ESG Reporting Deadlines in 2024

What Does Reporting Entail…?

Frameworks, Standards, and Ranking Schemas that require the submission of questionnaires and specific data to an external portal will have definitive annual deadlines to abide by, and overall timelines for portals opening and results being released. These include frameworks like CDP, GRESB, and UN Global Compact, as well as rating/ranking entities like S&P ESG indexes. Reporting “due dates” for those putting together reports that follow GRI, SASB, TCFD, IR, and SBTi for example, are generally year-round and flexible and can vary depending on the company’s internal reporting schedule. Certain frameworks and standards as aforementioned do not have formal processes for submitting data on portal sites, rather they are intended to be followed closely when firms are putting together their own reports or integrating them into financial 10k filings. Regardless, final deadlines should not be your sole focus – think about the milestones necessary to get there (final data due date, third-party accreditation deadlines, internal deadlines for annual reporting, how long your legal team need to vet the response, etc.). Internal review, as well as data collection and auditing, are two key roadblocks that can pop up at the last minute so it’s important to build in buffer time. You should confirm timelines for general reporting (e.g., ESG report, 10-K, annual report, and proxy statement) if  your business plans to integrate ESG narratives into internal disclosures.

Timelines and Dates

While many deadlines may occur in Q2 or Q3 of each year, it is essential to have the right technology in place for emissions calculations and other sustainability data collection well in advance of those deadlines. We have identified some key reporting deadlines and release dates for ESG frameworks, standards, rating and ranking questionnaires, and assessments.

U.S. Relevant Regulations with Non-Specific Reporting dates:

• SEC Climate Disclosure Rules (proposed): The SEC’s climate disclosure rule (expected Q1, 2024) would require publicly traded companies to disclose information about climate-related financial risks and report their greenhouse gas emissions.
• California SB 253 Climate Corporate Data Accountability Act: Scope 1 and 2 for FY2025 in 2026 & limited assurance 
• California SB 261 Climate-related Financial Risk: 2026 and every two years thereafter
• Building Performance Standards: Building performance standards are regulations specifically targeted toward reducing emissions or improving energy efficiency in buildings. Check out the Institute for Market Transformation website to find out more about whether your city or state currently has a BPS plan in place with future rolling deadlines or is in the process of enacting one. 
• EU Corporate Sustainability Reporting Directive: For non-EU companies, the requirement to provide a sustainability report applies to all companies generating a net turnover of €150 million in the EU and which have at least one qualifying EU subsidiary or a branch with EUR 40 million of turnover in the EU. These companies must provide a report on their ESG impacts, risks, and opportunities in accordance with the European Sustainability Reporting Standards. The first reporting requirements start from 1 January 2024 for companies already subject to the non-financial reporting directive, but most non-EU companies will have until 2028/29 to comply.

Rating and Ranking Indices

• Corporate Knights Global 100: Portal opens and closes in Q3
• Bloomberg: Rolling submissions, ongoing analysis
• Morningstar Sustainalytics: Rolling by company
• MSCI: Company-determined, ongoing

Tips on Reporting

With the global rise of greenwashing penalties and civil litigation, companies need to shore up on their sustainability reporting processes and ensure they are following recommended steps and protocols for data collection. While procrastination may seem alluring, given that the inaugural deadlines for many directives are not imminent — and do not apply to all businesses — such a game plan could be short-sighted.

1. Proactively Align With Standards: Leading companies are engaging in voluntary sustainability reporting schemas in the year 2024 that follow stringent guidelines similar to those of future legislation that may come into effect (ISSB, GRI, and CDP). This ensures they have a strategic advantage when it comes to future compliance. This year’s reporting cycle should be thought of as a preliminary exercise for the impending regulatory environment. By conducting this year’s sustainability reporting with diligence as if it were already under the scrutiny of these new mandates, businesses will position themselves favorably for future regulation.
2. Do Not Defer Action: Mandated reporting for corporations in the U.S. may still be on hiatus, but the global trend is unmistakably moving towards obligatory reporting mandates, impacting every corporation, irrespective of size. Deferring action could prove detrimental and financially onerous. The construction of a sustainability management framework that aligns with relevant legislation and directives is a multi-stakeholder, intensive commitment that requires cross-functional team support within an organization, and investment in tools and technology. 
3. Leverage Technology for Data Management: Employ advanced data management tools and software to streamline the collection, analysis, and presentation of sustainability data. This could include using AI for data analysis or blockchain for ensuring data integrity. By automating and digitizing processes, you can enhance the accuracy and efficiency of your reporting, while also making it easier to track progress over time. Given that the data for reporting in a particular fiscal year is based on the sustainability data acquired from the previous year, corporations should be reporting voluntarily to practice their data collection at least 2 years prior to regulations going into effect. Organizations are highly encouraged to collect data on a regular basis throughout the year via real-time monitoring. This establishes credible data coverage of important environmental metrics and reduces data error. 
4. Hire Experts in Sustainability: Sustainability analysts, consultants, and assurance providers may be necessary to outsource when preparing reports going forward. A well-intentioned report drafted internally and reviewed by in-house counsel, instead of an attorney who specializes in this area, could cause tangible legal problems in 2024, as greenwashing litigation is on the rise. 

Preparations by Quarter

Q1 Prepare and Plan: 

The first quarter of the year is the perfect time to prepare and plan for ESG reporting by starting to aggregate resources. Begin by reviewing your organization’s ESG reporting obligations and familiarizing yourself with the relevant frameworks and standards, such as the Internation Sustainability Standards Board (ISSB), Global Reporting Initiative (GRI), the Sustainability Accounting Standards Board (SASB), the Task Force on Climate-related Financial Disclosures (TCFD), and the Carbon Disclosure Project (CDP). Map out available data, policies, strategies, and goals for developing reporting narratives. If there is any documentation needed from external sources to comply with certain standards, such as supplier policies or employee satisfaction surveys, collect these documents in advance. Continue to gather relevant data points associated with reporting needs. If you have set any ESG goals or targets in the past few years (e.g., emission reduction targets, increased diversity, equity, and inclusion metrics), track progress against these goals year-to-date (YTD).

Q2 Collect and Analyze:

During the second quarter, focus on collecting and analyzing ESG data. After compiling all your resources and information, this is the time to start writing your narratives. Work with internal stakeholders to draft responses to questionnaires and begin internal review.

During Q2, GRESB and CDP’s online response systems open. Companies can begin submitting responses at this time. During Q2 of the reporting year, you want to finalize and release Q2 filings for general reporting based on other standards.

Q3 Report and Review: 

You should continue communicating with stakeholders/shareholders on the reported content. Submissions are due this quarter for standards with specific deadlines like CDP and GRESB.

Q4 Reflect and Improve: 

Scoring results are generally released by the end of the calendar year. it will be time to start the initial planning for the next reporting cycle. You want to confirm any changes in reporting requirements, themes, and structures of the reports for the next year and initiate data collection for the next calendar year.

More About WatchWire

WatchWire by Tango is a market-leading, energy and sustainability data management platform that uses cloud-based software to collect, automize, and analyze utility, energy, and sustainability data metrics. WatchWire streamlines, automates, and standardizes your sustainability reporting process by integrating directly and/or providing reporting exports to ENERGY STAR Portfolio Manager, LEED Arc, GRESB, CDP, SASB, GRI, and more. The platform provides customizable dashboards, which allow asset managers, sustainability managers, engineers, and more to monitor individual key performance indicators (KPIs) and create custom views for specific use cases.

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