Comparison of environmental reporting requirements from the European Sustainability Reporting Standards (ESRS) with selected environmental laws : case studies from a large and mid-sized company : interim report

The Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) require large companies to provide comprehensive information on their environmental performance, policies, targets and actions. At the same time, many of the affected companies are subject to other environmental regulations that require them to collect and disclose, among others, data on emissions, resource use and waste management. This paper includes the results of two case studies from the manufacturing industry. It investigates the extent to which the companies can use information already collected to meet their environmental regulatory obligations for the purposes of reporting under the ESRS environmental standards and which synergies and challenges exist. The case studies find that some of the information required to be collected under environmental legislation can be used for ESRS reporting, or that processes, responsibilities and infrastructure (e.g. measurement equipment) may be in place due to existing environmental obligations that facilitate data collection for the ESRS. They also show that the usability of the data in the companies is of course highly dependent on whether companies are already covered by legislation to which the ESRS standards directly refer or not. For topics such as biodiversity and microplastics, the two companies that served as the case studies can barely draw on existing information from existing legal requirements. However, information collected for their voluntary sustainability reporting and as part of their environmental management system often is a good source for reporting against the ESRS. Overall, the availability of environmental data from legal requirements that can be used for ESRS reporting differs between topics and standards. This paper is the English version of part of the final report "Weiterentwicklung europäischer Nachhaltigkeitsberichtsstandards für Unternehmen" (Schöpflin et al. 2024) to be published by the German Environment Agency.