• “non-financial reporting directive
    • transposition in Austria: NaDiVeG
    • large companies only (PIEs)
    • member states could choose some details
  • adopted in 2014, first applicable 2017
  • 2 non-binding guidelines
    • in 2017 further non-binding guidelines about reporting methodology
    • in 2019 further non-binding guidelines about climate-related information
  • also includes
    • environment
    • social matters
    • employees
    • human rights
    • corruption and bribery
    • diversity (PIEs only)
  • comply or explain why not
  • CH has developed a similar standard in 2024

Actual Affects

  • check for presence only
  • supervisory board examines content
    • can be offloaded to external auditor
  • free choice of reporting standard
  • choice between separate report or section in management report
  • wording change
    • non-financial report sustainability report

Transpositions

  • some countries require further topics
  • differences in
    • PIEs definition
    • separate report allowed
    • independent assurance mandatory
    • consistency requirements

Requirements

  • disclosure requirements
  • non-requirements
    • KPIs cherry-picking possible in report
    • diversity information for listed companies

Goals

  • enhance the consistency and comparability of non-financial information
  • indeed, disclosure of non-financial information is vital for managing change towards a sustainable global economy

Deficiencies

  • report by EU in 2021
  • enables Green Washing too much
    • no requirement for reporting standard
  • comparability and consistency is not mandatory
    • e.g. not part of management report but separate
  • missing validation/reliability proof
  • only companies in scope (PIEs)
  • missing Sanctions/enforcement