Navigating sustainability & ESG reporting.

The sustainability reporting world is converging around a set of interconnected frameworks. Understanding how they relate saves significant effort because the underlying data is largely the same.

Mandatory frameworks: CSRD/ESRS (EU mandatory, double materiality, detailed climate disclosures under ESRS E1), California SB 253 (Scope 1, 2, and 3 for $1B+ revenue companies doing business in CA; CARB adopted initial regulations in February 2026, with the first Scope 1 and 2 reporting deadline deferred to November 10, 2026 and Scope 3 from 2027), and California SB 261 (climate financial risk reports for $500M+ revenue companies, though a Ninth Circuit injunction in November 2025 paused its enforcement).

Voluntary frameworks: CDP (largest disclosure system, 23,000+ companies, investor-driven), SBTi (target validation for 1.5°C alignment), GRI (impact-focused, widely used for sustainability reports), and TCFD (now incorporated into ISSB S2).

Global baseline: ISSB's IFRS S1 and S2 standards provide a common baseline being adopted by jurisdictions worldwide (UK, Japan, Singapore, Australia, Brazil, Canada). ISSB uses single (financial) materiality.

CSRD is the most comprehensive mandatory sustainability reporting regime. It requires disclosures under 12 ESRS standards covering environmental, social, and governance topics.

ESRS E1 (Climate Change) is the most data-intensive standard. It requires: total GHG emissions by scope with breakdowns by significant Scope 3 categories; energy consumption and mix; GHG intensity ratios; emission reduction targets and progress; transition plans with actions, investments, and timelines; financial effects of climate risks and opportunities; and internal carbon pricing details.

The double materiality assessment determines which ESRS topics require full disclosure. While climate (E1) is material for virtually all covered companies, other topics (water, biodiversity, circular economy, workforce) depend on the company's specific impacts and risks.

CSRD requires limited assurance initially, moving to reasonable assurance. Reports must be tagged in machine-readable XBRL format and integrated with the management report. The assurance requirement means data must be traceable to source documents with clear evidence trails — not just calculated numbers.

Timeline (updated for the 2025 Omnibus "Stop-the-Clock" directive): Wave 1, the large EU public-interest entities already in scope, reported FY 2024 in 2025 and continue annually. Wave 2 (other large companies) was delayed two years and now reports FY 2027 in 2028. Wave 3 (listed SMEs) was likewise pushed back two years. The Omnibus package also raised the thresholds, keeping only companies with more than 1,000 employees and over €450M in turnover in scope, which pulls many previously covered companies out entirely. Because this area is still moving, treat these dates as current as of July 2026.

CDP's annual climate questionnaire has become the de facto standard for voluntary climate disclosure. Preparing a strong CDP response requires the same data foundation as regulatory reporting but adds strategic and governance dimensions.

Scoring ranges from A (leadership) to D– (minimal). A-list companies demonstrate comprehensive disclosure, awareness of environmental impacts, management through targets and actions, and leadership through best practices.

CDP is working to further align its reporting questionnaire with those of other standards, such as ISSB.

The key to efficient reporting across multiple frameworks is a single source of truth for emissions and ESG data, combined with flexible output formatting.

Gravity is built around all four layers in one platform, so that a single data collection and calculation effort produces disclosure-ready outputs for every framework your organization faces.