been dealt with by each of the surveyed states. This section includes an overview of the scope and format, environmental, social and governance (ESG) factors to report on, the information to be provided, the notion of materiality, the verification process, the basis of reporting and the consequences of non-compliance. The paper also presents a comparative table and comprehensive analysis of the domestic transpositions of each of the four countries under review.

The Directive provides the first comprehensive framework for ESG reporting at the EU level but gives considerable leeway to Member states in the transposition process. Whilst generally the new EU-wide legislation has been a positive step, there are a number of gaps in the Directive itself, which have not been adequately addressed in the implementing legislation.

Keywords: non-financial reporting directive, ESG reporting, sustainability reporting, integrated reporting, European Commission, ESG, sustainable companies

JEL Classification: M4, M40, M41, M48, M1, M00

Suggested Citation

Jeffwitz, Claire and Gregor, Filip, Comparing the Implementation of the EU Non-Financial Reporting Directive (November 28, 2017). Available at SSRN: https://ssrn.com/abstract=3083368 or http://dx.doi.org/10.2139/ssrn.3083368

Claire Jeffwitz

Frank Bold ( email )

Rue d'Edimbourg 26
Bruxelles, 1050
Belgium

Filip Gregor (Contact Author)

Frank Bold ( email )

Rue d'Edimbourg 26
Bruxelles, 1050
Belgium

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