Regulatory Divergence and ESG Alignment: Comparative Assessment of Sustainability Disclosures of Canada's CSDS, EU's CSRD/ESRS and India's BRSR Frameworks

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🔬研究者:Comparative governance scholars will find a structured analysis of three major frameworks, highlighting trade-offs between materiality approaches and enforcement levels.

🏢実務担当者:Multinational companies can use this to assess compliance burdens and strategic alignment across jurisdictions.

🏛政策担当者:Regulators seeking to harmonize standards or design national frameworks will benefit from the cross-system comparison and convergence recommendations.

Sustainability disclosure standards are redesigning corporate reporting by developing transparency, consistency and accountability in environmental, social and governance (ESG). This is driven by global objectives, investor demands and cross-border market needs. This chapter compares three key frameworks: The Canadian Sustainability Disclosure Standard (CSDS), which is aligned with ISSB IFRS S1 and S2, adopt a voluntary, financial material approach emphasizing climate-related risks; the European Union&s;s Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standard (ESRS), requiring mandatory double materiality, comprehensive ESG coverage, and enforcement large entities; and India&s;s Business Responsibility and Sustainability Reporting (BRSR), a mixed mandatory voluntary system for to 1,000 listed companies, stakeholder oriented and aligned with national guidelines and GRI. Despite ISSB interoperability, gaps in scope and enforcement challenge multinationals. The urgent convergence is needed for uniform, credible and comparable ESG insights. The study adopts a qualitative research methodology using thematic analysis. By qualitatively analyzing how these frameworks affect corporate sustainability reporting and SDG disclosure, the study seeks to generate insights into regulatory convergence, divergence, and governance outcomes. Ultimately, it aims to provide policy-relevant recommendations and actionable strategies for enhancing sustainability reporting effectiveness and fostering corporate contributions to sustainable development within disparate legal and institutional contexts. The research will contribute to the academic discourse on comparative sustainability governance and support ongoing international efforts toward harmonized ESG standards. The findings provide valuable insights for regulators globally to advance the Sustainable Development Goals, while fostering corporate governance and achieving a balance between prescriptive and principle-based approaches.

• openalex https://doi.org/10.1201/9781042009664-14first seen 2026-07-18 06:08:17