Stakeholder participation in EFRAG's standard-setting process for sustainability reporting – New publication in SEAJ

In her latest article, Alessandra Kulik (Professor of Business Administration, specializing in Auditing and Taxation, Dresden University of Technology) examines stakeholder participation in the European Financial Reporting Advisory Group (EFRAG) standard-setting process for sustainability reporting. The analysis covers the comment letters received for the first 13 Exposure Drafts (EDs) of the European Sustainability Reporting Standards (ESRS).

The empirical findings show clear differences between stakeholder groups: companies participate more frequently in the consultation, while users of sustainability reports signal stronger support for additional disclosure requirements. Furthermore, feedback varies depending on cultural and institutional background as well as parallel participation in other consultations on sustainability reporting.

The results provide the first systematic empirical evidence on the dynamics and significance of stakeholder participation for the input legitimacy and normativity of the ESRS and contribute to emerging research on sustainability reporting and standard setting in Europe.

The article is available in  Open Access.

Kulik, A. (2025). Initial Evidence on Stakeholder Participation in EFRAG's Sustainability Reporting Standard-Setting Process. Social and Environmental Accountability Journal, online first. https://doi.org/10.1080/0969160X.2025.2588597

Abstract

This paper investigates stakeholder participation in the European Financial Reporting Advisory Group’s (EFRAG’s) standard-setting process for sustainability reporting, with a focus on the extent of participation and the level of support across different stakeholder groups and geographical regions. Centred on EFRAG’s development of the European Sustainability Reporting Standards (ESRS), this study analyses participation in the public consultation on the first 13 exposure drafts (EDs). Employing a rational-choice framework and neo-institutional approaches in the analysis of the feedback received from the public consultation, the research tests hypotheses regarding stakeholder behaviours and country-specific differences. The findings highlight significant disparities in participation: preparers demonstrate higher participation frequencies than users, while users express greater support for additional sustainability-related disclosure requirements. Furthermore, support varies among stakeholders with different attributes, such as cultural and institutional backgrounds or simultaneous participation in other sustainability reporting consultations. These results underscore the critical role of stakeholder diversity in fostering input legitimacy and the normativity of the ESRS. By offering early empirical evidence, this paper contributes to emerging literature on sustainability reporting standard-setting and provides valuable insights into the stakeholder dynamics within the European Union (EU) sustainability reporting framework.