任意から標準化へ：ESRSとISSBにおけるサステナビリティ報告の変容

Unofficial AI-generated summary based on the public title and abstract. Not an official translation.

🔬研究者:Provides a systematic comparative framework for analyzing sustainability reporting standards, useful for further research on regulatory convergence.

🏢実務担当者:Helps multinational companies understand the differences between ESRS and ISSB to prepare for dual reporting and align internal processes.

🏛政策担当者:Informs regulators about the degree of interoperability and remaining gaps between ESRS and ISSB, supporting efforts toward global standardization.

Sustainability reporting has undergone a fundamental structural transformation, shifting from fragmented, voluntary frameworks—long dominated by the Global Reporting Initiative—toward rigorous, standardized, and increasingly mandatory regimes. This evolution has been crystallised by the parallel emergence of two landmark regulatory architectures: the European Sustainability Reporting Standards, developed by the European Financial Reporting Advisory Group under the Corporate Sustainability Reporting Directive (Directive 2022/2464/EU), and the IFRS Sustainability Disclosure Standards (IFRS S1 and IFRS S2), issued by the International Sustainability Standards Board under the auspices of the IFRS Foundation. Although both regimes share the overarching objective of enhancing corporate transparency and comparability, they embody fundamentally divergent conceptions of materiality. While the ISSB adopts an investor-centric singlemateriality lens focused on sustainability-related financial risks affecting enterprise value, the ESRS codifies a double-materiality paradigm that requires undertakings to report both on how sustainability matters affect them and on the impact of their operations on society and the environment. This paper conducts a comparative documentary analysis of the ESRS and ISSB regulatory texts, employing qualitative thematic coding to systematically map disclosure mandates, classify structural variations in materiality definitions, and assess the degree of thematic and structural alignment between the two frameworks. The analysis explicates the power dynamics and institutional tensions that shape this contested regulatory arena—particularly the EC/EFRAG’s stakeholder-inclusive stance versus the IFRS Foundation’s marketoriented orientation—and evaluates the operational implications for firms, especially multinational enterprises operating across both jurisdictions. Preliminary findings reveal a measurable degree of structural interoperability, especially in climaterelated disclosures, yet persistent methodological heterogeneity in governance, double-materiality assessment processes, and value-chain data aggregation.

• openalex https://doi.org/10.47535/1991auoes35(1)042first seen 2026-08-28 04:35:39