SUSTAINABILITY · COMPLIANCE · REPORTING
ESG Frameworks
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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
The 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.
The Carbon Border Adjustment Mechanism (CBAM)
The purpose of the Carbon Border Adjustment Mechanism (CBAM) is to prevent carbon leakage and support the EU's climate objectives by ensuring that imported products are subject to a carbon cost equivalent to that faced by EU producers under the EU Emissions Trading System (EU ETS).
CBAM applies to certain goods imported into the EU and requires importers to report embedded greenhouse gas emissions associated with those products. The mechanism aims to encourage cleaner production globally while maintaining a level playing field between EU and non-EU producers.
Who needs to report?
The CBAM Regulation applies to companies importing certain carbon-intensive goods into the European Union.
During the transitional period, importers of the following goods are required to report:
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Cement
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Iron and steel
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Aluminium
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Fertilisers
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Electricity
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Hydrogen
In addition, certain downstream and processed products containing these materials may also be covered.
Importers must submit quarterly CBAM reports covering the emissions associated with imported products.
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What is being reported on?
Companies must report the embedded greenhouse gas emissions associated with imported CBAM goods.
The report should cover:
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Direct emissions generated during the production process
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Indirect emissions from electricity consumption (where required)
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Quantity of imported goods
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Production facility information
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Carbon price paid in the country of origin, if applicable
Reporting must be completed for each CBAM-covered import and submitted quarterly during the transitional phase.
How is this done?
Companies are required to collect emissions data from suppliers and manufacturers.
This includes:
- Identifying imported products that are subject to CBAM
- Gathering emissions data from production facilities
- Applying approved EU calculation methodologies
- Validating and documenting emissions information
- Submitting quarterly CBAM reports through the designated reporting system
Organizations should also establish supplier engagement and data governance processes to improve data quality and regulatory compliance.
The EU Deforestation Regulation (EUDR)
The EU Deforestation Regulation (EUDR) aims to reduce the European Union's contribution to global deforestation and forest degradation.
The regulation requires companies to ensure that certain products placed on, made available on, or exported from the EU market are deforestation-free and produced in compliance with applicable laws in the country of origin.
The regulation promotes responsible sourcing and increased transparency across global supply chains.
Who needs to report?
EUDR applies to operators and traders dealing with covered commodities and products within the EU market.
The regulation currently covers:
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Cattle
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Cocoa
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Coffee
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Palm oil
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Rubber
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Soy
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Wood
As well as many derived products made from these commodities.
Organizations placing covered products on the EU market must demonstrate compliance with EUDR requirements.
What is being reported on?
Companies must demonstrate that products are:
- Deforestation-free
- Produced legally in the country of origin
- Traceable to their source location
The due diligence information should include:
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Geolocation of production plots
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Country and supplier information
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Risk assessment results
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Risk mitigation measures
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Evidence supporting compliance
Due diligence statements must be submitted before products are placed on the EU market.
How is this done?
This includes:
- Mapping supply chains
- Collecting supplier and origin information
- Obtaining geolocation data
- Conducting deforestation risk assessments
- Implementing risk mitigation measures where required
- Submitting due diligence statements through the EU information system
Organizations should establish traceability and supplier engagement processes to support ongoing compliance.
The Digital Product Passport (DPP)
The Digital Product Passport (DPP) is a key element of the EU Ecodesign for Sustainable Products Regulation (ESPR).
It provides digital access to product-related information across the value chain, enabling greater transparency regarding sustainability, circularity, material composition, and product lifecycle impacts.
The DPP supports circular economy objectives by helping customers, regulators, recyclers, and supply chain partners access reliable product information.
Who needs to report?
DPP requirements will apply to manufacturers, importers, distributors, and other economic operators placing covered products on the EU market.
The exact requirements will vary by product category as implementing regulations are introduced.
Expected product groups include:
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Batteries
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Textiles
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Electronics
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Construction products
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Other high-impact product categories
Organizations responsible for placing covered products on the market must maintain and provide required product information.
What is being reported on?
The Digital Product Passport will contain product-specific sustainability information such as:
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Product identification information
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Material composition
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Substances of concern
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Carbon footprint information
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Repairability and durability data
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Recycled content
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End-of-life and recycling information
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Supply chain and sustainability attributes
The information available will vary according to product-specific regulations.
How is this done?
Companies will be required to maintain digital product information and make it accessible through a unique identifier such as a QR code or similar digital solution.
This includes:
- Collecting product lifecycle data
- Managing material and supplier information
- Maintaining traceability records
- Updating product information as required
- Making information digitally accessible to relevant stakeholders
Organizations should establish product data governance processes and digital systems capable of supporting future DPP requirements across the product lifecycle.
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.
GHG-accoutning is highly relevant input in a double materiality assessment (DMA) 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.
The Carbon Disclosure Project (CDP)
The Carbon Disclosure Project (CDP) is a globally recognized environmental disclosure framework that enables organizations to measure, manage, and disclose their environmental impacts.
CDP helps investors, customers, regulators, and other stakeholders assess how organizations manage climate change, water security, and deforestation-related risks and opportunities.
By participating in CDP, companies improve transparency, strengthen environmental governance, and demonstrate progress toward sustainability goals.
Who needs to report?
CDP reporting is voluntary but is increasingly requested by:
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Investors
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Customers and supply chain partners
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Banks and financial institutions
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Public sector organizations
Companies may receive direct requests from customers or investors to complete a CDP questionnaire as part of supplier assessments or ESG evaluations.
What is being reported on?
Companies disclose information related to environmental performance and management.
The report typically covers:
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Greenhouse gas (GHG) emissions
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Climate-related risks and opportunities
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Climate targets and transition plans
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Energy consumption and renewable energy use
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Water security impacts and management
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Deforestation-related risks and actions (where applicable)
Organizations receive a CDP score based on the completeness and quality of their disclosures.
How is this done?
This includes:
- Collecting environmental data across the organization
- Calculating greenhouse gas emissions
- Assessing climate-related risks and opportunities
- Defining targets and reduction initiatives
- Completing and submitting the annual CDP questionnaire
Organizations should establish robust data management processes to ensure consistency, accuracy, and year-on-year comparability. emissions information
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.
Science Based Targets initiative (SBTi)
The Science Based Targets initiative (SBTi) is a globally recognized framework that helps organizations set greenhouse gas reduction targets aligned with climate science and the goals of the Paris Agreement.
SBTi provides companies with a credible methodology for reducing emissions and supporting the transition to a low-carbon economy.
The framework enables organizations to establish ambitious climate targets and demonstrate climate leadership.
The framework is continuously evolving, and new requirements related to areas such as Scope 3 emissions, transition plans, and the management of residual emissions are currently being considered through the revised Net-Zero Standard.
Who should report?
SBTi is a voluntary framework that can be adopted by organizations of all sizes and sectors.
It is particularly relevant for:
- Companies with climate commitments
- Organizations reporting under CSRD, CDP, or IFRS
- Businesses seeking validated emissions reduction targets
- Companies responding to investor, customer, or lender expectations
Organizations committing to SBTi are required to develop and submit targets for validation.
What is being reported on?
Companies are expected to disclose their climate targets and progress toward achieving them.
Reporting typically includes:
- Scope 1 emissions
- Scope 2 emissions
- Scope 3 emissions (where applicable)
- Near-term emissions reduction targets
- Long-term net-zero targets
- Progress against established targets
- Emissions reduction initiatives and action plans
Targets must be based on scientific methodologies and comply with SBTi criteria.
How is this done?
Organizations must establish a greenhouse gas inventory and develop targets according to SBTi methodologies.
This includes:
- Measuring Scope 1, Scope 2, and Scope 3 emissions
- Defining a baseline year
- Calculating emissions reduction pathways and targets
- Submitting targets for SBTi validation
- Monitoring and reporting progress annually
Companies should integrate climate targets into strategy, investment decisions, governance, and operational planning to achieve meaningful emissions reductions over time.
The IFRS Sustainability Disclosure Standards
The IFRS Sustainability Disclosure Standards, developed by the International Sustainability Standards Board (ISSB), establish a global baseline for sustainability-related financial disclosures.
The standards help investors and other stakeholders understand how sustainability-related risks and opportunities affect an organization's financial performance, strategy, and long-term value creation.
The framework currently consists primarily of IFRS S1 (General Requirements for Sustainability-related Financial Disclosures) and IFRS S2 (Climate-related Disclosures).
Organizations use the standards to provide consistent, comparable, and decision-useful sustainability information alongside financial reporting.
Who should report?
IFRS Sustainability Disclosure Standards apply to organizations in jurisdictions that have adopted or incorporated the standards into regulatory requirements.
Reporting may be required for:
- Listed companies
- Large private companies
- Organizations subject to sustainability disclosure regulations
- Companies responding to investor expectations
What is being reported on?
Companies must disclose sustainability-related risks and opportunities that could reasonably affect their financial position, performance, prospects, or enterprise value.
The report should cover:
- Governance of sustainability-related risks and opportunities
- Strategy and business impacts
- Risk management processes
- Metrics and targets
- Climate-related risks and opportunities
- Greenhouse gas (GHG) emissions
- Climate transition plans and targets
Disclosures should focus on information that is material to investors and other providers of capital.
How is this done?
Organizations are required to identify, assess, monitor, and disclose sustainability-related risks and opportunities across their operations and value chains.
This includes:
- Identifying material sustainability-related risks and opportunities
- Assessing financial impacts on the business
- Establishing governance and oversight processes
- Collecting and managing sustainability data
- Measuring performance against targets and metrics
- Preparing disclosures aligned with IFRS S1 and IFRS S2
Companies should integrate sustainability reporting with existing financial reporting processes to ensure consistency, transparency, and auditability.