Constituent participation in the public consultation on EU CSRD: Who was the most active stakeholder?

Abstract

Purpose – Based on the rational choice model of lobbying, this paper examines the level of involvement of all major stakeholder groups in the development of the EU Corporate Sustainability Reporting Directive (CSRD) and their level of support (or opposition) through comment letters submitted on the public consultation of the Non-Financial Reporting Directive (NFRD). Design/methodology/approach – The analysis is based on the publicly available document containing stakeholders’ comments letters. Respondents to the consultation were grouped according to the variables reflecting their characteristics. A content analysis of the feedback provided by the respondents to the public consultation has been developed. The analysis focuses on the issues the respondents discussed and the level of agreement or disagreement with the questions posed by the consultation related to potential changes to the NFRD. Findings – The findings show significant differences between different respondents’ groups based on country, size, entity and type, regarding both how much they discussed the issues included in the consultation’s thematic sections and the support for changes to the NFRD. Practical implications – The study highlights how different stakeholder groups engage with regulatory formal consultations based on their proximity to regulation and organisational characteristics. These findings suggest that policymakers should design consultation processes and regulatory requirements with proportionality in mind, ensuring inclusive engagement across a diverse range of stakeholders. Social implications – The active involvement of stakeholders, such as users and non-business entities, in the sustainability reporting consultation underscores the societal relevance of sustainability disclosures. Broadening stakeholder engagement in formal public consultation processes can enhance the legitimacy and public accountability of EU sustainability policy. Originality/value – While lobbying behaviour through comment letters has long been investigated in financial accounting literature, relatively little research, to the best of the authors’ knowledge, addresses public consultation processes in the context of sustainability accounting and reporting.