The new EU sustainability framework vis-à-vis integrated reporting and intangibles: a systematic perspective
Alessandro d’Eri and
Valerio Novembre
Chapter 17 in Handbook on Intangibles, 2026, pp 299-311 from Edward Elgar Publishing
Abstract:
With the advent of the Corporate Sustainability Reporting Directive (CSRD), sustainability and financial reporting are given the same dignity in the EU context, however the role of intangibles and integrated reporting may have fallen into an existential crisis. The CSRD, in fact, opts for a dichotomic approach to corporate disclosures by setting out the content and format of the sustainability statements that are meant to constitute almost a twin counterpart to the financial statements. While attempts are being made to investigate how to best improve the connectivity between financial and sustainability reporting, such a dichotomy may contrast with the fact that, traditionally, integrated reporting and reporting on intangibles have been seen as tools to improve the usability and clarity of corporate reporting as whole. Partly, the issue stems from the fact that sustainability reporting and reporting on intangibles are not fully overlapping areas. For example, while staff satisfaction may be seen as both an ESG indicator and an intangible, customer satisfaction would not typically fall under the ESG umbrella. In addition, the introduction of the new EU regime under the CSRD seems to exacerbate the risk of fragmentation in corporate disclosures adding to a plethora of existing requirements both at EU and national level that already make the annual reporting package somewhat piecemeal. For example, the sustainability report will need to fit with multiple other sets of disclosures, such as, the management report, the corporate governance statement, the remuneration report as well as the financial statements. While digital reporting has often been seen as a panacea for solving several of these issues, it is still to be confirmed in practice how, in the absence of requirements that explicitly address the importance of reporting on intangibles, it alone can effectively address the needs of investors and financial analysts to get an overall understanding of a company’s strategy, risks, impacts and performance. In the above-described fragmented context, a further dimension that is worthwhile investigating is the role of the board of directors in monitoring and ultimately taking responsibility for corporate disclosures, in particular on ESG-related aspects and intangibles. Interestingly, the European Commission’s proposal for a Corporate Sustainability Due Diligence Directive (CS3D) originally provided for further involvement of the board in the area of sustainability, in particular the company’s (and its value chain’s) sustainable business conduct, however the final CS3D text obliterated such provisions. It is nonetheless worthwhile assessing the challenges for the board to reconcile the company’s conduct and disclosure-related duties and whether further steps in the direction of more integrated reporting would promote a more cohesive corporate view.
Keywords: Corporate Sustainability Reporting Directive (CSRD); Integrated reporting; Intangibles; Sustainability reporting; Financial reporting; Corporate disclosures; Fragmentation; ESG; Board of directors; Digital reporting; CS3D; European Union regulation; Corporate governance; Investor information (search for similar items in EconPapers)
Date: 2026
ISBN: 9781035306367
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