ESG disclosure for issuers, what to publish and where

ESG disclosure for issuers means publishing what the rules in your markets require, in the place they require it, and then answering investor requests consistently. Mandatory items go in the annual report or filings, voluntary data in a sustainability report and an ESG section of the IR website.

Few areas of corporate reporting have moved as fast, or as unpredictably, as sustainability disclosure. In a few years issuers have seen new EU directives and standards, an international baseline from the ISSB, a US federal climate rule adopted and then abandoned in court, state laws in California, and a growing number of questionnaires from investors and rating providers. For a small or mid cap issuer the practical question is simple: what do we have to publish, where, and how do we keep it consistent? This guide answers it in general terms. It describes the main frameworks as they stood at the time of writing, is not legal or investment advice, and you should check the current status of each rule with counsel, because several have changed recently.

Start with what is mandatory for you

Mandatory sustainability disclosure depends on where you are listed, where you are incorporated, your size and, increasingly, where you do business. Map your obligations before you decide anything about voluntary reporting.

European Union

• Corporate Sustainability Reporting Directive. The CSRD requires companies in scope to report sustainability information in a dedicated section of the management report, prepared under the European Sustainability Reporting Standards, with limited assurance and digital tagging. Reporting started with the largest public interest entities for financial year 2024. In 2025 the EU adopted a postponement of later reporting waves and proposed, through the Omnibus simplification package, to narrow the scope and reduce the number of data points. The final scope and timing for your company depend on how that package was adopted and transposed in your member state.
• Double materiality. Under ESRS, a company reports on sustainability matters that are material either because of their impact on people and the environment, or because of their financial effect on the company, or both. The materiality assessment drives what is reported.
• EU Taxonomy. Article 8 of the Taxonomy Regulation requires companies subject to the sustainability reporting rules to disclose the share of turnover, capital expenditure and operating expenditure associated with environmentally sustainable activities.
• Funds. Asset managers and funds have their own regime under the Sustainable Finance Disclosure Regulation, with entity level and product level disclosures.

United States

• SEC rules. The SEC adopted a climate disclosure rule in March 2024. It was stayed pending litigation, and in 2025 the SEC voted to end its defense of the rule. There is therefore no specific federal climate disclosure rule in effect for US issuers at the time of writing.
• Existing SEC requirements still apply. Material risks, including climate related and other sustainability risks, belong in risk factors and in management's discussion where they are material. Regulation S-K also requires a description of human capital resources to the extent material to understanding the business. The SEC published interpretive guidance on climate change disclosure in 2010, which applies the general materiality principles.
• State laws. California adopted laws requiring large companies doing business in the state to report greenhouse gas emissions and climate related financial risk. Their implementation has been subject to rulemaking and litigation, so check the current position if you have revenue in California.

The international baseline

The International Sustainability Standards Board issued IFRS S1, on general sustainability related financial information, and IFRS S2, on climate, in 2023. They focus on financial materiality, meaning information useful to investors. They apply only where a jurisdiction adopts them, and a growing number of jurisdictions have adopted or are adopting them, in full or adapted form. Many issuers that are not required to use them still align voluntary reporting with them, because investors recognize the structure.

Exchange rules

Some stock exchanges require or recommend ESG reporting in listing rules or in corporate governance codes, often on a comply or explain basis. Check your exchange.

What to publish

Beyond the mandatory items, issuers face a long list of possible topics. A useful way to decide is to ask what your investors actually use, and what is material to your business. The table below shows the core areas investors commonly ask about.

Area	Typical content	Why investors ask
Governance	Board composition and independence, oversight of sustainability, executive pay links, ethics and anti-corruption policies	Governance quality is a long standing input to investment decisions and voting
Climate	Scope 1 and 2 emissions, Scope 3 where material, targets, transition plan, physical and transition risks	Climate risk affects cost of capital, regulation and asset values
Workforce	Headcount, turnover, health and safety, training, pay practices	Human capital drives performance in most sectors
Supply chain	Supplier standards, human rights due diligence, sourcing risks	Legal exposure and reputational risk
Sector specific topics	Water for utilities and food, data privacy for software, product safety for consumer goods	Material issues differ by industry

Two principles matter more than the length of the list. First, report metrics that you can reproduce every year with the same method, because a one-off number nobody can update does more harm than good. Second, separate facts from ambitions. Targets need a baseline, a date and a plan, and progress against them should be reported plainly, including when you are behind.

Avoid greenwashing risk

Regulators in the US, the EU and the UK have taken action against misleading sustainability claims, mostly by asset managers but increasingly by companies. Every claim in an ESG report is a public statement by the issuer. Treat it with the same discipline as financial disclosure: a source for every figure, a review by finance and legal, and wording that does not promise more than the data shows.

Where to publish

The same information often appears in four or five places. The risk is not too little disclosure but inconsistent disclosure: a different emissions figure in the annual report, the sustainability report, the website and a questionnaire. Decide where each item lives and make the other places point to it.

Channel	What goes there	Notes
Annual report or management report	Mandatory sustainability statement under CSRD and Taxonomy disclosures for EU companies in scope, material risks for all issuers	Audited or assured content, highest liability standard
SEC filings	Material sustainability risks in 10-K risk factors and MD&A, human capital description	Subject to the same liability as other filed content
Sustainability or ESG report	Voluntary metrics, targets, policies, framework indexes	Often published annually, sometimes aligned to ISSB or other frameworks
IR website ESG section	Summary, reports, policies, data tables, ratings responses, contacts	The first place investors and analysts look
Investor questionnaires and rating providers	Answers to specific data requests	Should reuse published figures, not create new ones

The IR website as the hub

For most investors the ESG section of the IR website is where research starts. A good section has a short summary of your approach, the latest reports and policies as documents with dates, a data table with several years of the key metrics and their definitions, the frameworks you report against, and a named contact for ESG questions. Keep older reports available so that analysts can see the history.

Questionnaires and requests

Issuers receive a steady flow of ESG questionnaires from investors, data providers and customers. Answering each from scratch wastes time and creates inconsistent numbers. Build a library of approved answers and figures with their sources, update it once a year after the report is published, and answer from it. When a question asks for something you do not publish, decide deliberately whether to add it to your reporting, rather than disclosing it privately to one requester.

Running the ESG reporting cycle

Sustainability reporting works best when it follows the same rhythm and controls as financial reporting.

1. Map obligations. Each year, list the rules that apply to you, their status and their deadlines.
2. Assess materiality. Run or refresh the materiality assessment, documenting the process and the result.
3. Collect data with owners. Each metric has an owner, a definition, a source system and a deadline.
4. Review and approve. Finance, legal and the relevant committee review the report and the figures, and the approval is recorded.
5. Assure where required. Limited assurance under CSRD, or voluntary assurance on key metrics.
6. Publish consistently. Annual report, sustainability report, website and data tables updated together.
7. Answer requests from the library. Questionnaires and investor questions answered from approved content.

Calendar overlaps

ESG reporting usually overlaps with the annual results cycle, the AGM season and peak questionnaire season. Putting the ESG milestones on the same calendar as the earnings release checklist and the AGM avoids last minute conflicts for the same small team.

Common mistakes

• Three numbers for one metric. The annual report, the sustainability report and a questionnaire show different emissions or headcount figures because each was compiled separately.
• Changing methods without saying so. A new calculation method makes the trend look better or worse. Restate prior years or explain the break.
• Targets without a plan. A net zero date with no interim milestones and no capital allocation invites hard questions and regulatory scrutiny.
• Copying a peer's report. Material topics differ even within a sector. A report built on someone else's materiality assessment answers the wrong questions.
• Private disclosure by questionnaire. Giving one data provider a figure that is not public, and that may be material, creates the same selective disclosure risk as a private meeting.
• Stale web pages. An ESG page that still shows a report from three years ago signals that nobody owns the topic.

Most of these mistakes come from the same cause: ESG data handled outside the controls used for financial reporting. Bringing it into the same calendar, the same review and the same approval record removes most of them.

ESG in investor meetings

ESG questions now come up in ordinary investor meetings, not only in dedicated stewardship meetings. Prepare for them like any other topic. Know the published figures and targets, know the questions the investor's stewardship team has asked other companies, and stay within public information. Regulation FD and MAR apply to sustainability information as to any other, so a new target or a material change in emissions belongs in a public announcement, not in a private conversation. Our investor meeting preparation checklist covers how to prepare.

How Issuers fits in

Issuers does not calculate emissions or prepare the sustainability statement. Specialist tools and advisers do that. What Issuers handles is the disclosure workflow around it. In the disclosure management software module, ESG reports and policies go through the same deadline calendar and approval chain as other announcements, with versions and an audit trail. Published documents feed the IR website, and the investor CRM records ESG questions from each investor so the next brief includes them. Every figure the Copilot uses in a brief or a draft answer links to the published document it came from.

This article is general information about sustainability disclosure frameworks and common practice. It is not legal or investment advice. Sustainability rules have changed several times recently and differ by market, so confirm the current requirements with your counsel and auditors.