SUSTAINABILITY · COMPLIANCE · REPORTING
ESG Frameworks
We are always aligned with the latest regulatory and framework developments.
Mandatory Reporting Requirements
Corporate Sustainability Reporting Directive (CSRD)
EU’s Corporate Sustainability Reporting Directive (CSRD) requires sustainability information to be included in the annual report from the board of directors, and to be subject to external assurance.
The purpose is to make reporting on environmental, social, and governance (ESG) matters more comparable, reliable, and useful for investors, customers, and other stakeholders. CSRD is also intended to increase transparency and reduce the risk of greenwashing.
In Norway, the rules have been incorporated into legislation and are in effect from January 2024.
Who needs to report?
CSRD applies to listed companies fulfilling the following requirements:
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with more than 500 employees
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above 580 MNOK in revenue
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and/or balance sheet total of more than 290 MNOK
Following the Omnibus changes, the thresholds have been revised so that CSRD will apply to undertakings with more than 1,000 employees and more than EUR 450 million in net turnover from FY 2027.
These changes have been adopted at EU level, and the Norwegian Government are working on legislation for national implementation. Until new regulations are adopted, the existing regulations are applicable and are described in the following.
What is being reported on?
CSRD is based on the principle of double materiality assessment (DMA), meaning that the companies must report both on how material sustainability matters affect the company and how the company materially affects people and the environment and how ESG affects the company (risk and opportunities). The materiality aspect is to ensure a balanced and relevant report.
The sustainability reporting shall be conducted in accordance with the European Sustainability Reporting Standards (ESRS). These standards set out what companies must report on under CSRD. The framework consists of 12 standards covering environmental, social, and governance topics (ESG- topics), together with cross-cutting requirements and disclosures. All companies who are required to report on CSRD shall follow the ESRS framework.
The CSRD report shall also include a report on the EU Taxonomy.
How is this done?
The sustainability report shall be published in a dedicated part of the annual report. This report should be available publically on the company website.
The sustainability report shall be assured by an external auditor, either the same as the financial auditor or another qualified auditor.
EU-Taxonomy
The EU Taxonomy is a key part of the EU Green Deal, aiming to direct capital towards activities that support climate and environmental objectives.
It provides a common classification system for defining sustainable economic activities and gives investors, financial institutions, and organizations a shared language for green investment.
Financial institutions must also report on their exposure to sustainable and non-sustainable activities.
The taxonomy is built around six environmental objectives, including climate change mitigation and adaptation, resource use, circular economy, pollution prevention, and biodiversity.
Who needs to report?
The EU Taxonomy applies to companies subject to CSRD.
Following the EU Omnibus changes (effective from FY 2027), mandatory reporting applies to companies with:
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with more than 1000 employees
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above EUR 450 million in revenue
Simplifications include a streamlined reporting template and application of a materiality principle for KPI disclosures.
What is being reported on?
Organizations must disclose the share of:
- Revenue
- Capital expenditure (CapEx)
- Operating expenditure (OpEx)
linked to taxonomy-aligned activities (KPIs).
This information must be included in the annual report and is subject to assurance requirements under CSRD
This improves transparency and comparability in the green transition.
How is this done?
The EU Taxonomy is implemented through a structured assessment of economic activities against defined technical screening criteria. Companies must first identify which of their activities are eligible under the taxonomy and then assess whether these activities meet the requirements for alignment.
The taxonomy covers six environmental objectives:
- Climate change mitigation
- Climate change adaptation
- Sustainable use of water and marine resources
- Circular economy transition
- Pollution prevention
- Protection of biodiversity and ecosystems
To be taxonomy-aligned, an activity must:
- Make a substantial contribution to at least one objective
- Do no significant harm to the other objectives
- Meet minimum safeguards related to social conditions and human rights
Transparency act (Åpenhetsloven)
The purpose of the Transparency Act is twofold. It promotes respect for fundamental human rights and decent working conditions in the production of goods and services and gives the public access to information about how organizationses prevent and address adverse impacts in their own operations, supply chains, and organizations relationships.
Organizationses covered by the Transparency Act have a legal requirement to carry out due diligence in line with the OECD Guidelines regarding human rights and decent working conditions and publish an annual statement regarding their work on their website by the 30th of June.
Who needs to report?
The Transparency Act applies to organizationses based in Norway, as well as foreign companies that offer goods or services, and pay tax, in Norway.
At least two of the following three thresholds must be exceeded to be covered by the Act:
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Revenue above NOK 70 million
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Balance sheet total above NOK 35 million
- An average of more than 50 full-time equivalent employees during the financial year
Simplifications include a streamlined reporting template and application of a materiality principle for KPI disclosures.
What is being reported on?
Companies must publish an annual statement describing their due diligence efforts related to human rights and decent working conditions.
The report should cover:
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Identified risks and adverse impacts
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Measures implemented to prevent or mitigate impacts
- Results and follow-up actions
The statement must be made publicly available on the company’s website by 30 June each year.
How is this done?
Companies are required to carry out due diligence in line with the OECD Guidelines for Multinational Enterprises.
This includes:
- Mapping and assessing risks in operations and supply chains
- Implementing measures to prevent or reduce negative impacts
- Tracking the effectiveness of actions taken
- Communicating how impacts are addressed
Companies must also respond to written requests from the public regarding these topics within a reasonable time and no later than three weeks.
Voluntary Reporting Requirements
Voluntary Sustainability Standard (VS/VSME)
The Voluntary Sustainability Standard (VS), formerly known as VSME, is designed for companies that are not subject to CSRD but choose to report on sustainability voluntarily.
It helps organizations respond to increasing requests for ESG information from customers, suppliers, banks, and investors in a structured and proportionate way.
The standard supports transparency and comparability while remaining practical and scalable for smaller and mid-sized companies.
A double materiality assessment (DMA) is not required under VSME, but it remains a strategically important tool for prioritizing the most relevant sustainability topics and strengthening overall ESG work.
Who needs to report?
The standard is intended for companies not covered by CSRD, particularly small and medium-sized enterprises (SMEs).
It is suitable for:
- Companies that receive sustainability data requests from stakeholders
- Organizations preparing for future regulatory requirements
- Businesses seeking a structured approach to ESG reporting
For companies with more than 750 employees, the VSME may not provide sufficient detail, and more comprehensive frameworks such as ESRS may be more appropriate.
What is being reported on?
The VSME consists of two modules:
- A basic module with core sustainability disclosures
- A comprehensive module with more detailed information
Companies can choose to report using only the basic module or both modules, depending on their size, complexity, and stakeholder needs.
The disclosures typically cover key ESG topics, including environmental impact, social factors, and governance practices.
How is this done?
Companies implement VSME by selecting the appropriate module(s) and collecting relevant ESG data aligned with the standard’s requirements.
The process includes:
- Identifying relevant sustainability topics
- Collecting and structuring ESG data
- Responding to stakeholder information requests
- Publishing disclosures in a consistent and transparent format
The framework is designed to be proportionate, allowing companies to start simple and gradually expand their reporting as maturity increases.
Climate Accounting (GHG Accounting)
Climate accounting measures and reports a company’s greenhouse gas (GHG) emissions, providing insight into its environmental impact across operations and the value chain.
It is a key tool for managing climate risks, identifying reduction opportunities, and supporting the transition to a low-carbon economy.
The purpose is to ensure transparent, consistent, and comparable reporting of emissions, enabling organizations to meet regulatory requirements, stakeholder expectations, and climate targets.
Who should or need to report?
Climate accounting under the GHG protocol is relevant for all organizations seeking to understand and reduce their environmental impact.
It is required for:
- Companies subject to CSRD and ESRS (E1 Climate standard)
- Organizations with climate targets (e.g. net-zero or science-based targets)
- Businesses responding to investor, customer, or regulatory expectations
It is also widely used voluntarily by companies preparing for future requirements or strengthening ESG reporting.
What is being reported on?
Companies report greenhouse gas emissions based on internationally recognized standards, primarily the GHG Protocol.
Emissions are categorized into:
- Scope 1: Direct emissions from owned or controlled sources
- Scope 2: Indirect emissions from purchased energy
- Scope 3: Other indirect emissions across the value chain
Typical disclosures include:
- Total emissions (CO₂e) by scope
- Emissions intensity metrics
- Key emission sources and drivers
- Progress against targets and baseline year
Climate disclosures can also be aligned with GRI Standards (GRI 305) and ESRS, ensuring consistency across sustainability reporting frameworks.
How is this done?
Climate accounting is typically carried out in line with the GHG Protocol, the global standard for measuring and managing emissions.
The process includes:
- Defining organizational and operational boundaries
- Collecting activity data (e.g. energy, fuel, spend, transport)
- Applying emission factors to calculate CO₂e emissions
- Consolidating and validating emissions data across scopes
Companies may use both activity-based and spend-based methods, often supported by digital tools integrated with ERP systems.
A double materiality assessment (DMA) is not required for climate accounting itself, but is highly relevant under CSRD to identify and prioritize climate-related impacts, risks, and opportunities.
Results are disclosed in line with frameworks such as GRI, VSME and ESRS, improving transparency and comparability across organizations.
Task Force on Climate-related Financial Disclosures (TCFD)
The TCFD is an international framework for reporting climate-related risks and opportunities. It has played a key role in helping companies structure their approach to climate risk, scenario analysis, and strategic planning, and has influenced more recent frameworks such as ESRS.
The purpose is to improve transparency around how climate change affects organizations, enabling better decision-making for investors, stakeholders, and management.
Who should report?
TCFD has been widely adopted by companies globally and is particularly relevant for:
- Companies subject to CSRD and ESRS (which build on TCFD principles)
- Organizations exposed to climate-related risks
- Businesses responding to investor and market expectations
While not always a standalone legal requirement, TCFD is increasingly embedded in regulatory frameworks and best practice reporting.
What is being reported on?
TCFD is structured around four core pillars:
- Governance: Oversight and management of climate-related risks and opportunities
- Strategy: Actual and potential impacts on business, strategy, and financial planning
- Risk management: Processes for identifying, assessing, and managing climate risks
- Metrics and targets: Metrics used and targets set to manage climate-related risks and opportunities
The framework also introduces analysis of:
- Physical risks (e.g. extreme weather, floods, droughts)
- Transition risks (e.g. regulation, technology shifts, market changes)
How is this done?
TCFD is implemented by integrating climate considerations into existing governance, strategy, and risk management processes.
The process includes:
- Identifying climate-related risks and opportunities
- Assessing impacts on business and financial performance
- Conducting climate scenario analysis
Scenario analysis typically compares:
- A low-emission scenario aligned with the Paris Agreement
- A high-emission scenario with continued elevated emissions
This helps organizations understand how different future pathways may affect operations, strategy, and investments over time.
The results are disclosed in line with the four TCFD pillars and are increasingly aligned with frameworks such as ESRS and GRI, supporting consistent and comparable climate reporting.