A guide to ESG

reporting frameworks
Contents

01 02 03 04
Introduction Select ESG frameworks Adopt a dedicated Prepare for future
for reporting ESG reporting system ESG reporting trends

05 06 07
Consult different Conclusion Appendix: ESG
sources for guidance frameworks in detail
01 There’s global consensus among governments, businesses and financial
institutions that environmental, social and governance (ESG) risk is

Introduction investment risk, and actions to protect the environment and society
through strong governance are critical to our future.

And just as organizations are required to produce reports on financial

performance, they are expected—and sometimes required by law—to
disclose their ESG performance.

But how to do this? Unlike financial performance reporting, which is

governed by clear expectations on format and content, the world of ESG
reporting is still fragmented and confusing. Each framework poses its own
set of questions and requirements, and frameworks cross over each other,
requiring complex cross-checking of responses. Most frameworks require
the provision of supporting documentation, and many quantitative questions
require complex numerical calculations based on multiple data streams.

ESG reporting is now a high-stakes business imperative. In many cases,

reports must be fully auditable, comparable across periods and approved
by a corporate officer.

In this publication, we set out to provide you with guidelines to assist with
your approach to ESG reporting. We outline the ESG framework landscape,
propose approaches that organizations can employ when selecting ESG
frameworks, and consider the future of ESG reporting as ESG performance
soars to the top of the corporate agenda.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
3
“Climate change has become The rise of corporate ESG So how do these ESG reporting frameworks
The pace at which ESG metrics are being compare? And how can organizations better
a defining factor in companies’ reported on is on an incredible trajectory. understand the nuances of ESG reporting?
long-term prospects.” Largely in response to rising investor and
community interest, growing numbers of In this ebook, we explore:
Larry Fink organizations are focusing their attention
Chief Executive Officer on reporting their ESG performance and – How to select which ESG frameworks
BlackRock1 targeting sustainability performance to use
improvement, driven by ESG goals. – Best-practice approaches when
reporting to ESG frameworks
As a result, ESG has moved from the margins – How to prepare your organization
to the mainstream, and now more than ever for future ESG reporting trends
before, organizations are expected to report – Where to look for additional guidance
their ESG performance. Failure to take ESG
risks seriously could result in many negative
impacts for organizations, from shareholder
action at annual general meetings to
divestment by asset managers.

The growing importance of ESG means that

organizations must report their impact using
an ever-increasing range of frameworks,
guidance and standards. For simplicity, we
use the word framework to include reporting
standards, tools, guidance, and voluntary or
legal reporting obligations. See the Appendix
for more detail.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
4
02 The ESG reporting landscape is crowded
with various reporting frameworks. Applying What is materiality in the context of ESG?

Select ESG different lenses to assess and categorize the The concept of materiality helps organizations focus on ESG issues that are relevant to them
various requirements can help you understand and will have a measurable impact on their business.

frameworks the options and select the right ESG

frameworks for your organization’s reporting. To determine materiality, an organization must first identify its risks, then assess the consequences

for reporting
of those vulnerabilities. Using a risk matrix, your organization can determine which ESG-related risks
to prioritize based on your risk profile. You can also decide which of those consequences might have
Lens 1 any significant negative impacts on the organization.
Potential for impact
Example: A large-cap e-commerce company may choose to focus on packaging materials and
Materiality and relevance waste (environmental), supply chain labor standards (social) and business ethics (governance)
The decision about which framework to use in its materiality assessment because it determined these to have the largest risk profiles for
for reporting should start by considering environmental impact, overall shareholder and consumer confidence, and regulatory requirements.
materiality and relevance. In this case, the company should look for frameworks that cover all three ESG categories.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
5
Consider assessing double materiality Impact and influence For example, organizations in the fast-moving
Double materiality calls on organizations In addition to materiality and relevance, consumer goods and retail sectors can most
to consider materiality from two viewpoints: organizations may want to examine impact easily exert influence within their supply chain.
financial materiality and materiality to the and influence. Organizations assessing their Quick wins Major projects In these sectors, an organization’s procurement
market, the environment and people. ESG reporting approach may also find it choices can have significant impact on the ESG
beneficial to consider the environmental and performance of companies in the supply chain
Double materiality recognizes that an social factors that they can influence most which can magnify their ESG impact.

Impact
organization is responsible for managing directly and rapidly.
its own financial risks by looking inward.
But it also looks at the outward impacts Using an action priority or impact effort
of its decisions and operations on people prioritization matrix, organizations can quickly
Fill-ins Thankless tasks
and the environment. identify where to focus their initial efforts. They
can then use these insights to determine which
By applying the concept of double materiality, ESG framework is best for realizing goals that
organizations can identify both the financial are within reach.
and nonfinancial impacts of their operations Effort
to help shape a more holistic ESG strategy. Figure 1. Impact effort prioritization matrix.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
6
Lens 2 How will internal stakeholders Lens 3
use the information?
Stakeholder expectations Stakeholders will use ESG disclosures for Geography
a range of purposes. Organizations should
What are external stakeholders take this into account when developing their Certain ESG reporting frameworks are only
looking for? ESG reporting strategy. The risk, compliance relevant in specific geographies. In some
Organizations may also consider what their and HR teams would most likely be invested cases, this is because reporting is mandated
stakeholders are looking for and which ESG in the data to drive strategic decisions by law. In others, it can be because the
frameworks these stakeholders plan to use. around equity and inclusion, while energy framework is specific to local conditions.
For example, investors, boards, insurers and and utilities teams might be looking closely Examples include ENERGY STAR in North
creditors may prefer the organization report at consumption and expenditure across the America and select other countries, SECR
following the guidance of the Task Force on organization. On the other hand, procurement in the UK and NGER in Australia.
Climate-related Financial Disclosures (TCFD) teams would be using the data collected to
or criteria of the Sustainability Accounting assess their supply chain operations and the
Standards Board (SASB). In contrast, risk profile of suppliers.
employees and consumers may expect
disclosures based on the United Nations
Sustainable Development Goals (UN SDGs)
while governments or regulators may prefer
Streamlined Energy and Carbon Reporting
(SECR) or National Greenhouse and Energy
Reporting (NGER), depending on the locale.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
7
Lens 4 Industry Relevant frameworks, regulations Disclosures typically required
and certifications
Sector preference Commercial real estate LEED, BREEAM, DGNB, WELL, GRESB, NABERS Energy, water, waste, capital improvements,
climate risk
Organizations belonging to a particular Financial services PRI, PCAF, SFDR, EU Taxonomy Financed emissions, DEI, governance,
industry sector will find a natural alignment climate risks

between their sector and some ESG reporting Oil and gas IPIECA Principles, IRA 60113 CO2, methane, water, EHS compliance,
carbon capture
frameworks, such as the Global Real Estate
Sustainability Benchmark (GRESB) that’s used Manufacturing ISO 14001, UN IDDI, cGMP Materials, waste/recycling, EHS compliance,
to assess the sustainability performance of value chain

real estate and infrastructure portfolios. Telecom EPEAT, GDPR, FAST-Infra Energy, e-waste, privacy and security,
access, reliability

Organizations interested in evaluating which Utilities FERC 2222, RPS / CES, RED Emissions, materials, energy mix and
use of DERs, grid reliability
frameworks their peers report to can find
this information by reviewing the websites
of reporting frameworks which often include
a sector filter and a list of reporters. Using ESG framework information directory
this information, organizations can determine In chapter 5, “Consult different sources for guidance,” we provide a directory of framework websites
the relevance of the ESG framework to for your organization to use when seeking more information on different ESG frameworks.
their sector. Similarly, organizations can also
review sustainability reports along with
annual reports published by their sector peers
to see how the peers’ reporting is aligned to
relevant frameworks.

The table included here shows ESG reporting

frameworks typically adopted by organizations
within specific sectors, and can help you select
the right framework. (Note: This table is based
on IBM’s experience and does not constitute
official ESG guidance.)

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
8
Lens 5 Level of coverage:

Framework coverage Complete Some None

Environmental* Social Governance Carbon Energy Waste Water

Each of the major ESG reporting frameworks
has different levels of focus on key ESG CDP
performance metrics. Understanding which
CSA
framework focuses on which indicator can
help you choose a framework and provide
ENERGY STAR
insights into where organizations may be able
to report to multiple frameworks using existing GRESB
data. This matrix illustrates the focus areas for
each reporting framework. GRI

IIRC
Note: The included analysis and categorization
of different ESG frameworks is based on IBM’s NABERS AU
experience and does not constitute official
ESG guidance. NGER

SASB

SBTi

SECR

SFDR

TCFD

UN SDGs

CSRD

BRSR

Figure 2. ESG framework indicator coverage *Environmental includes all elements that are not carbon, energy, waste or water.
Examples include a focus on biodiversity, air quality, desertification and more.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
9
03 As the investor community sharpens its focus
on ESG metrics, the level of scrutiny applied
Most organizations operate dedicated IT
systems to support processes and security,
ESG reporting software such as the IBM®
Envizi™ ESG Suite can help you stay organized

Adopt a to ESG data intensifies. After all, the most

valuable commodity in capital markets is
accounting systems to securely store financial
data, and HR systems to capture and manage
by automating data capture directly from the
source and maintaining an emissions factor

dedicated ESG reliable, auditable data. Unlike typical

financial data that investors are familiar with,
people data. ESG data management and
reporting should not be any different.
library for nationally recognized carbon
emissions factor data tables. These tables

reporting system ESG data has generally not been held to the
same standards of accuracy. ESG data is often
Organizations can benefit from having a
specialized software platform to capture their
include the US EPA Climate Leaders Program,
e-GRID USA, Intergovernmental Panel on
held in disparate systems. In fact, some activity data, calculate the emissions impact Climate Change (IPCC), IEA National Electricity
organizations attempt to run their annual of their sustainability initiatives and manage Factors, Australian National Greenhouse
greenhouse gas (GHG) accounting using their ESG reporting processes. Nowhere is this Accounts, DEFRA (UK) and NZ Ministry for
spreadsheets which provide little control over more important than for the E (environmental) the Environment.
inputs. Approaches like this are not an efficient in ESG, which is under increasing scrutiny due
means of managing ESG data in the face of to the impacts of climate change.
stakeholder and regulatory pressure—especially Keep it simple
for complex global organizations reporting The metrics captured within the “E” of ESG The IBM Envizi ESG Suite solution helps
against multiple frameworks. generally include environmental factors such simplify the process of ESG reporting
as water, waste, pollutants and energy as well against different frameworks. All your
as metrics required to support greenhouse gas responses are available in a framework
(GHG) emissions accounting. library with one data set and one
repository of information across multiple
internationally recognized ESG frameworks
and standards including SASB and Global
Reporting Initiative (GRI).

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
10
04 AI-driven data scraping How to prepare for an AI-driven ESG valuation
With the practice of data scraping on an
Determine the best keywords
Check your organization’s publicly available
by ESG ratings tools
Prepare for upward trend, investment and sustainability
teams should consider a new approach to
information to ensure that the data captured
by the AI data scraping and bots is accurate.

future ESG Increasingly, AI tools and bots are used to

evaluate an organization’s ESG performance
regain control of their data. This approach
can protect the organization’s ESG valuation
Analyze the terminology used and adjust for
clarity. This analysis should include your

reporting trends through publicly available data. This practice,

known as data scraping, presents a new
from the inevitable shortcomings of AI-driven
ESG data scraping.
organization’s web pages, comparison
websites and company search databases
challenge for organizations because it means such as Bloomberg.
that the data being used to evaluate access to Step 1: Identify which rating agencies you
The ESG disclosures landscape is evolving capital is largely outside your control. Various need to target. Approach your potential key Employ social listening
rapidly. Here are a few additional things firms synthesize ESG data from many different institutional investors and ask them which Track conversations online to determine
to consider as you follow new trends to sources. Data can be harvested from ranked ratings agencies they trust. what has been published about your
navigate this space. and “best of” lists, product review websites, organization and do your best to remove or
social media posts and comments, company Step 2: Understand what data the target rating change any inaccurate statements. Examples
databases, and news articles, then used to build agencies use and how they go about uncovering of items to watch include customer reviews,
an organization’s profile. Although these scoring it. Ask the rating agencies directly if possible, Google business listings, and customer social
systems and the piecemeal data gathered or do research online to uncover what you can. media comments and mentions about
through data scraping fail to provide the your organization.
context, methodology or granular detail that Step 3: Ensure that the data you’re providing
most investors require, the practices are and the places where you’re sharing it meet Increase publicly available ESG information
nonetheless becoming more widespread. the needs of the rating agencies. Here are Provide more data in sustainability action plans
some tips to help you accomplish this. and reports. Publish supporting documents that
go into further detail about your organization’s
ESG performance and efforts. Be especially
diligent that any information published is
consistent with what’s provided in regulatory
filings. The data can then be published on
your organization’s website, in social media
channels and on other platforms.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
11
A global standard
2024 (anticipated)
in ESG reporting March-April 2021
– World Economic Forum and SASB
– Q1: Large organizations
start publication of the
joint statement outlining intent
first reports following the
to work together toward global
There are at least three perspectives to corporate disclosure reporting
CSRD requirements
consider regarding the future of ESG reporting: November 2021 – Taskforce for Climate
– EU Sustainable Finance Disclosure IFRS announces June 2023 Related Financial
regulatory changes, industry coalescence comes into force creation of the ISSB, The ISSB issues its Disclosures enforced for
around frameworks and interframework June 2020 – Publication of a proposal of the EU establishing first two sustainability Financial Institutions
EU Sustainable Finance Corporate Sustainability Reporting a unified corporate disclosure standards— from 2021–2024 or
consolidation. All these perspectives point Taxonomy introduced Directive (CSRD) reporting system IFRS S1 and S2 2025, depending on size
to one major directional move—the
harmonization of ESG reporting frameworks.
January 2020 September 2020 June 2021 March 2022 Mid to late 2023
Larry Fink’s letter to – IFRS issues a consultation on IIRC and SASB finalize US SEC climate disclosure New SEC reporting regulations
CEOs: climate risk sustainability reporting, calling on merger to form the Value rule proposal to mandate for large enterprise reporting
is investment risk the creation of the International Reporting Foundation emissions disclosures for for Scope 1 and 2 expected to
Sustainability Standards Board (ISSB) large companies come into effect in 2023
– CDP, CDSB, GRI, IIRC and SASB
joint statement of intent detailing
desire to work with IFRS toward a
comprehensive reporting system

Figure 3. Timeline of ESG reporting framework harmonization.

Regulatory changes Industry sectors coalescing Framework consolidation

Various progress has been made across As the practice of ESG reporting matures, These changes are resulting in a reporting
national and supranational jurisdictions. industry sectors are coalescing around landscape where frameworks are becoming
The U.S. Securities and Exchange Commission their preferred frameworks. The early more specialized, as seen with the International
(SEC) announced a proposal in 2022 to mandate movers in this regard were in the property Financial Reporting Standards (IFRS) Foundation
ESG disclosure modeled from the TCFD. New sector which favors reporting against the and GRI, or are consolidating, as seen with the
SEC climate disclosure regulations are expected GRESB framework. International Integrated Reporting Council
to come into effect in 2023 for reporting in 2024. (IIRC) and SASB.
Similarly, the EU’s sustainable finance package,
the EU Taxonomy, the Sustainable Finance
Disclosure Regulation (SFDR), and the CSRD,
will require further ESG-related disclosures
from companies.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
12
How to prepare for ESG reporting changes Get the data right
With progressive steps toward a common With an accurate and auditable data
language for ESG reporting and new foundation today, you can avoid both historical
announcements being made every few errors and the hassles of modifying processes
months, how can organizations better when ESG reporting changes are required. The
prepare for the inevitable changes facing IBM® Envizi™ ESG Suite can help organizations
ESG frameworks? achieve this with an auditable data record and
accurate emissions calculations. The solution
is regularly updated to incorporate new
framework requirements so ESG reporting
remains current with market obligations.

Figure 4. The IBM reporting and management solution.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
13
05 In the lead-up to key reporting dates and throughout the year,
frameworks publish updates and guidance to help participants

Consult with their ESG reporting.

different sources These updates can be viewed on their channels, including:

for guidance Social media, specifically LinkedIn

Electronic newsletters

Media and blog section of their websites

Webinars and online forums

Sustainability professionals involved with their organization’s ESG

reporting may find it beneficial to stay up to date by monitoring these
online communities and resources.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
14
Here’s a directory covering many of these Main website eNewsletter sign-up Media/blog Social media
information sources. IBM issues regular (LinkedIn)
updates and guidance throughout the year CDP www.cdp.net/en Available on website www.cdp.net/en/blog www.linkedin.com/company/cdp-
worldwide
on emerging trends and changes in the ESG
reporting landscape. You can access these CSA www.spglobal.com/esg www.pages.marketintelligence. www.spglobal.com/ www.linkedin.com/company/
spglobal.com/Newsletter-Hub- marketintelligence/en/news- spglobal
resources through our website. Request.html insights/latest-news-headlines

ENERGY STAR www.energystar.gov/buildings www.cloud.mail.energystar.gov/ www.energystar.gov/about/ www.linkedin.com/showcase/

preferences/profile newsroom energy-star-canada/

GRESB www.gresb.com www.gresb.com/nl-en/gresb- www.gresb.com/nl-en/news- www.linkedin.com/company/gresb

newsletter and-updates

GRI www.globalreporting.org www.r1.dotdigital-pages. www.globalreporting.org/about- www.linkedin.com/company/global-

com/p/4J5-SLH/gri-email- gri/news-center reporting-initiative-gri
communication-sign-up-form

IIRC www.integratedreporting.org www.valuereportingfoundation. www.integratedreporting.org/ www.linkedin.com/company/

org/subscribe newspage international-integrated-reporting-
council

NABERS AU www.nabers.gov.au www.nabers.us6.list-manage. www.nabers.gov.au/about/news www.linkedin.com/company/nabers

com/subscribe?u=cf8c911de
05f356279288cde0&id=594
16b8f3b

NGER www.cleanenergyregulator.gov. www.cleanenergyregulator.gov. www.cleanenergyregulator.gov. www.linkedin.com/company/clean-

au/NGER au/About/Subscribe-to-email- au/NGER/News-and-updates energy-regulator
updates

SASB www.sasb.org www.valuereportingfoundation. www.sasb.org/about/news www.linkedin.com/company/

org/subscribe sasb-sustainability-accounting-
standards-board

SBTi www.sciencebasedtargets.org www.sciencebasedtargets.org/ www.sciencebasedtargets.org/ www.linkedin.com/company/

newsletter news-events science-based-targets

SECR www.gov.uk/government/publications/academy-trust-financial-management-
good-practice-guides/streamlined-energy-and-carbon-reporting

SFDR www.eurosif.org www.eurosif.org/monthly- www.eurosif.org/news www.linkedin.com/company/eurosif

newsletter

TCFD www.fsb-tcfd.org www.fsb-tcfd.org/mailing-list www.fsb-tcfd.org/press www.linkedin.com/company/task-

force-on-climate-related-financial-
disclosures-tcfd

CSRD finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-
and-auditing/company-reporting/corporate-sustainability-reporting_en

BRSR www.sebi.gov.in/sebi_data/commondocs/may-2021/Business%20responsibility%20
and%20sustainability%20reporting%20by%20listed%20entitiesAnnexure1_p.PDF

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
15
Framework guidance embedded
in ESG reporting
The IBM Envizi ESG reporting frameworks
solution includes best-practice guidance and
enables you to record all your framework
responses in one place.

Figure 5. This product screenshot is an example of the type of

guidance provided for individual framework questions. It offers
guidance on a question in the TCFD reporting framework.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
16
06 ESG reporting is a complex space and staying up to date on requirements can be a burden for
organizations who need to report against or to multiple frameworks. However, if organizations apply
Part of this assessment also includes ensuring
that there is a solid data foundation to work

Conclusion a systematic approach, they can stay ahead. The first step is to ensure the most appropriate reporting
frameworks are selected to begin with. This decision is crucial, yet it’s not always a simple decision.
from which meets the same standards applied
to financial data. Accuracy, automation and
One way to approach the selection decision is to apply a number of different analytical lenses, which auditability are at the center of sound ESG
we mentioned earlier in the ebook: reporting practices. Organizations that adopt
these practices through a specialized ESG
1. Identify where your organization can make 4. Distinguish sector preference as reporting solution such as the IBM Envizi ESG
the most difference including materiality organizations belonging to a particular Suite will be better prepared to face the many
and double materiality assessments, an sector may find that there is a natural changes facing the ESG landscape.
organization’s impact and influence across alignment between their sector and
the supply chain. some ESG reporting frameworks. Learn more about how IBM can support you
to achieve your ESG reporting goals.
2. Understand stakeholder expectations 5. Ascertain framework coverage of each
specific to preferred ESG reporting ESG reporting framework pertaining to
frameworks and how different stakeholders key performance indicators including
will use information from disclosures. environment, social, governance, carbon,
energy, waste and water.
3. Recognize geography and the relevance
of some ESG frameworks to locations
and jurisdictions.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
17
07 In this section, we provide an overview of sustainability performance
indicators used in each ESG framework. To make this list easier to navigate,

Appendix: we have grouped the major ESG reporting frameworks into four categories:

ESG frameworks –
–
Voluntary scored frameworks: CDP, GRESB
Voluntary frameworks: GRI, TCFD, VRF (SASB + IIRC)

in detail –
–
Regulatory frameworks: SFDR, NGER, SECR, CSRD, BRSR
Rating agencies: ENERGY STAR, DJSI (CSA), NABERS

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
18
Voluntary scored frameworks Carbon Disclosure Global Real Estate
Organizations can choose voluntary scored
Project (CDP) Sustainability
frameworks to disclose environmental
CDP is a framework for companies to
Benchmark (GRESB)
information to their stakeholders. These
provide environmental information to
examples require responses to all questions GRESB is a global tool used predominately
their stakeholders—investors, employees
in the framework and typically have by investors to assess the sustainability
and customers—covering environmental
a scoring element. performance of real estate and infrastructure
governance and policy, risks and opportunity
portfolios, and assets worldwide.
management, environmental targets, and
strategy and scenario analysis.
How GRESB works
GRESB assessments provide investors and asset
How CDP works
managers with insights into the sustainability
CDP offers three questionnaires on the topics
performance of a company’s real assets.
of climate change, water and forests, each of
These performance insights are aligned with
which is scored using different methodologies.
international reporting frameworks such as the
Each questionnaire includes general questions
GRI and Principles for Responsible Investment
along with sector-specific questions aimed
(PRI). Assessment participants receive
at high-impact sectors. The scoring of CDP’s
comparative business intelligence illustrating
questionnaires is conducted by accredited
where they stand compared to peers, a roadmap
scoring partners trained by CDP.
with actions they can take to improve their ESG
performance and a communication platform to
Related reading: What is CDP, how it works
engage with investors. Investors use the ESG
and how software can help
data and GRESB analytical tools to improve the
sustainability performance of their investment
portfolios, engage with managers and prepare
for increasingly rigorous ESG obligations.

Related reading: What is GRESB?

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
19
Voluntary frameworks Global Reporting Task Force on Climate-related How the TCFD works
The TCFD addresses disclosure requirements
These frameworks allow reporters to select
Initiative (GRI) Financial Disclosures (TCFD) related to four pillars.
the questions they want to report against,
GRI is a globally applicable guidance The TCFD was explicitly designed to address 1. Governance: How does the organization’s
depending on factors such as their industry
framework that provides standards detailing climate risks to the business, falling squarely governance structure address climate-
of operation and their materiality. Scoring is
approaches to materiality, management within the “E” of ESG reporting. The TCFD helps related risks and opportunities?
typically not included in these frameworks.
reporting and disclosure for a comprehensive organizations across the globe articulate how 2. Strategy: What are the tangible material
range of sustainability issues. GRI Standards ESG performance is most likely to materially impacts of climate-related risks and
guide many organizations in the production impact future financial performance and value opportunities on the whole business,
of their own sustainability reports. creation. The TCFD was created in December including strategy and financial planning?
2015 after the G20 Finance Ministers asked the 3. Risk management: How does the
How GRI works Financial Stability Board (FSB) to evaluate the organization define, assess and manage
The modular, interrelated GRI Standards connection between climate-related issues and climate-related risks?
are designed primarily to be used as a set the financial sector. The FSB is an international 4. Metrics and targets: What are the
to prepare a sustainability report focused body that makes recommendations to the measurements used to assess material
on material topics. The three universal global financial system, so this push toward climate-related risks and opportunities?
standards are used by every organization climate-related finance was significant.
that reports under the GRI framework. An Related reading: What is the TCFD?
organization also chooses from the topic-
specific standards to report on its material
topics—economic, environmental or social.

Related reading: What is the Global

Reporting Initiative?

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
20
SASB How the SASB Standards work
Of the other ESG reporting frameworks,
The SASB Standards track ESG issues and the GRI is most like SASB but supplies more
performance across 77 industry standards. broadly material information for reporting
These industry-specific standards include six to stakeholders who are not concerned only
disclosure topics and 13 accounting metrics with financial portfolios.
across five key dimensions of sustainability—
environment, social capital, human capital, Corporations who use SASB standards
business model and innovation, and leadership to disclose ESG metrics include asset
and governance. management companies such as BlackRock,
Goldman Sachs and Morgan Stanley;
Through a series of mergers, the SASB is now manufacturing giants such as General Motors
a part of the IFRS Foundation to support the and Nike; and even specialized industries
new ISSB 2. According to the IFRS, “The ISSB including companies such as Merck and
encourages companies and investors to JetBlue. SASB also supplies resources to
continue to provide full support for, and explain how investors use the standards
use of, the SASB Standards.” across multiple asset classes. These tools
allow organizations to be specific and report
with a system that allows for transparency
and relevancy with their investors.

Related reading: What is SASB?

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
21
Regulatory frameworks Sustainable Finance Corporate Sustainability CSRD applies to organizations with over EUR
20 million in total assets, a net turnover of
Regulatory frameworks are like benchmark
Disclosure Regulation (SFDR) Reporting Directive (CSRD) EUR 40 million or 250 or more employees
frameworks because all responses are or all three criteria. These include both EU
SFDR aims to standardize the reporting of The European Union’s CSRD is a law that companies and EU subsidiaries of non-EU
required but are not always scored. These
ESG metrics for financial products and entities prescribes rules for organizations to report companies, and would impact more than
frameworks and reporting requirements are
within the EU. It does this by mandating that sustainability disclosures across several topics 50,000 companies, nearly 10,000 of which
also required by a government body.
reporters publish a Principal Adverse Impact pertaining to environmental and social issues, are outside of the EU.
(PAI) statement detailing their disclosures. as specified by the European Sustainability
SFDR will act in concert with the EU taxonomy Reporting Standards (ESRS). Sustainability reporting will also be required
and the proposed EU Corporate Sustainability of non-European companies that generate an
Reporting Directive (CSRD) to form the basis The CSRD is informed by the concept of double annual net turnover of EUR 150 million in the
for the EU sustainable finance agenda. materiality. It requires organizations to detail EU and that have at least one subsidiary or
how their business strategy will mitigate the branch in the EU. Non-EU companies will have
How SFDR works risks and realize the opportunities associated to comply starting in 2028. While the CSRD
SFDR’s PAI statement requires financial with these environmental and social matters– has been finalized, the ESRS are expected
bodies to report different types of quantitative and make these disclosures public–and how to be passed as EU law in 2023.
indicators, including weighted averages across environmental and social issues will impact
various ESG metrics for their investments as the business (beyond financial impact alone). Related reading: The EU CSRD Explained
well as emissions from their own activities.
In practice, this means that organizations It values social metrics alongside environmental
must report the proportion of their investees’ performance by looking at matters such as
activities that they finance. For example, employee health, human rights, bribery, anti-
if an investee generates 100 metric tons corruption and diversity across management.
of hazardous waste and the financial body
has 20% of the equity in that company, the
financial body reports 20 metric tons of
hazardous waste in its SFDR PAI.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
22
Business Responsibility National Greenhouse and Streamlined Energy and How the SECR works
Quoted companies that report to the SECR are
and Sustainability Report Energy Reporting (NGER) Carbon Reporting (SECR) required to disclose their energy use, global
(BRSR)—India The NGER Scheme is the Australian national The SECR taxonomy is the UK government’s
Scope 1 and 2 GHG emissions in metric tons
of CO2 equivalent, and at least one emissions
framework for reporting and disseminating guidance for organizations required to disclose intensity metric of their choosing for current
India’s BRSR framework and reporting
company information about GHG emissions, their energy use, GHG emissions and related and previous financial years. Scope 3 emissions
guidelines replace the existing Business
energy production and energy consumption. information. The SECR was introduced to take remain voluntary but are recommended for
Responsibility Report (BRR). Starting from
Established by the NGER Act in 2007, it is effect from 1 April 2019 as the previous Carbon emissions sources considered material.
financial year 2022–2023, the top 1,000
monitored by the Clean Energy Regulator. Reduction Commitment (CRC) Energy Efficiency Unquoted large companies and LLPs will also
listed Indian companies by market
Scheme came to an end. It builds on and need to report, at a minimum, their UK energy
capitalization must file a BRSR-compliant
How NGER works extends the previous reporting requirements use and associated GHG emissions from
report to the Securities and Exchange
The NGER Scheme collects emissions-related faced by quoted companies while adding new electricity, gas and transport fuels as well at
Board (SEBI). The BRSR covers three areas.
data about GHGs such as carbon dioxide mandates for large unquoted and limited least one intensity metric. Reporting each of
(CO2), methane (CH4), nitrous oxide (N2O), liability partnerships (LLPs). It can also help all these sustainability dimensions and tracking
– General Disclosures
sulphur hexafluoride (SF6) and specified kinds organizations with voluntary reporting on a their progress over time requires access to
These cover operational, services and
of hydrofluorocarbons and perfluorocarbons. range of environmental subjects, including GHG consolidated, auditable data which can be
financial details as well as employee
Records of activities must be adequate reporting and the use of KPIs. The SECR is more easily achieved with sustainability
details covering diversity and inclusion,
to enable the Clean Energy Regulator to central to the UK’s strategy for improving energy reporting software.
retention, and grievances.
ascertain whether the corporation or person efficiency and reducing CO2 emissions, as set
– Management and Process Disclosures
has complied with its obligations under the out in the Climate Change Act 2008. It is Related reading: SECR reporting explained
This area requires disclosures related
NGER Act. This includes information that can expected that an estimated 11,900 companies
to organizational policies and management
be used to verify the relevance, completeness, incorporated in the UK will need to report on
processes, governance, and leadership
consistency, transparency and accuracy their energy and carbon emissions under the
accountability.
of reported data during an external audit. new framework.3
– Principle Wise Performance Disclosure
This is the most quantitative-data-intensive
section where companies are required to
report against KPIs based on the nine
principles of India’s National Guidelines on
Responsible Business Conduct (NGRBC)

Related reading: The Indian BRSR explained

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
23
The Securities and Exchange IFRS Sustainability
Commissions (SEC) climate Disclosure Standards
disclosure rule—expected The International Financial Reporting
in 2023 Standards Foundation (IFRS) announced
the formation of the International
The Securities and Exchange Commission Sustainability Standards Board (ISSB) in
(SEC) has issued a rule proposal to standardize 2021. The ISSB has since made progress
the way organizations make climate-related on developing standards aimed to create
disclosures. The rule proposal requires US a global baseline of sustainability disclosures
publicly traded companies to disclose annually to meet the information needs of investors.
how their businesses are assessing, measuring In June 2023, the ISSB issued its first two
and managing climate-related risks. These IFRS Sustainability Disclosure Standards,
disclosures would apply to annual 10-K IFRS S1 General Requirements for Disclosure
reports used by analysts, investors and of Sustainability-related Financial Information
creditors to make decisions. The proposed and IFRS S2 Climate-related Disclosures.
rules include the disclosure of greenhouse Under the IFRS Sustainability Disclosure
gas emissions as a measure of exposure to Standards, it is expected that companies
climate-related risk. The proposed rule aims will need to deploy processes and controls
to standardize climate-related disclosures for to disclose sustainability information that
investors, allowing them to clarify exposure matches the quality and auditability
to risk and potential impact on the business standards of financial information.
operations or financial condition of the
organization they are investing in.

Related reading: SEC’s climate disclosure

rule proposal explained

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
24
Rating agencies ENERGY STAR ENERGY STAR scores are based on data from
national building energy consumption surveys
These type of frameworks have a scoring ENERGY STAR is a nationally recognized which allows the ENERGY STAR Portfolio
element and are often responded to through energy rating and benchmarking mechanism Manager tool to control for key variables
a questionnaire that is not public. in North America that covers commercial affecting a building’s energy performance
buildings across a diverse group of building including climate, hours of operation and
use types. building size. This means that buildings from
around the country with different operating
How ENERGY STAR works parameters and subject to different weather
ENERGY STAR is a U.S. Environmental patterns can be compared side by side to see
Protection Agency (EPA) voluntary program how they stack up regarding energy
that helps businesses and individuals save performance. The specific factors that are
money and protect the climate through included in this normalization—hours, workers,
superior energy efficiency. Rankings compare climate and more—will depend on the property
the performance of a building against other type. The 1 to 100 scale is set so that 1
similar buildings called a peer group. Building represents the worst-performing buildings and
owners can benchmark their performance 100 represents the best performing buildings,
internally across their portfolio and externally with 50 representing the average.
among similar sectors.

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
25
Dow Jones Sustainability How DJSI works National Built How NABERS works
The DJSI applies a transparent, rules-based NABERS compares the performance of
Indices (DJSI) and the component selection process based on the Environment Ratings Scheme a building or tenancy to benchmarks that
Corporate Sustainability company’s Total Sustainability Scores (NABERS) AU represent the performance of other similar
resulting from the annual CSA. The CSA buildings in the same location. NABERS
Assessment (CSA) compares companies across 61 industries Using a six-star scale, NABERS helps scores are calculated by an independent
questionnaire with questionnaires assessing a mix of 80 Australian building owners understand how assessor using 12 months of real, measurable
to 100 cross-industry and industry-specific their asset impacts the environment and information about a building or tenancy. The
The DJSI tracks the performance of the world’s questions. Companies receive scores ranging helps prospective tenants understand how data can include energy and water bills or
leading companies in terms of economic, from 0 to 100 and percentile rankings for energy-efficient their leased space is. waste consumption data as the basis of their
environmental and social criteria. It’s used by approximately 20 financially relevant rating. NABERS ratings are available for
investors who wish to jointly assess financial sustainability criteria across economic, commercial office buildings, tenancies, hotels,
and ESG aspects of company performance. environmental and social dimensions. Only shopping centers and data centers. NABERS
the top-ranked companies within each announced in 2019 a plan to expand to all
industry are selected for inclusion in the major building types. Under Australia’s
DJSI family. Investors in these indices gain Building Energy Efficiency Disclosure Act,
exposure to the performance potential of all buildings for sale or under lease over
well-known common factors—low volatility, 10,000 sq ft must receive a NABERS rating.
dividend yield, value or momentum—while Governments are required to lease space
avoiding ESG-related risks in their portfolios in buildings with ratings of 4.5 or higher.
by directing their investment toward more
sustainable companies. Related reading: What is a NABERS rating?

01 Introduction 02 Select ESG 03 Adopt a 04 Prepare for future 05 Consult 06 Conclusion 07 Appendix:
frameworks dedicated ESG ESG reporting trends different sources ESG frameworks
for reporting reporting system for guidance in detail
26
© Copyright IBM Corporation 2023

IBM Corporation
Route 100
Somers, NY 10589

Produced in the United States of America

August 2023

IBM, the IBM logo, and Envizi are trademarks or registered

trademarks of International Business Machines Corporation, in the
United States and/or other countries. Other product and service
names might be trademarks of IBM or other companies. A current
list of IBM trademarks is available on ibm.com/trademark.

This document is current as of the initial date of publication and

may be changed by IBM at any time. Not all offerings are available
in every country in which IBM operates.

THE INFORMATION IN THIS DOCUMENT IS PROVIDED “AS IS”

WITHOUT ANY WARRANTY, EXPRESS OR IMPLIED, INCLUDING
WITHOUT ANY WARRANTIES OF MERCHANTABILITY, FITNESS
FOR A PARTICULAR PURPOSE AND ANY WARRANTY OR
CONDITION OF NON-INFRINGEMENT. IBM products are
warranted according to the terms and conditions of the
agreements under which they are provided.

The client is responsible for ensuring compliance with laws and

regulations applicable to it. IBM does not provide legal advice or
represent or warrant that its services or products will ensure that
the client is in compliance with any law or regulation.

1 A Fundamental Reshaping of Finance, BlackRock letter to CEOs,

Accessed July 2023.
2 IFRS Foundation completes consolidation with Value Reporting
Foundation, IFRS announcement, 1 Aug 2022.
3 New digital tool enables easier energy and carbon reporting,
GOV.UK press release, 13 March 2020.