CORPORATE ACTION → DISCLOSURE
Disclosure
Telling the world where you stand – the catalyst for strategy and target-setting.
Corporate Sustainability Journey
In 30 Seconds
Disclosure comes after measurement – once you know your baseline, you tell stakeholders where you stand. This isn't just compliance; it's the catalyst that drives strategy and target-setting.
The reality: CDP asks “do you have a science-based target?” CSRD requires you to explain your strategy. The act of disclosure creates pressure to commit. Many organisations set their first targets in response to disclosure requirements.
The opportunity: Well-executed disclosure builds credibility, attracts capital, and forces strategic clarity. It's not the end of the journey – it's the moment that shapes what comes next.
The Reporting Landscape
Different frameworks serve different purposes. Understanding which apply to you – and how they connect – is the first step.
CDP
formerly Carbon Disclosure Project
Scope: Global, voluntary (but often expected)
Who: Any company, SME questionnaire available
What: Annual questionnaire on climate, water, forests, biodiversity
CSRD
Corporate Sustainability Reporting Directive
Scope: EU mandatory
Who: Large companies, listed SMEs (phased)
What: Comprehensive sustainability statement using ESRS
UK SRS
UK Sustainability Reporting Standards
Scope: UK mandatory (from 2026)
Who: Large UK companies (phased)
What: UK-endorsed ISSB standards (IFRS S1, S2)
Key insight: These frameworks increasingly align. Data collected for CDP often feeds CSRD. CSRD and UK SRS share common ancestry in ISSB. Build once, report many.
CDP: The Gateway to Corporate Disclosure
For many companies, CDP is where sustainability reporting begins. Over 23,000 companies disclosed through CDP in 2023, driven by investor and customer requests.
Full CDP Questionnaire
For larger organisations
- • Comprehensive climate, water, and/or forests disclosure
- • Governance, strategy, risk management, metrics
- • Scored A to D- (or F for non-disclosure)
- • Significant time investment (weeks to months)
- • Often requested by investors, customers in supply chains
CDP SME Questionnaire
For smaller organisations
- • Streamlined version launched for SMEs
- • Lower barrier to entry
- • Focus on material climate impacts
- • Pathway to full disclosure over time
- • Increasingly requested by large corporate customers
Why CDP Matters
CDP isn't just a questionnaire – it's a credibility signal. A strong CDP score opens doors: investor confidence, supply chain contracts, benchmarking against peers. A poor score (or no disclosure) increasingly closes them.
Many companies start their sustainability journey here, then use the data and processes for broader reporting.
CSRD: The EU Standard
The Corporate Sustainability Reporting Directive represents a step-change in mandatory disclosure. If you operate in the EU or have significant EU business, this is likely on your horizon.
Phased Implementation
Companies already under NFRD
Reporting on 2024 data
Large companies (250+ employees, €40M+ turnover)
Reporting on 2025 data
Listed SMEs (with opt-out until 2028)
Reporting on 2026 data
Non-EU companies with significant EU presence
Reporting on 2028 data
What CSRD Requires
CSRD uses the European Sustainability Reporting Standards (ESRS), covering environment, social, and governance topics. It requires double materiality – reporting on both how sustainability issues affect your business AND how your business affects people and planet.
This is comprehensive reporting: governance structures, strategy, policies, targets, metrics, and forward-looking statements. Third-party assurance is required.
UK SRS: What's Coming
The UK is developing its own Sustainability Reporting Standards, endorsing the ISSB standards (IFRS S1 and S2) with UK-specific modifications. This creates the UK's mandatory climate and sustainability reporting regime.
IFRS S1
General Sustainability Disclosures
Core framework for reporting sustainability-related risks and opportunities that affect enterprise value.
IFRS S2
Climate-related Disclosures
Climate-specific requirements including physical and transition risks, Scope 1, 2, and 3 emissions.
Timeline & Scope
UK SRS is expected to apply from accounting periods starting January 2026, initially for the largest UK companies. The scope will expand over subsequent years.
Companies already reporting under TCFD have a head start – ISSB builds on the TCFD framework. But the level of detail and assurance requirements will increase significantly.
Building Once, Reporting Many
The good news: these frameworks are converging. The data you collect for one increasingly serves others. The challenge: knowing where to start and how to build efficiently.
Common Foundations
Governance
Board oversight, management roles, policies
Strategy
How sustainability affects business model
Risk Management
Identification, assessment, mitigation
Metrics & Targets
What you measure, what you're aiming for
Practical Approach
- 1. Map your obligations: Which frameworks actually apply to you now and in 2-3 years?
- 2. Build core data infrastructure: Emissions data, governance documentation, risk registers
- 3. Start with the most demanding: If you need CSRD, that data serves CDP and UK SRS
- 4. Iterate annually: Reporting quality improves over time – start now, refine later
The Pandion View
Reporting isn't the end goal – it's a forcing function. The discipline of disclosure drives better data, clearer thinking, and more accountable commitments. But only if you treat it as a strategic exercise, not a compliance checkbox.
The companies that report well are the companies that act well. Disclosure creates accountability. Accountability drives performance. That's why we see reporting as the foundation for everything else.
As a hybrid professional, we help clients navigate the reporting landscape without getting lost in it. We focus on building reporting capability that serves the business – not just the compliance team.