Lead with interoperability: How to streamline sustainability reporting across a fragmented regulatory landscape

  • 9 minute read
  • August 26, 2025

Kevin O’Connell

Sustainability Assurance Services Leader, PwC US

Emily Kirsch

Director, Sustainability Assurance, PwC US

A new era of opportunity is emerging as sustainability disclosure requirements — from California’s climate laws to the EU’s Corporate Sustainability Reporting Directive (CSRD) — continue to take shape. Rather than just adding complexity, these developments are opening the door for companies to strengthen and unify their sustainability and financial reporting practices like never before. Many companies are focusing on the common foundations that underpin both domestic and international requirements and areas of strategic focus to streamline their reporting efforts and make efficient use of limited resources.

By understanding interoperability — that is, focusing on common data foundations and how disclosure frameworks overlap and differ — and then embedding sustainability into financial reporting processes, your company can proactively build a resilient, future-ready reporting ecosystem, and potentially leverage sustainability data to identify ways to create long-term value for the business.

Sustainability reporting shift Navigating the challenges — and opportunities — of an evolving reporting landscape

For US companies, the evolving sustainability reporting landscape – shaped by the 2024 election and shifting global sentiments – presents both challenges and new opportunities. The SEC’s March 2024 climate-related disclosure rules have an uncertain future under the new administration, which has begun rolling back many sustainability-related regulations. In the absence of federal standards, many individual states are following California’s approach and proposing their own unique disclosure requirements. Though varied in scope and timing, these state-level initiatives offer companies the chance to build flexible reporting systems that can adapt to regional nuances while contributing to a broader culture of transparency.

At the same time, both global and US companies are monitoring a steady stream of global regulatory changes, including efforts to make reporting more accessible and practical. The European Commission’s Omnibus simplification package has led to proposed revisions to the European Sustainability Reporting Standards (ESRS) and the Taxonomy Regulation, as well as relief for wave 1 CSRD reporters — all of which are aimed at simplifying the reporting itself. Around the world, emerging sustainability regulations increasingly include third-party independent assurance requirements, reinforcing the importance and credibility of sustainability data.

While the breadth of global standards can be complex, many companies are discovering areas of alignment and overlap. These common threads allow for a more integrated reporting foundation — an encouraging sign that despite the patchwork nature of some regulations, there are pathways to streamline data collection, reduce duplication and improve reporting efficiency. This opportunity to establish a streamlined approach could slash costs, reduce resource use and enable your organization to quickly adapt to new regulations.

But how can your company achieve these benefits? This new era of sustainability reporting requires a fresh approach. To support end-to-end reporting your organization should consider combining deep knowledge of sustainability frameworks with emerging technologies, new carbon accounting software and AI and generative AI (GenAI) to help streamline processes and enhance internal controls. Your company can wisely use any extra time it now has before new reporting deadlines kick in to implement a scalable approach that can transform what could be viewed as a convoluted compliance exercise into opportunities to capture synergies and drive business value, including improved target setting, transition planning, real-time progress monitoring and greater operational efficiency.

Define interoperability How can interoperability improve sustainability reporting efficiency?

CFOs and ESG controllers are increasingly working with sustainability leaders to guide sustainability efforts because they have the technical acumen to produce sustainability reporting alongside traditional financial disclosures and can align these efforts with long-term strategic planning. As they discuss compliance with these regulations throughout the C-suite, the conversations likely turn to a key concept: interoperability.

Given the multitude of reporting requirements, your CFO or ESG controller may ask: “Can’t we just use the reporting we produced for one country’s requirements to meet another’s regulations?” For now, there are limited opportunities to use reporting produced using a particular framework to satisfy regulations in other regions or countries that use a different framework in its entirety. This is why your company should understand how the underlying data may be interoperable — or, how disclosure frameworks overlap and differ — to be able to gather data once and use it across regulations. ESRS and the IFRS Sustainability Disclosure Standards (issued by the International Sustainability Standards Board (ISSB)) have a high degree of alignment — structured around governance, strategy and risk management topics — that is only expected to increase following the EFRAG’s ESRS revisions. EFRAG and the ISSB have even provided interoperability guidance, with a specific emphasis on climate-related disclosures.

Interoperability won’t magically erase reporting obligations. For example, there may be regional, country and state-specific regulatory nuances, including the obligation to report at a subsidiary level. But if you act now you can use the remaining runway to prepare thoughtfully and convert any effort spent into measurable value.

Reporting and technology Five steps for building a reporting process in a complex regulatory landscape

Imagine a US manufacturer maneuvering through this regulatory environment, sourcing components from Asia while distributing products across Europe, the US and other global markets. The company may need to meet California’s climate reporting requirements, the CSRD and other international regulations. It should thoroughly understand how to implement a sustainability reporting strategy to help meet multiple requirements as compliance becomes mandatory. In this example, this means having the ability to report under several reporting regimes — including ESRS and ISSB reporting frameworks — by implementing a scalable reporting process.

So how can CFOs and ESG controllers tasked with this responsibility work with the sustainability function to pull it off? Here are some considerations that may drive your company’s approach to sustainability reporting:

Although there are reporting regulations in many countries, your organization may only be subject to a subset of them. Each regulation has unique criteria for scope and reporting deadlines, making it important to assess applicability and centralize these determinations in collaboration with the legal function, subsidiaries and business units across geographies to reduce regulatory surprises due to misinterpretation. Sensitivity analyses of scoping thresholds may also help companies anticipate how shifts in CSRD and EU Taxonomy Regulation — and in their own growth plans and business strategies — could impact reporting obligations.

Climate reporting shines through as a fundamental element of many global regulations, making it a probable candidate to prioritize. Additionally, CFOs and ESG controllers should understand independent assurance requirements for each regulation, including what information requires independent assurance, the timing of these obligations and the level of assurance needed, to incorporate the necessary activities into implementation planning.

While the board will likely know about major regulations like the CSRD, your CFO or ESG controller may need to upskill directors on how reporting requirements align and diverge, in developments in the ever-changing regulatory environment, and on local obligations that require their attention. They should also work across the C-suite to enable responsibilities consistently for sustainability data sourcing and collection, and other sustainability initiatives, are clearly defined and communicated.

If your company is reporting in multiple jurisdictions, you may want to design your materiality assessment process in a way that is useful for multiple frameworks — that is, implementing an approach in which the results of the materiality assessment may be used as the basis for reporting in more than one jurisdiction.

Each framework has its own definition of materiality that should be applied to information; although, some of these definitions are aligned. EFRAG’s proposed revisions to ESRS simplify the double materiality assessment requirements and bring aspects of the assessment even closer to the ISSB’s principles. Your company may find comfort in streamlining the materiality assessment process where possible, to reduce complexity in approach and to allow for time to focus on the strategic insights that materiality assessment can bring to light.

Want insights into what companies have been disclosing, including materiality assessments? PwC looked at CSRD reports from 250 Wave 1 companies to analyze how companies are identifying both risks and opportunities. Our sustainability reporting guide has additional information on how to navigate these assessments across regulations.

PwC’s Global CSRD Survey 2024 revealed that data availability and data quality are the major challenges for companies to comply with disclosure regulations. The lack of consistent, verifiable data can make it difficult to track emissions, energy use and resource impacts across the value chain. That’s why it’s so important for your CFO or ESG controller to understand how the data flowing through the company’s systems is sourced, collected, cleansed and stored. These leaders can help put in place effective governance and controls that can drive confidence in the traceability and reliability of this data. Identifying common metrics across regulations is integral to interoperability before moving on to spotting any data gaps, remediation and development of a testing strategy for the accuracy of this information so that it can be leveraged across multiple reporting needs.

Wave 2 companies should look at the additional time to comply with CSRD as an opportunity to invest in developing, prioritizing and gaining consensus on meaningful plans to move from data that’s “good enough” to data that can be relied on to make strategic decisions that could impact the core of a company’s business model. But remember, California deadlines are quickly approaching. A good rule of thumb: Companies should focus on availability and quality of the core common data points such as GHG emissions and then modify their approach to meet specific regional or country requirements.

Once your company is comfortable with its established processes and data, an assessment of your current technology landscape with an eye toward identifying capabilities gaps can prove invaluable. The goal? To seamlessly collect and share information not only across the organization — finance, operations, procurement, sustainability, human resources and risk — but also between supplier and customer. The technology you select should be flexible enough to adapt to evolving regulatory demands. While your organization can likely augment its existing systems with cost-effective upgrades, it should also be looking to the future to understand how AI, including GenAI, may drastically change data collection and reporting.

For example, CFOs and ESG controllers can free up resources by working with technology teams to deploy agentic AI that automates key tasks — retrieving data, assessing quality, and analyzing trends. These autonomous AI agents can also monitor regulatory updates, summarize their impacts and draft initial disclosures and reports for review. With human oversight of those automated tasks, teams can focus on higher-value work while an AI-enabled operating model drives efficiency across the reporting lifecycle.

Sustainable value A regulatory strategy that can help drive business outcomes beyond compliance

It may be tempting to be reactive to the compliance requirements that companies should meet. But those that take a “wait and see” approach may fall behind more proactive peers on realizing the value of reliable, decision-useful data beyond compliance to better analyze business trends, identify potential risks and opportunities and measure progress against goals. Effective reporting strategies can also allow companies to directly engage with stakeholders to tell a compelling story on the actions they are taking to improve operational efficiencies and reduce costs and their carbon footprints.

In today’s regulatory environment, CFOs and ESG controllers should consider adopting a proactive, tech-enabled approach to sustainability reporting that starts with assessing the interoperability of applicable regulations. Doing so will allow companies to focus attention on areas with the highest likely ROI – from both compliance and strategic perspectives – while also being more streamlined with resources and potentially reducing risk in an era of increasing regulatory complexity.

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Kevin O’Connell

Kevin O’Connell

Sustainability Assurance Services Leader, PwC US

Emily Kirsch

Emily Kirsch

Director, Sustainability Assurance, PwC US

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