Reporting Frameworks

Legal base

Article 1 of the DIRECTIVE sets out that companies concerned "[...] may rely on national,Union-based or international frameworks, and if they do so, [...] shall specify which frameworks they have relied upon".

Recital 9 of the Directive provides examples of existing reporting frameworks. However this list should not be viewed as exhaustive.

Recital 9 of the DIRECTIVE states: "In providing this information, undertakings which are subject to this Directive may rely on national frameworks, Union-based frameworks such as the Eco-Management and Audit Scheme (EMAS), or international frameworks such as the United Nations (UN) Global Compact, the Guiding Principles on Business and Human Rights implementing the UN 'Protect, Respect and Remedy' Framework, the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the International Organisation for Standardisation's ISO 26000, the International Labour Organisation's Tripartite Declaration of principles concerning multinational enterprises and social policy, the Global Reporting Initiative, or other recognised international frameworks. "

Although companies may also consider using other reporting frameworks such as for example the International Integrated Reporting Framework, the Sustainability Accounting Standard Board standards, CDP, CDSB, the Organisation Environmental Footprint Guide or others. Last but not least a legal framework of GDP Regulation must be provided.

National, EU-based or international frameworks 

In line with the Directive, a company may rely on high quality, broadly recognised national, EU-based or international frameworks when preparing its non-financial statement. Some of them are horizontal; others are sector or thematic issue-specific. Some target exclusively disclosure of non-financial information; others refer to transparency in a broader context.

Usually, relying on a widely recognized framework developed with due process provides companies with a structured reporting approach to key issues of broad interest, limits administrative burden, and enhances comparability.

A company relying on one or several frameworks in order to report material non-financial information, should disclose which framework(s) it has used for which specific disclosures. This disclosure would enhance clarity and comparability.