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Sustainability Reporting Timelines & Deadlines
Environmental, Social, and Governance (ESG) or “Sustainability” reporting has become a crucial aspect of corporate responsibility, with increasing attention from investors, customers, and regulators. Adhering to relevant frameworks and standards is essential for companies to stay ahead of the curve. In this blog, we outline the key annual timelines and due dates for major ESG reporting frameworks and standards and provide general advice on what to do in each quarter to ensure successful reporting.
When are reports due?
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.
Keep in mind that final deadlines for internal reports or for external submissions to standards should not be the sole focus of sustainability reporting. There are many milestones involved in the process of reporting that demand equal if not more attention than the final report completion deadline. Thinking about continuous rather than periodic data collection, 3rd party accreditation deadlines, how long each team may need in order to contribute relevant information, data collection & review, and even the reporting cycle for the years ahead is important for successful ongoing sustainability work and getting ahead of potential roadblocks.
- Data Collection: 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.
- Validation for Science-based targets: Submitting and receiving validation for an SBT takes four to six months if the organization is new to the submission process. If a firm wishes to include its SBT in its CDP submission, we recommend starting the submission process in March to be able to submit a target to the Science Based Targets Initiative (SBTi) by mid-July.
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 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 in order 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). Progress should be used as part of your 2022 reporting cycle.
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.
Specific Timelines and Due Dates
SASB and TCFD
- Companies that adhere to SASB Standards should begin gathering data for ESG metrics during Q1. SASB does not have a specific due date for reporting, but it is common for companies to align their ESG reporting with their financial reporting cycle.
- Organizations following TCFD recommendations should start assessing their climate-related risks and opportunities during Q1
- Include findings in relevant annual financial disclosures (i.e., 10-K, Annual Report)
- Organizations following the GRI Standards should start preparing their sustainability report during Q1. There is no set due date for GRI reporting, but companies typically publish their reports during Q2 or Q3.
Carbon Disclosure Project (CDP)
- The CDP annual reporting cycle begins in February when questionnaires are sent out. The Online Response System (ORS) opens the 17 April for 2023 corporate disclosure. Sign in and activate your questionnaire(s) when the ORS opens.
- Submit via the online CDP Portal
- Submission deadline: July 26, 2023
- CDP publishes its annual A-List of high-performing companies during Q3. Review your CDP score and feedback to identify areas for improvement.
Global Real Estate Sustainability Benchmark (GRESB)
- Submit via the online GRESB Portal, which stays open from April 1 to the submission deadline.
- Submission deadline: July 1, 2023
- Results released: October 2, 2023
S&P’s Dow Jones Sustainability Index (DJSI)
- Submit via the online DJSI Portal
- The latest Assessment Window for companies to meet this deadline is July-August 2023, with the latest submission date of September 15th
- Submit via the online UNPRI Portal
- Reporting cycle opens in mid-May and closes in August, with results released in December
State and Local Energy Benchmarking: Energy Star Portfolio Manager
- Due Dates vary based on city and jurisdiction
- Check your relevant dates here
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