Accounting in Europe

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Corporate Sustainability Reporting in Europe: A

Scoping Review

Tami Dinh, Anna Husmann & Gaia Melloni

To cite this article: Tami Dinh, Anna Husmann & Gaia Melloni (2023) Corporate
Sustainability Reporting in Europe: A Scoping Review, Accounting in Europe, 20:1, 1-29, DOI:
10.1080/17449480.2022.2149345

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Accounting in Europe, 2023
Vol. 20, No. 1, 1–29, https://doi.org/10.1080/17449480.2022.2149345

Corporate Sustainability Reporting in

Europe: A Scoping Review

TAMI DINH *, ANNA HUSMANN * and GAIA MELLONI **

*Institute of Accounting, Control and Auditing, University of St.Gallen, St.Gallen, Switzerland and **Department of
Accounting and Control, HEC University of Lausanne, Lausanne, Switzerland

ABSTRACT This paper provides a scoping review of European sustainability reporting studies.
Previous sustainability studies do not offer a comprehensive discussion of features key to the European
setting. Despite their important role in the European economy, research on small and medium-sized
enterprises (SMEs) and financial institutions (i.e. insurers and banks) is limited. Furthermore, regions in
southern and particularly eastern Europe, which are critical given regulators’ objectives for European
Union-wide and global sustainability standards, are neglected. Finally, studies on non-financial effects of
sustainability reporting are also limited, and only a few studies differentiate between stakeholder- and
shareholder-oriented countries. This is needed for a holistic view on sustainability beyond financial
performance. Based on material issues identified for the European context, our study provides a research
agenda based on comprehensive and rigorous scientific evidence on the state of the art of sustainability
research in Europe.

Keywords: CSR; ESG; European corporate reporting; scoping review; sustainability reporting

1. Introduction
To help make Europe the world’s first climate-neutral continent, in July 2021, the European
Union (EU) proposed a package of policy initiatives (European Commission, 2021a). The Euro-
pean Green Deal was first communicated in 2019 by the European Commission along with the
proposal to review Directive 2014/95/EU (the Non-Financial Reporting Directive, NFRD). The
NFRD was considered key for ensuring sustainable investments (European Parliament, 2021).
This is consistent with the United Nations’ (UN) explicit call for firms’ transparency on their
sustainability performance via reporting (United Nations, 2015). Hence, in April 2021, the Euro-
pean Commission published a proposal for the Corporate Sustainability Reporting Directive
(CSRD) that shall amend the NFRD to ensure more transparency on corporate sustainability.
In June 2022, the European Council and Parliament reached a provisional political agreement
on the CSRD, which was adopted on 10th November 2022 by the European Parliament (Euro-
pean Council, 2022c; European Parliament, 2022). In general, Europe aims to be a ‘frontrunner
[…] in climate friendly industries, in clean technologies [and] in green financing’ (Von der

*
Correspondence Address: Tami Dinh, Institute of Accounting, Control and Auditing, University of St.Gallen, ACA-
HSG, Office 57-104, Tigerbergstrasse 9, 9000 St.Gallen, Switzerland. E-mail: [email protected]
Paper accepted by Francesco Mazzi.
Supplemental data including Appendix 1–6 for this article can be accessed http://doi.org/10.1080/17449480.2022.2149345.
This article has been republished with minor changes. These changes do not impact the academic content of the article.

© 2022 European Accounting Association

2 T. Dinh et al.

Leyen, 2019). Compared to other regions, Europe has achieved more substantial changes in sus-
tainability regulations and performances in recent years (Von der Leyen, 2019). Furthermore, in
2021, parts of the EU Sustainable Finance Action Plan became effective for building a ‘sustain-
able finance ecosystem’ (European Commission, 2021a).
Against the background of these large EU sustainability initiatives, our scoping review exam-
ines existing interdisciplinary literature on sustainability reporting in Europe. We use the term
‘corporate sustainability reporting’ or ‘sustainability reporting’ in line with the new CSRD.
As stated by Byrch et al. (2015), there is no universal definition of ‘sustainability’ and no
common understanding of how it can be achieved. This is also the case for the alternative
term ‘corporate social responsibility’ (CSR) (Hinze & Sump, 2019). Initially, CSR comprised
social topics, whereas sustainability comprised environmental topics. Currently, the two terms
are mostly used interchangeably (Van Marrewijk, 2003).1 Simnett and Huggins (2015) argue
that, owing to the rising demand, firms engage in sustainability reporting to provide insights
into their non-financial (i.e. environmental and social) activities and performance.
Our understanding of sustainability reporting in this study is consistent with the term ‘corpor-
ate sustainability reporting’ used by the Association of Certified Chartered Accountants
(ACCA). It is the communication of information ‘relevant for understanding a company’s
long-term economic value and contribution towards a sustainable global economy, taking
account of the company’s economic, environmental, social and governance performance and
impacts’ (ACCA, 2016). More recently, the term Environmental, Social and Governance
(ESG) reporting has come into use. Large asset managers have begun demanding ESG infor-
mation and metrics that are comparable and concise for their investment decisions.2
In our scoping review, we treat the terms sustainability, CSR, non-financial and ESG inter-
changeably unless there is a specific focal point such as the analysis of the different parts of
E-S-G. We focus on studies published between 2015 and June 2021 because 2015 marks a criti-
cal milestone in the international sustainability debate with the adoption of the Sustainable
Development Goals (SDGs) by all members of the United Nations and the Paris Agreement
to limit global warming to well below 2° Celsius and pursuing efforts to limit it to 1.5°
Celsius. We classify the studies reviewed according to the publication outlet, research focus,
underlying theory, research method and data collection, sample selection and regulatory
framework.
In our main analysis, we identify three distinct features highly relevant for the European
setting: the economic system, regulatory environment and role of the company in society. We
show that the literature on sustainability reporting overlooks several highly relevant aspects
for the European context. First, little evidence is available on the role of financial institutions,
including banks and insurers, which play a key regulatory role in the raising and allocation of
capital, especially in bank-based European economies (European Commission, 2021b). Further-
more, there is limited research on small and medium-sized enterprises (SMEs), which form the
backbone of the European economy, and whose exclusion from the CSRD was heavily debated
(European Commission, 2021c; European Council, 2022a; European Fund and Asset Manage-
ment Association, 2022). Additionally, there is scope for research on the social and governance
dimensions and the need to better differentiate between stakeholder- and shareholder-oriented
countries. Most studies analysing the sustainability reporting of European firms focus on its
link to financial performance but insights on sustainability performance are scarce. This
ignores the needs of the broad and diverse stakeholder groups that play an important role, par-
ticularly in continental Europe (Ayuso et al., 2014).
Overall, academic studies on sustainability reporting in Europe show a country selection bias,
and mainly focus on the UK, Germany, France and Italy. This is an issue given the increasing
global developments in the regulatory landscape of sustainability reporting that will affect
 Accounting in Europe 3

more countries than those typically analysed in scientific studies. More evidence on less inves-
tigated regions such as eastern Europe is necessary for a full picture of the region (cf. Albu et al.,
2017).
Based on these novel findings, we contribute to the literature on sustainability reporting by
offering a research agenda for future studies on sustainability reporting in Europe. Our time
period of 2015–2021 covers the years when sustainability reporting started becoming a main-
stream research area. As such, our analysis of European sustainability reporting studies forms
an important starting point for future research in this field. Our findings are expected to be
helpful to identify new research questions, to consider innovative data as well as to explore
alternative research methods.
Furthermore, we contribute to previous sustainability reporting literature reviews. The focused
approach of using a scoping review allows us providing a literature review that particularly
fleshes out the existing European evidence. While Christensen et al.’s (2019) review primarily
speaks to a potential mandate for sustainability reporting in the U.S., findings of our study
should particularly stimulate and inform the regulatory debate in Europe. Academic studies
often form the information base for new regulations (see Christensen et al., 2019 for the Secu-
rities and Exchange Commission on a potential global mandate on sustainability reporting; Dinh
et al., 2021 for the European Parliament on the CSRD; Filip et al., 2017 for discussions at the
International Accounting Standards Board’s public January 2018 meeting on IFRS 13 Fair
Value Measurement; Michelon et al., 2020 for the Financial Reporting Council on corporate
reporting). Our insights will be useful for standard setters, regulators and policymakers.
The scoping review is structured as follows: we first discuss the European setting regarding
sustainability disclosure and performance (Section 2). We then present our methodological
approach (Section 3), the results of the scoping review (Section 4) and its discussion considering
selected features of the European setting (Section 5). Finally, we propose a research agenda
(Section 6).

2. The European Setting for Sustainability

2.1. Sustainability Regulations
For EU countries, the EU legislative level adds to existing national and regional regulations,
including those for sustainability reporting. Non-EU European countries, however, use the EU
legislation for reference when defining national disclosure requirements (e.g. KPMG, 2021).
Hence, in this study, we refer to the entire European region as the European setting unless
when explicitly related to EU Directives such as the NFRD or CSRD.
Institutional investors such as BlackRock and organisations such as the International Organ-
ization of Securities Commissions increasingly demand standardised sustainability information
(International Organization of Securities Commissions, 2021; Jessop & Ross, 2020). However,
managers have high discretion in the frameworks followed, the quality of information reported,
and assurance obtained. This results in a globally scattered sustainability disclosure landscape
even when such disclosures are mandated.3 Companies regularly rely on global guidelines
such as the Global Reporting Initiative (GRI). In 2020, several steps were made towards globally
unifying sustainability reporting.4 Furthermore, third parties such as rating agencies attempt to
provide standardised sustainability information (e.g. Bloomberg, 2021).
To date, in the U.S., sustainability reporting primarily relies on voluntary regimes, with share-
holder pressure pushing companies to disclose such information (Harper Ho, 2019, 2020). In
contrast, as reported in Figure 1, at the EU level, mandatory sustainability regulations and regu-
latory standardisation are already in place:
4 T. Dinh et al.

Figure 1. Key global and European sustainability initiatives.

Note: Figure 1 presents an overview of the key global and European sustainability initiatives which were
initiated, adopted and/or came into force over the period 2015–2021. The abbreviations relate to the
following initiatives and regulations:
(i) Global:
- ‘SDG’: ‘The 2030 Agenda for Sustainable Development’ (‘17 SDGs’) adopted by the UN;
- ‘Paris Agreement’: legally binding agreement adopted by 196 countries;
(ii) European - financial and non-financial companies:
- ‘Directive 2014/95/EU’: ‘Directive 2014/95/EU amending Directive 2013/34/EU as regards disclosure of
non-financial and diversity information by certain large undertakings and groups (32014L0095)’ (NFRD)
by the European Parliament;
- ‘Directive (EU) 2017/828’: ‘Directive 2017/828 amending Directive 2007/36/EC as regards the encour-
agement of long-term shareholder engagement’ (Shareholder Rights Directive II (SRD II)) by the European
Parliament;
- ‘Guideline 2017/C 215/01’: ‘Guidelines on non-financial reporting (methodology for reporting non-finan-
cial information)’ by the European Commission;
- ‘Guideline 2019/C 209/01’: ‘Guidelines on non-financial reporting: Supplement on reporting climate-
related information’ by the European Commission;
- ‘Regulation (EU) 2020/852’: ‘Regulation (EU) 2020/852 on the establishment of a framework to facilitate
sustainable investment, and amending Regulation (EU) 2019/2088’ (Taxonomy Regulation, part of the EU
Sustainable Finance Action Plan) by the European Parliament;
- ‘Proposal: Directive COM/2021/189’: ‘Proposal for a Directive amending Directive 2013/34/EU, Direc-
tive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustain-
ability reporting’ (CSRD) by the European Parliament;
(iii) European - financial companies:
- ‘Regulation 2019/2088’: ‘Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial
services sector (32019R2088)’ (SFDR), part of the EU Sustainable Finance Action Plan) by the European
Parliament.

. Mandatory regulations: Since 2018, Directive 2014/95/EU (the NFRD) requires large EU
public-interest companies with more than 500 employees to disclose environmental and
social information. When effective, the Directive COM/2021/189 (the CSRD) amending
the former NFRD will greatly increase the scope of companies subject to the mandate
and provide more guidance on the information to disclose.5 Furthermore, it will require
a third-party audit or certification of reported information and the publication of
XHTML financial statements and management reports.
. Regulatory standardisation: Since 2021, Regulation 2019/2088 (the Sustainable Finance
Disclosure Regulation, SFDR) requires financial market participants and financial advisors
in the EU to apply a binding transparency framework based on entity- and product-level
 Accounting in Europe 5

information requirements. The aim is to achieve harmonisation on defining sustainable

investment products. Furthermore, Regulation 2020/852 (the Taxonomy Regulation)
establishes a green taxonomy, that is, a classification scheme to identify environmentally
sustainable investments.

2.2. Sustainability Performance

Compared to other regions in the world, Europe and especially the (pre-Brexit) EU-28 countries
show higher sustainability performance: as Table 1 Panel A indicates, in 2018, the CO2 intensity
of the gross domestic product (GDP) in Europe was considerably lower than that in the U.S.,
China, South Africa and the rest of the world. Furthermore, Europe and the (pre-Brexit) EU-

Table 1. Sustainability indicators

Panel A: CO2 intensity of GDP (CO2 emissions per unit of GDP)
2000 2018 Change
World 0.29 0.22 −24%
Europe 0.34 0.19 −44%
pre-Brexit EU - 28 0.28 0.16 −43%
Top 4 by GDP 0.21 0.13 −38%
China 0.69 0.44 −36%
South Africa 0.63 0.60 −5%
U.S. 0.42 0.25 −40%
Rest of the World 0.27 0.23 −15%
Panel B: SGD - Goal achievement tracker
Average SDG index rating 2019 2021 Change
World 68 71 -
Europe 26 23 +
pre-Brexit EU - 28 21 19 +
Top 4 by GDP 13 14 -
China 39 57 -
South Africa 113 107 +
U.S. 35 32 +
Rest of the World 81 85 -
Average SDG index score 2019 2021 Change
World 55 57 +
Europe 69 71 +
pre-Brexit EU - 28 78 80 +
Top 4 by GDP 79 81 +
China 73 72 -
South Africa 61 64 +
U.S. 75 76 +
Rest of the World 51 53 +
Note: Table 1 displays sustainability indicators of different regions. Panel A shows the CO2 intensity of GDP by region in
2000, in 2018 and the percentage change. The data relates to 138 countries in the category World and 39 countries in the
category Europe (Andorra, Holy See, Liechtenstein, Monaco and San Marino are excluded). The data for Montenegro is
based on 2005 and 2018, that for South Sudan on 2012 and 2018 (OECD. Stat., 2021). Panel B provides two measures of
SDG achievement: the SDG index rating ranks countries based on their SDG index score (‘1’ best; ‘193’worst); the SDG
index score measures the total progress of a country towards the achievement of the 17 SDGs (‘100’ best; ‘0’ worst). The
category World comprises 193 countries and Europe 43 countries (excl. Holy See) (Sachs et al., 2019, 2021).
6 T. Dinh et al.

28 reduced the CO2 intensity of GDP since 2000.6 According to the SDG index rating (which
ranks countries based on their SDG index score7, with a lower rating indicating higher perform-
ance), Europe considerably outperformed the U.S., China, South Africa and the rest of the world
in both 2019 and 2021 (Table 1 Panel B based on Sachs et al., 2019 and 2021). This is mainly
driven by the Top 4 European countries by GDP (Germany, UK, France and Italy). Hence, sus-
tainability reporting is part of a large global debate but the density of its regulations is particu-
larly pronounced in Europe or the EU.

3. Methodology
This scoping review focuses on a specific ‘topic area’ (Pham et al., 2014), that is, sustainability
reporting in the European setting. Scoping reviews ‘aim to map the literature on a particular
topic or research area and provide an opportunity to identify key concepts; gaps in the research;
and types and sources of evidence to inform practice, policymaking, and research’ (Daudt et al.,
2013, p. 8). We therefore refrain from including governmental, institutional and corporate pub-
lications. Furthermore, we only analyse academic studies with a specific European focus pub-
lished in top-ranked accounting, finance and management academic journals. In addition, our
period starts in 2015, the year of the Paris agreement and the adoption of the SDGs by UN
countries, which are two events that mark important milestones in the international sustainability
debate (United Nations, 2015). Our scoping review is a standalone project rather than the base for
a systematic review (Arksey & O’Malley, 2005).
We aim to inform academics and practice on how the peculiarities of the European setting
have been addressed to date. The exclusion of studies published before 2015, in other journals
or with a different setting represents a limitation of our analysis as important scientific ground-
work may not be included. However, we are interested in this recent period and scope to capture
when sustainability began evolving from a niche to mainstream research area. We also include
non-EU countries to have a complete picture of the European setting.8
We started our analysis with the 45 journals that comprise all top accounting journals rated 3
or higher and all top management and finance journals rated 4 or higher by the Chartered Associ-
ation of Business Schools (2018). We decided on different minimum rankings as the focus of our
scoping review is accounting. However, during the screening process, we identified only a few
studies analysing the internal perspective, which is a key dimension of our analysis. We also
lowered the threshold for management journals, thereby adding 12 journals. This allows a
more comprehensive overview of the findings related to the internal perspective. We narrowed
down the articles using 35 targeted keywords (in line with e.g. Michelon et al., 2022; Appendix
2), and then carefully screened the abstracts to assess suitability for our analysis. Furthermore,
we excluded articles focusing on governments, the third sector or assurance companies. The
final analysis included 57 studies from 14 journals from 2015–2021 that we discuss along the
following dimensions (e.g. Dinh et al., 2021)9:

. The general publication features (i.e. journal and publication year);

. The research focus including
o Perspective (internal i.e. managerial decision-making vs external i.e. transparency);
o Effect (economic vs non-economic) and distinct E-S-G information (environmental vs
social vs governance);
o Type of information (qualitative vs quantitative; content vs style);
. The underlying theory (theory building vs testing and individual vs combined)
. The research method (empirical vs descriptive or qualitative) and data collection (desk-
based vs field or lab work approach);
 Accounting in Europe 7

. The sample selection including business model (financial vs non-financial), firm listing
status (listed vs non-listed companies) and jurisdiction (specific vs multiple European
countries vs others);
. The regulation of sustainability disclosures in terms of requirement (mandatory vs
voluntary) and framework or guideline (specific vs multiple international vs national vs
others).

4. Main Findings of the Scoping Review

4.1. Publication Features: Journal and Year of Publication
As Table 2 shows, the 57 studies reviewed were primarily published in the following journals:
the Accounting, Auditing and Accountability Journal (22%), the Journal of Business Ethics
(17%) and the European Accounting Review (10%).
Although the length of the writing and review process greatly influences a study’s
publication date, the years of publications coincide with the launch of major global sustainability
initiatives:

. 2015: the adoption of the UNs’ 2030 Agenda for Sustainable Development (‘17 SDGs’) as
well as the ‘well below 2° Celsius’ Paris Agreement;
. 2017: the publication of Directive (EU) 2017/828 and Guideline 2017/C 215/01;
. 2018: the effective date of the EU Directive 2014/95/EU (the NFRD);

The publication trend reached a peak after the enforcement of the NFRD, with the majority of
studies (26%) published in 2018 (Figure 2). In other years between 2015 and 2021, the number of
published studies was rather stable with seven studies per year on average. Another important
event was the 2020 speech by the UN general secretary António Guterres on the issues
exposed by the coronavirus disease 2019 pandemic, focused on the need for a more sustainable
system as well as attempts towards unifying corporate sustainability reporting.

Table 2. Count of studies reviewed – Journal

Classification of 57 studies
Accounting Account. Bus. Res. 3 5% Br. Tax Rev. 1 2%
Account. Forum 4 7% Crit. Perspect. Account. 4 7%
Account. Audit. Account. 13 *22% Eur. Account. Rev. 6 *10%
Account. Organ. Soc. 2 4% J. Account. Public Policy 2 4%
Br. Account. Rev. 5 9% J. Account. Res. 1 2%
Finance J. Corp. Finance 1 2%
Management Bus. Soc. 1 2% J. Bus. Res. 4 7%
J. Bus. Ethics 10 *17%
Total 57 100%
Note: Table 2 presents the number of studies published by journal from 2015–2021 (cut-off June 2021). The journal
names are abbreviated according to the ISO 4 standard. Accounting journals: ‘Account. Bus. Res.’: Accounting and
Business Research; ‘Account. Forum’: Accounting Forum; ‘Account. Audit. Account.’: Accounting, Auditing and
Accountability Journal; ‘Account. Organ. Soc.’: Accounting, Organizations and Society; ‘Br. Account. Rev.’: British
Accounting Review; ‘Br. Tax Rev.’: British Tax Review; ‘Crit. Perspect. Account.’: Critical Perspectives on
Accounting; ‘Eur. Account. Rev.’: European Accounting Review; ‘J. Account. Public Policy’: Journal of Accounting
and Public Policy; ‘J. Account. Res.’: Journal of Accounting Research; Finance journals: ‘J. Corp. Finance’: Journal
of Corporate Finance; Management journals: ‘Bus. Soc.’: Business and Society; ‘J. Bus. Ethics’: Journal of Business
Ethics; ‘J. Bus. Res.’: Journal of Business Research. The percentages are provided to indicate the proportion.
*Rounding errors for numbers are marked with an asterisk to result in 100% in total.
8 T. Dinh et al.

Figure 2. Count of studies reviewed – Year of publication.

Note: Figure 2 presents the number of studies analysed in this study per year of publication from 2015–
2021. The publication year 2021 is not complete (cut-off in June 2021).

4.2. Research Focus

4.2.1. Perspective: Internal vs External
Table 3 provides an overview of the studies reviewed classified along four dimensions: perspec-
tive (external vs internal), economic vs non-economic effects, distinct E-S-G information
(environmental vs social vs governance) and information type (quantitative vs qualitative,
content vs style).
Sustainability reporting provides decision-making information to external users and can also
change the internal behaviour of preparers. To date, most studies relate to the external perspec-
tive: of the 57 studies reviewed, only 15 focus on the internal perspective analysing among others
(i) the links between sustainability information and financial or sustainability performance (e.g.
Broadstock et al., 2018; Laine et al., 2017; Passetti et al., 2018) and (ii) the corporate factors that
drive internal improvements of sustainability performance and strategic developments (e.g. Al-
Shaer & Zaman, 2019; Halme et al., 2020; Lisi, 2018; O’Sullivan & O’Dwyer, 2015).
Further, Gonçalves et al. (2020) analyse the relevance of various company characteristics includ-
ing group affiliation for sustainability reporting. Finally, based on an IIRC pilot company, Gibas-
sier et al. (2018) analyse the internal process of introducing integrated reporting.
The 33 studies on the external perspective primarily examine the link between sustainability
disclosures and market valuation (e.g. Baboukardos, 2017; Clarkson et al., 2015; De Villiers &
Marques, 2016; Li et al., 2018; Nekhili et al., 2017), risk (e.g. Benlemlih et al., 2018), cost of
debt (e.g. Eliwa et al., 2021), and analyst following (e.g. Bernardi & Stark, 2018). Furthermore,
studies analyse stakeholder ownership and pressure that potentially drive sustainability disclos-
ures (e.g. Campopiano & De Massis, 2015; Liesen et al., 2015). Other studies focus on disclosure
strategies and styles (e.g. Borgstedt et al., 2019; Chauvey et al., 2015; Chelli et al., 2018; Fergu-
son et al., 2016; Pesci et al., 2015; Table 3 Panel A).
There are several reasons for the strong focus on the external perspective: first, data are
typically more easily publicly available. Second, the focus of reporting initiatives is mainly
on the external perspective (i.e. the quality of information externally disclosed) (cf. Section
2.1). Third, the activities and programmes undertaken may depend on whether they help
bolster legitimacy by external stakeholders (cf. Brammer et al., 2012). Overall, we observe
a research gap on how sustainability reporting in Europe may shape firms’ internal processes
and decisions.
 Accounting in Europe 9

Table 3. Count of studies reviewed – Research focus

Classification of 57 studies
Panel A: By perspective
External 33 58% Internal 15 26%
Both 9 16%

Total 57 100%
Panel B: By effect
Economic 27 47% Non-economic 30 53%
Total 57 100%
Panel C: By distinct E-S-G information
Environmental 15 52% Social 4 14%
Governance 2 7% Environmental and social 9 *27%
30
Focus of studies not distinguishing between E-S-G

‘CSR’ in general 12 44% ‘Integrated’ in general 6 22%

‘ESG’ in general 4 15% Other 5 19%
27
Total 57 100%
Panel D: By information type
Content (qualitative) 22 45% Style 2 4%
Content (quantitative) 16 33% Content (qual.) and style 2 4%
Content (qual. and quant.) 7 14%
49
Focus of studies not analysing content or style or disclosures

Assurance report 1 13% Integrated or sustainability report 6 *74%

Other 1 13%
8
Total 57 100%
Note: Table 3 shows a classification of the studies reviewed along four dimensions: Panel A: perspective (external vs
internal), Panel B: effect (economic vs non-economic), Panel C: sustainability dimension and Panel D: information
type. The internal perspective includes studies primarily focused on (i) management processes and decision-making
within and/or (ii) action, strategy, or performance of a company. The external perspective includes studies primarily
focused on (i) stakeholders’ reaction to/perception of actions, performance or disclosures of a company or the
relevance of information and/or (ii) (disclosure) strategies chosen by companies. Both is selected, when the internal
and external perspective are both analysed, or the classification is not possible. The percentages are provided to
indicate the proportion. *Rounding errors for numbers are marked with an asterisk to result in 100% in total.

4.2.2. Effect (Economic vs Non-Economic) and Distinct E-S-G Information (Environmental vs

Social vs Governance)
Most studies reviewed focus on the economic effect including financial performance and market
reaction (47%, Table 3 Panel B). Approximately half of the studies reviewed neither distinguish
between the three distinct types of E-S-G information nor explicitly analyse them. Instead, they
focus on broader concepts, namely, CSR (44%), ESG (15%), Integrated (22%) or others (19%).
Studies that analyse distinct E-S-G information mostly focus on the environmental perspective
(52%), followed by the social (14%) and governance perspectives (7%, Table 3 Panel C). In fact,
in earlier studies, the term sustainability was often used to refer to only environmental topics
10 T. Dinh et al.

rather than including social and governance issues. Over time, that distinction between sustain-
ability and responsibility studies was blurred (Bansal & Song, 2017). Furthermore, the focus on
social topics is stronger than that on governance topics. This is likely due to governance repre-
senting a literature stream by itself since the corporate scandals around the millennium (for
reviews see Brown et al., 2011; Bushman & Smith, 2001). Studies analysing the information
in sustainability reporting more distinctly – that is, with a separate and more detailed focus on
the E-S-G perspectives – are limited.

4.2.3. Information Type: Qualitative vs Quantitative and Content vs Style

Most European sustainability studies analysed focus on the qualitative content, that is, the narratives
disclosed (45%). Some combine this with analyses of the quantitative content, that is, the numbers
disclosed (14%) or style features of the report (e.g. space of sustainability disclosures in Chauvey
et al., 2015) (4%). One-third of the studies solely analyses quantitative content and only a small
number of studies specifically analyses style elements (e.g. the number of sentences in Islam
et al., 2018 or the use of narrative and visual repetitions in Pesci et al., 2015) (Table 3 Panel D).
This is likely due to the low comparability of quantitative disclosures to date with missing standard-
isation for most sustainability information except for greenhouse gas emissions. Compared to most
other quantitative sustainability disclosures, greenhouse gas disclosures are (i) monetisable given the
existence of emission trading schemes (e.g. the EU Carbon Emissions Trading Scheme) and (ii) ver-
ifiable given the existence of external scoring providers (e.g. the CDP). This is also reflected in the
relatively high portion of studies (11%, not tabulated) analysing that type of disclosure.

4.3. Underlying Theory

Only a few studies contribute to the literature by theory-building (e.g. Antonini et al., 2020; Halme
et al., 2020; Siano et al., 2017). Instead, most studies reviewed focus on testing one or more theories
(Table 4). Theories that most often form the base of the study (either individually or in combination
with others) are legitimacy theory (23%), stakeholder theory (16%) and agency theory (12%).
Combining theories allows for developing hypotheses from different perspectives; for
example based on the voluntary disclosure theory, providing sustainability information may
be informative by decreasing information asymmetries, but based on the legitimacy theory, it
may result in greenwashing (e.g. Hummel & Schlick, 2016). Studies combining stakeholder
and legitimacy theories focus primarily on communication strategies, analysing voluntary cor-
porate disclosures such as ecological targets and GHG emissions reported (e.g. Borgstedt

Table 4. Count of studies reviewed – Theoretical framing

Classification of 57 studies
Theoretical base
Single theory 23 40% Combination of theories 29 51%
No specific theory 5 9%
Total 57 100%
Theory employed (individually or in combination)
Agency theory 7 12% Proprietary cost theory 2 4%
Impression management theory 3 5% Voluntary disclosure theory 2 4%
Institutional theory 5 9% Resource-based view 3 5%
Legitimacy theory 13 23% Stakeholder theory 9 16%
Network theory 2 4%
Note: Table 4 shows the theoretical framing employed individually or in combination with others in the studies reviewed.
 Accounting in Europe 11

et al., 2019; Liesen et al., 2015; Moussa et al., 2021). Other studies focus on the role of the CEO,
the ownership structure or the firm risk by combining stakeholder and agency theories (e.g. Al-
Shaer & Zaman, 2019; Benlemlih et al., 2018; Li et al., 2018; Nekhili et al., 2017).

4.4. Research Method and Data Collection

In 2015, the first year of our analysis, Byrch et al. (2015) state that most sustainability studies are
normative and conceptual, and only a few studies follow an empirical approach investigating the
actual content of reports. This is no longer the case for our scoping review, possibly owing to the
restriction parameters on studies of more recent years and in top-ranked journals. Consistent with
empirical studies dominating accounting literature to date (Bloomfield et al., 2016), the European
sustainability studies reviewed are also primarily empirical (86%, Table 5 Panel A).
Panel B of Table 5 shows that none of the studies reviewed uses a conceptual approach. In fact,
67% of the studies are based on a desk-based method with data sources coming from original docu-
mentation, databases or a combination of those. Thirty of the studies using original documentation as
a data source analyse different types of reports published by the company itself. These include (not
tabulated) primarily sustainability reports (44%), annual reports (35%) and corporate websites (14%).
Only a few studies analyse integrated reports (5%) or internal documents (3%). Finally, only three
studies consider company-independent newspaper articles (e.g. Antonini et al., 2020; Laine et al.,
2017; Siano et al., 2017). Future research should focus more on such alternative data sources.
Furthermore, 78% (not tabulated) of all archival studies reviewed employ a content analysis
approach. However, most do so with a primarily manual selection approach, that is, the research-
ers screen the documents or other input material and code it according to pre-defined rules. In
contrast, only two studies employ an automated textual analysis-approach (Mittelbach-Hörman-
seder et al., 2021; Siano et al., 2017; Appendix 3).10 Compared to such automated analyses,

Table 5. Count of studies reviewed – Research method and data collection

Classification of 57 studies
Panel A: By research method
Empirical 49 86% Descriptive/qualitative 8 14%
Total 57 100%
Panel B: By data collection method
Desk-based 38 67% Field and lab work 9 16%
Both 10 *17%
Total 57 100%
Desk-based method used (only)
Conceptual 0 0% Data source: database 10 26%
Data source: original documents 11 29% Multiple 17 45%
Total 38 100%
Field and lab work method used (only)
Field experiment 0 0% Questionnaire/interview 6 67%
Lab experiment 3 33% Multiple 0 0%
Total 9 100%
Note: Table 5 presents an overview of the number of studies (primarily) employing either an empirical or a descriptive/
qualitative research method. Empirical includes the analysis of large datasets using statistical analyses. Descriptive/
qualitative includes all others e.g. the analysis of smaller datasets based on e.g. systematic and in-depth analysis
approaches aiming at providing exploratory insights rather than statistically significant evidence. The percentages are
provided to indicate the proportion. *Rounding errors for numbers are marked with an asterisk to result in 100% in total.
12 T. Dinh et al.

manual content analyses are said to enable better analysis of complex narratives given that
human annotators can consider meaning and context when interpreting. However, the manual
approach may suffer from potential subjectivity, limited traceability and the inability to detect
latent features in large datasets. In addition, as data and reports in general are becoming more
easily available, textual analysis and natural language processing can be used to analyse large
amounts of information (e.g. Loughran & McDonald, 2016).
Studies that collect data via field and lab work do so via questionnaires or interviews (67%)
and lab experiments (33%). Studies which rely on questionnaires or interviews focus on the
internal perspective (81%), such as e.g. Arevalo and Aravind (2017).11 In contrast, all exper-
imental studies analyse research questions focusing on the external perspective, specifically
the equity market view (e.g. Crifo et al., 2015; Jahn & Brühl, 2019). This is consistent with
the challenge of assuming homogeneity across participants when focusing on the internal
view. No study reviewed uses a field experiment for data collection, likely given the resources
needed and the challenges to limit such interventions. We encourage future studies to adopt a
field experiment for data collection to offer strong causal attribution.

4.5. Sample Selection

4.5.1. Business Model: Financial vs Non-Financial
As stated by Hummel et al. (2021), financial institutions are ‘central for the steering of the global
economy towards sustainability’ (p. 21). The EU Guideline 2017/C 215/01 highlights the importance
of banks’ investments in sustainability. Approximately half of the banks consider a net zero carbon
business strategy themselves (Carbon Disclosure Project, 2020). Panel A of Table 6 shows that 56%
of the studies focus on samples including both financial and non-financial institutions. Among those
studies screened only six focus on banks or insurance providers with only three solely analysing
financial institutions (Hummel et al., 2021; Lai et al., 2018; Pesci et al., 2015, see Appendix 4, cf.
Section 5.1.2). This is remarkable given that politicians increasingly consider the financial sector
to have a key role in moving towards a greener future (European Commission, 2021d).

4.5.2. Listing Status: Listed vs Non-Listed

To date, mandatory regulations like the NFRD and the supplementing non-binding guidelines
require only large public-interest companies to provide sustainability disclosures. While data
on sustainability is publicly available for listed companies, little is known about the sustainability
reporting of non-listed companies. Most studies focus on listed companies (72%, Table 6 Panel
B). Although the proposed CSRD will also become relevant for many non-listed companies, no
study to date has investigated the role and consequences of sustainability disclosures solely for
those types of firms.

4.5.3. Jurisdiction: Single vs Multiple European Countries vs Other Settings

Our analysis is restricted to the European setting. However, strong differences are still observed
in the geographical focus. As shown in Panel C of Table 6, 25% of the studies use a sample with
companies from the UK, 12% from France, 11% from Italy and 7% from Germany. The focus on
these four countries may be explained by the economic relevance of the countries with the Top 3
EU member states Germany, France and Italy making up more than 50% of the EU-27 GDP in
2020 (Eurostat, 2022). UK’s GDP has historically been comparable to that of France. The other
samples consist of companies from Finland, the Netherlands, Portugal and Spain, likely due to
the authors’ nationalities.
The rest of the studies analyse multiple European countries (21%) or compare one or more
European countries to a non-European country (11%). In those studies, which disclose the
 Accounting in Europe 13

Table 6. Count of studies reviewed – Sample composition

Classification of 57 studies
Panel A: By business model
Financial 3 *7% Non-financial 21 37%
Both 32 56%
Total 57 100%
Panel B: By listing
Listed 41 72% Non-listed 0 0%
Both 16 28%
Total 57 100%
Panel C: By jurisdiction
Finland 2 *3% Portugal 1 2%
France 7 12% Spain 3 5%
Germany 4 7% UK 14 25%
Italy 6 11% Multiple (EU only) 12 21%
Netherlands 2 *3% Multiple (EU and non-EU) 6 11%
Total 57 100%
Multi-country comparison (Incl. EU and non-EU countries) for studies disclosing the information
EU-27
Austria 8 4% Italy 13 7%
Belgium 10 5% Latvia 2 1%
Bulgaria 1 *0.5% Lithuania 2 1%
Croatia 2 1% Luxembourg 5 3%
Cyprus 1 *0.5% Malta 1 *0.5%
Czechia 4 2% Netherlands 9 5%
Denmark 9 5% Poland 5 3%
Estonia 1 *0.5% Portugal 7 4%
Finland 9 5% Romania 3 2%
France 13 7% Slovakia 1 *0.5%
Germany 13 7% Slovenia 3 2%
Greece 6 3% Spain 10 5%
Hungary 4 2% Sweden 9 5%
Ireland 6 3%

prior EU-28
UK 14 8%

Other European countries

Liechtenstein 2 1% Russia 1 *0.5%
Norway 6 3% Switzerland 6 3%
Non-European countries
Australia 2 18% South Africa 2 18%
Canada 2 18% Turkey 2 18%
Iceland 1 *10% U.S. 2 18%
Note: Table 6 shows the sample selection i.e. the business model (Panel A), listing status (Panel B) and jurisdiction
(Panel C) in the studies reviewed. Financial companies include insurers and banks. By listing - Both is selected,
when the sample consists of listed and non-listed companies or the classification is not possible. The percentages are
provided to indicate the proportion. *Rounding errors for numbers are marked with an asterisk to result in 100% in total.

geographic features of their sample, there is a strong focus on EU-27 countries (plus the UK).
Furthermore, the studies reviewed appear to focus on western (35%) and northern (32%) Euro-
pean countries rather than on southern (24%) and eastern (9%) European countries. More
14 T. Dinh et al.

evidence on sustainability reporting in these regions is needed, given standard setters’ work
towards a common (European or global) sustainability accounting language (e.g. European
Financial Reporting Advisory Group, 2021; IFRS Foundation, 2022).

4.6. Disclosure Requirement: Mandatory vs Voluntary

Most studies focus on a voluntary setting (70%, Table 7 Panel A), given the lack of mandatory set-
tings to date (15% focus on national regulations, 12% on supranational regulations and 3% on the
CDP). Panel B of Table 7 shows that the standards by the GRI (39%) are most often investigated
followed by the IIRC framework (12%). With the longer history of the GRI going back to its foun-
dation in 1997, more data are available of companies using these guidelines (in 2020, 73% of the
G250 companies used GRI according to KPMG, 2020). In contrast, the IIRC was founded in
2010 with its framework being mandatory only in South Africa, which is a unique setting analysed
in some studies (e.g. Barth et al., 2017). The SDGs are only mentioned in three of the reviewed
studies: as one of many international initiatives guiding companies (Antonini et al., 2020), to
provide orientation for national sustainability associations (Clune & O’Dwyer, 2020) and as a frame-
work that, once considered by companies, should be analysed by researchers (Moussa et al., 2021).12
The SASB Materiality Map having had a primarily U.S. view until recently does not play a role in the
European studies analysed during our sample period. This may change as the SASB and IIRC were
merged into the new Value Reporting Foundation, and consolidated into the IFRS Foundation in
August 2022 (IFRS Foundation, 2021, 2022; Value Reporting Foundation, 2021).

Table 7. Count of studies reviewed – Regulation of sustainability disclosures

Classification of 57 studies
Panel A: By requirement
Mandatory 9 16% Voluntary 40 70%
Both 8 14%
Total 57 100%
Panel B: By framework/guideline
CDP 1 3% IIRC 5 12%
GRI 16 39% SASB 0 0%
SDG 0 0% Other international 5 12%
Multiple sustainability frameworks 8 *19% National 6 15%
41
Focus of studies not analysing a specific framework

Sustainability information 5 31% Financial information 1 *7%

Multiple information sources 5 31% Rating agencies 5 31%
(e.g. financial and sustainability
information)
16
Total 57 100%
Note: Table 7 shows the sustainability disclosure regulation/initiative analysed in the studies reviewed. By requirement - Both
is selected, when a mandatory and a voluntary setting are under review or the classification is not possible. CDP, GRI, IIRC,
SASB and SDG are selected when a study explicitly focuses on/refers to one of those specific frameworks. Studies are assigned
to the category Other international or National when they focus on/refer to another international or national sustainability
framework. The dimension Multiple sustainability frameworks is selected when a study focuses on/refers to two or more
specific (i.e. GRI, IIRC, SASB, CDP), other international or national frameworks. The percentages are provided to
indicate the proportion. *Rounding errors for numbers are marked with an asterisk to result in 100% in total.
 Accounting in Europe 15

5. Discussion: Sustainability Literature in the European Setting

To date, Christensen et al.’s (2021) study is the most comprehensive literature review on sustain-
ability reporting spanning different fields including accounting, finance, management and econ-
omics. While the studies discussed in such a literature review may also be relevant for the
European setting, their specific focus is on the potential economic effects of a mandate for sus-
tainability reporting in the U.S. As a key distinction, our literature review is more focused and
fleshes out the existing European evidence. On the contrary, Korca and Costa’s (2021) literature
review is focused on European evidence. However, they formulate a research agenda for future
studies on the EU NFRD; that is, they have a narrower scope than our approach. Finally, several
other publications have reviewed academic studies on corporate drivers of sustainability report-
ing, sustainable supply chains, integrated reporting or other (e.g. Dienes et al., 2016; Garcia-
Torres et al., 2019; Martins & Pato, 2019; Velte & Stawinoga, 2017). We focus on European
insights, but do not restrict ourselves topic-wise. We structure our discussion along three
aspects deemed the most characteristic of the European setting: the structure of the economic
system, the regulatory environment and the role of the company in society (cf. Dinh et al., 2021).

5.1. The Economic System

5.1.1. The Role of Banks
Compared to the market-based financing system in the U.S., many continental European countries
have a high degree of bank financing, whereas the UK has both (Bats & Houben, 2020). In bank-
based financing systems, banks play a more dominant role as financial intermediators and cannot
be easily substituted by the market. On the one hand, this dependency on the financial sector is
associated with a higher systemic risk (Bats & Houben, 2020; Crouzet, 2018). On the other
hand, the financial sector is another important lever for regulators to influence the allocation of
capital. Hence, several voluntary and mandatory legislations and guidelines by the EU address
financial institutions and their important role as not only preparers but also as users of sustainability
information. For example, Regulation (EU) 2019/2088 requires financial market participants and
financial advisors to apply a binding transparency framework based on entity- and product-level
information requirements (European Parliament, 2019). Additionally, in the latest version of the
CSRD, several rules have been added for this industry (e.g. a special definition of net turnover
to account for the features of financial institutions) (European Council, 2022c).
While studies have analysed financial companies’ disclosures, their insights are not specific to
the financial sector (Costa & Da Silva, 2019; Lai et al., 2018; Pesci et al., 2015, Appendix 4 Panel
A). In our sample, only a few studies approach research questions related to the important role of
financial institutions such as banks and insurance providers, i.e. organisations other than pro-
fessional investment companies. Eliwa et al. (2021) show that lending institutions include sus-
tainability performance and disclosures in their credit term decision. Hummel et al. (2021)
focus on the link between integrating environmental and social risk in management control
systems and whether this impacts environmental and social performance in the banking
sector. O’Sullivan and O’Dwyer (2015) interviewed commercial banks that adopted the
Equator Principles13 and non-governmental organisations (NGOs) exploring why and how
those banks voluntarily attempt to integrate sustainability issues in their project financing.
However, none of the studies analysed specifically considers the key features of the financial
sector, the sustainability quality of the lending portfolio14 and the specific role of financial insti-
tutions as a user and preparer of sustainability information. This may be because of limited data
availability. However, with Regulation (EU) 2019/2088 applicable as of March 2021 and
increased data on lending portfolios, future studies may analyse the additional monitoring role
16 T. Dinh et al.

of financial institutions. With Europe’s primarily bank-based system and the financial sector
being an important lever to influence the allocation of capital, such academic insights can
inform regulators.

5.1.2. The Importance of SMEs

In Europe, SMEs are the backbone of the economy, representing more than 90% of businesses
and providing more than 50% of employment (Muller et al., 2021; World Bank, 2021). Most
SMEs in Europe are non-listed and rely on bank financing: compared to loans (45%), market-
based instruments such as debt (2%) and equity securities (10%) are much less frequently con-
sidered a potential source of financing (European Central Bank, 2020). Within Europe, there are
considerable differences in the number of SMEs, the value added and the employment rates by
country and by firm size (micro, small, medium-sized and large) (Muller et al., 2021; Schuh
et al., 2017). SMEs in Europe face less regulatory pressure related to sustainability reporting
compared to larger and listed companies as they are not in the scope of the NFRD.
However, SMEs are similarly subject to external pressure to commit to sustainability (e.g. from
their lending financial institutions or customers subject to sustainability regulations). Hence, sus-
tainability reporting can be a competitive advantage for SMEs to position themselves within the
supply chain. According to the original CSRD proposal by the European Commission from
April 2021, SMEs would have had to comply with the rules within a three-year delay. According
to the amended version from February 2022, however, several delegations wanted ‘to exclude all
SMEs from the scope’, whereas others asked for ‘simplified standards’ (European Commission,
2021c; European Council, 2022a; European Fund and Asset Management Association, 2022).
This shows the heated discussions on whether SMEs should be included in the scope of the
CSRD and also provide more transparent sustainability disclosures (European Council, 2022b).
In the version from June 2022, there is a provisional agreement that the CSRD rules should
apply to SMEs, but with an opt-out option until 2028 (European Council, 2022c).
In our analyses, no study explicitly focuses on SMEs (or unlisted companies which most
SMEs are). However, some studies compare publicly listed companies to alternative companies,
this is social enterprises, SMEs, co-operatives and partnerships (Appendix 4 Panel B).
O’Dochartaigh (2019) provides insights on disclosure strategies. He compares the narratives
disclosed by large public companies, values-based SMEs, co-owned companies and social com-
panies not identifying many differences but all falling for sustainability storytelling. Further-
more, some studies show the relevance of ownership type on sustainability reporting and
performance (Campopiano & De Massis, 2015; Halme et al., 2020; Nekhili et al., 2017; Appen-
dix 4 Panel B). Based on the ownership type, there are different incentives (endogenous like
internally customised approaches or culture vs exogenous like compliance with sustainability
rating schemes) shaping companies’ approaches to sustainability (Halme et al., 2020).
Furthermore, some studies include SMEs (and non-listed companies) in their samples but do
not focus on the differences (e.g. Haller et al., 2018).15 Other under-investigated areas are the
external pressure from customers and financial institutions that SMEs face and the importance
of sustainability for their positioning within the supply chains. Further research is needed on
financial institutions and SMEs in the European setting. Existing studies which provide insights
on SMEs only analyse them with other alternative companies. In addition, the few studies ana-
lysing banks and insurance providers are rather not specific to financial institutions.

5.2. The Regulatory Environment

For its sustainability initiatives, the EU combines direct governmental (e.g. sustainability dis-
closure requirements) and indirect market mechanisms (e.g. emission market). Over time,
 Accounting in Europe 17

most regulations were further specified and tightened. Initially, most sustainability regulations
were targeted at companies in general. However, given the high relevance of financial insti-
tutions in Europe, those are becoming increasingly a more focal area (cf. recent EU regulations
in Figure 1).
Most European studies reviewed confirm prior international evidence; that is, voluntary sus-
tainability disclosure and performance seem to be largely positively associated with economic
benefits (e.g. Benlemlih et al., 2018; Jo & Na, 2012; Platonova et al., 2018; Qiu et al., 2016).
Most studies analysing a mandatory setting focus on single countries, primarily France and the
UK (Appendix 5 Panel A). Studies based on the French setting exploit the national regulations
Nouvelles Régulations Économiques #2001-420 and Grenelle II Acts analysing the legitimacy
and normativity of sustainability disclosures (Chauvey et al., 2015; Chelli et al., 2018). They
also examine the moderating value relevance of environmental provision disclosures under
IFRS (Baboukardos, 2018). Furthermore, Senn and Giordano-Spring (2020) analyse the
changes in environmental accounting disclosure strategies after introducing new national and
international guidelines and initiatives. They acknowledge the relevance of weak definitions
making enforcement more difficult and provide evidence that even within a country, the same
portfolio of regulations may result in heterogeneity.
Single-country studies based on the UK setting focus on national regulations: Baboukardos
(2017) shows that, after the introduction of the mandatory amendments of the UK Companies
Act 2006 (Strategic Report and Directors’ Reports) Regulations 2013, the market valuation is
less negatively associated with GHG emission disclosures. Downar et al. (2021)16 find that
UK companies subject to the regulation have improved their greenhouse gas emissions
without experiencing adverse effects on their gross margin relative to a control group of Euro-
pean companies. Ferguson et al. (2016) analyse corporate climate-change communication around
the introduction of the voluntary UK Emissions Trading Scheme and the mandatory Carbon
Reduction Commitment Energy Efficiency Scheme with a context-sensitive discursive analysis
(UK Emissions Trading Scheme: 2001-2004; Carbon Reduction Commitment Energy Efficiency
Scheme: 2009-2010). France and the UK were among the first European countries to require sus-
tainability reporting, which explains the studies’ focus. However, even among those studies ana-
lysing voluntary settings, there are papers focusing on those countries such as the study by
Depoers et al. (2016).
Most international regulations examined are based on multi-country studies (Appendix 5
Panel B):

(1) Directive 2014/95/EU: Mittelbach-Hörmanseder et al. (2021) analyse the value rel-
evance of topic-specific sustainability disclosures when there is a shift from a voluntary
to a mandatory setting in light of the announcement of the NFRD. A recently published
study by Fiechter et al. (2022)17 examines whether companies subject to the NFRD
mandate increase their sustainability activities.
(2) EU Emission Trading Scheme: Schiemann and Sakhel (2019) investigate the reporting of
higher exposure to physical risk based on a setting of multiple countries. Clarkson et al.
(2015) show that carbon allowances are not value relevant. However, they find a nega-
tive association between firms’ market value and the allocation shortfalls, that is, when
emissions are larger than the allowances.18
(3) Disclosure requirements for the extractive industry in the Accounting and Transparency
Directives: Rauter (2020) examines the effects of extraction payments disclosure
requirements on companies’ payments to foreign governments, investments and pro-
ductivity based on a sample of 30 European countries, Iceland and Canada.
18 T. Dinh et al.

(4) Environmental liability disclosures under IFRS: Paananen et al. (2021) analyse the infor-
mation content and market effects of environmental liabilities and the relevance of media
exposure on corporate disclosure strategy in 19 countries.

The institutional environment and enforcement are further found to be relevant for the value
relevance of sustainability disclosures in the European setting – both for a voluntary and a man-
datory environment (De Villiers & Marques, 2016; Mittelbach-Hörmanseder et al., 2021).
Academic insights on the European regulatory environment can be summarised as follows:
there are studies analysing the effects of national and international regulations, the effects of
direct governmental and indirect market mechanisms and the relevance of institutional environ-
ment and enforcement. However, there is a clear country selection bias and non-binding regu-
lations on sustainability reporting are not analysed. Future research may put more emphasis
on the specific transposition of EU legislation into domestic law. Studies may also analyse the
relevance of national enforcement (cf. Christensen et al., 2016 for IFRS) as well as the domi-
nance of EU compared to national sustainability legislations (e.g. Government of the Nether-
lands, 2021).

5.3. The Role of the Company in Society

Governments and their regulations play an important role in business and society and the closely
related sustainability debate (Dentchev et al., 2017). Driven by the public focus on sustainability
in general, a broader group of stakeholders is increasingly considered relevant (e.g. Ayuso et al.,
2014; Bento et al., 2017; Dentchev et al., 2017; Mason & Simmons, 2014). The national legal
traditions and governmental reforms affect how relevant non-shareholders are considered
from a sustainability perspective (Ayuso et al., 2014; Johnston et al., 2019; Maxfield et al.,
2018). Compared to the Anglo-American shareholder-oriented system, many continental Euro-
pean countries historically have had a strong stakeholder-orientation. In those countries, stake-
holder engagement and sustainability board responsibility are more common (Ayuso et al.,
2014).19
A few studies which discuss the role of the company in society analyse tax payments as a sus-
tainability activity (Holland et al., 2016; Ylönen & Laine, 2015; Appendix 6 Panel A). Most
studies reviewed focus on the link between stakeholders and sustainability performance and dis-
closures. Liesen et al. (2015) provide evidence that pressure from the state, NGOs and the public
influences the corporate choice for greenhouse gas disclosures. Islam et al. (2018) analyse the
relevance of networked governance (activities of the media and NGOs) for the anti-bribery dis-
closure practice. Hummel et al. (2021) examine the relevance of perceived power and legitimacy
of ten different stakeholder groups and find that those of clients, NGOs and (voluntary) standard
setters are related to a proactive environmental and social strategy approach.
In contrast, Lisi (2018) shows that perceived stakeholder concerns are not a significant deter-
minant for using social performance indicators in control and decision-making. Pérez et al.
(2017) provide evidence that the association between the sustainability information disclosed
and the firms’ sustainability reputation depends on the intensity of reporting to different stake-
holder groups. Costa and Da Silva (2019) examine the level of satisfaction of Italian cooperative
banks’ primary stakeholders20 with the banks’ social reporting. Miles and Ringham (2020) and
Antonini et al. (2020) analyse the setting of sustainability reporting boundaries and show that it is
related to accountability and social risks along the value chain, that is, working conditions and
human rights.
Haller et al. (2018) find that the value-added information disclosed lacks comparability, con-
ciseness and understandability. Despite the relevance of trade unions in Europe and the
 Accounting in Europe 19

increasing international scholarly attention on how they affect corporate sustainability (e.g. Ertu-
grul & Marciukaityte, 2021), there are no studies in our sample analysing those.21
Only two of the reviewed studies provide insights into the specific features of a stakeholder-
oriented governance system. Edgley et al. (2015) show that the materiality concept in the assur-
ance process has changed with the introduction of a rather stakeholder-oriented logic. Further-
more, based on a German setting, Briem and Wald (2018) identify NGOs, customers and
investors as the three main stakeholder groups asking for assurance. However, most reviewed
governance studies analyse governance mechanisms more in general22 such as compensation
and ownership (e.g. Al-Shaer & Zaman, 2019; Mio et al., 2015) and audit (e.g. Briem &
Wald, 2018; Channuntapipat et al., 2019; Edgley et al., 2015; Fuhrmann et al., 2017; Reimsbach
et al., 2018) (Appendix 6 Panel B).
Overall, previous research discusses the role of the company in society by analysing different
(non-financial) stakeholder groups. Most studies reviewed with respect to governance mechan-
isms primarily focus on compensation, ownership and audit. However, these issues are not
unique to the European setting. Future research should consider that many European countries
are less shareholder-oriented, particularly in the domain of sustainability. Future studies differ-
entiating between European countries traditionally more stakeholder-oriented and those that are
shareholder-oriented may provide valuable new findings.

6. Research Agenda and Conclusions

This study reviews extant academic literature published in top-ranked accounting, finance and
management academic journals with a specific European focus. We critically analyse those
studies and discuss the insights with respect to specific features of the European setting.
Based on this, we formulate an agenda for future research. Future studies should complement
the existing literature to provide a comprehensive information base for European institutions
to set regulations and stimulate the academic discourse.
First, we need more evidence on European banks, particularly regarding whether and how sus-
tainability reporting has changed by the introduction of the increased financial industry-focused
regulations. Furthermore, European banks’ specific role in capital allocation and monitoring in
the sustainability debate should be analysed. Especially with the new Regulation (EU) 2019/
2088 in 2021, data availability will increase with potential for future studies. Research questions
may ask (i) whether the new sustainability-monitoring role and the more sustainable lending
portfolios affect the relatively higher systemic risk associated with bank-based financing
systems, (ii) whether there are differences between the types of financial institutions and (iii)
how financial institutions change their sustainability disclosures after the introduction of the
new regulation.
Second, more research on non-listed companies, especially diverse SME types, is needed.
They are the backbone of the European economy, and although they may often not be in the
scope of regulations, several changes in the bank-lending and regulatory decisions may affect
them indirectly: lending financial institutions and corporate customers subject to regulations
may increase the pressure on SMEs to share sustainability information. In particular, research
questions may address how the sustainability reporting of the various SME types are affected
by regulations such as the NFRD (the CSRD, respectively) and Regulation (EU) 2019/2088.
More insights are needed on the importance of sustainability reporting and performance of
SMEs to position themselves within the supply chains.
Third, we identify the need for more studies on mandatory European settings and newly intro-
duced rules including the specific transposition of EU legislation into domestic law and the rel-
evance of national enforcement. None of the studies reviewed analyse the role of non-binding
20 T. Dinh et al.

guidelines such as the Guideline 2017/C 215/01 and the Guideline 2019/C 209/01 in corporate
sustainability disclosure and performance practice.
Fourth, considering the traditional orientation towards stakeholders like trade unions in most
European countries, a stronger focus on the differences in sustainability reporting and govern-
ance practice between rather stakeholder- and shareholder-focused countries may be insightful
(cf. Ayuso et al., 2014). Furthermore, the recently adopted and authorised German Supply
Chain Act23 may provide an interesting setting to analyse the management of social risks
along existing value chains.
Fifth, the country selection bias should be reduced; that is, focusing more on southern and
particularly eastern European countries to provide the evidence needed for effective policy-
making. Sixth, more automated textual analyses should be conducted in the European setting
which may improve the objectivity and traceability of research on sustainability disclosures.
Seventh, there is scope for studies employing field work to benefit from evidence that
proves causal relationships between key variables. Furthermore, more archival research is
needed analysing integrated reports, internal documents and third-party publications
related to companies such as newspaper articles. Finally, we see potential for studies ana-
lysing sustainability information more distinctly and disentangling the E-S-G more. Impor-
tant trade-offs may exist between social and environmental performance that deserve specific
investigation.
Overall, we contribute to the extant sustainability literature by offering a scoping review
of recently published studies in accounting, finance and management on sustainability
reporting in the European context. We discuss their findings considering specific features
of the European setting and suggest an agenda for future research in this field. In this
respect, the study has important implications for policymakers, companies and stakeholders
via comprehensive, rigorous scientific evidence on the state of the art of sustainability
research in Europe.
Our literature review and research agenda formulated are subject to several limitations: first,
with our scoping review and only focusing on studies published in top-ranked journals of three
disciplines within a specific period by using keyword search rather than in-depth screening, we
missed studies, including scientific groundwork and forthcoming working papers, which would
enrich our study. This is especially the case as among those journals screened niche journals such
as Sustainability, Sustainability Accounting, Management and Policy Journal and other impor-
tant outlets in the field, are missing. Furthermore, using a list of journals suffers from inherent
biases such as unidimensional rankings and change over time. Second, studies that provide
insights based on non-European settings but comprehensively discuss their transferability to
the European setting are not considered. Third, after careful evaluations, we decided on three
key features specific to the European setting with respect to which we analysed the content of
the studies selected. Future research should identify and consider other features to provide a
new perspective.

Acknowledgements
We thank the European Parliament’s Committee on Economic and Monetary Affairs (ECON) for
funding a related earlier research report of which this study is an extension. We also thank Andrei
Filip (Editor in Chief), Francesco Mazzi (Associate Editor), one anonymous reviewer, Giovanna
Michelon and Judith Stroehle, for their valuable comments on this paper as well as workshop
participants at the University of St.Gallen, the 44th European Accounting Association Annual
Congress 2022 and the 9th International Conference of the Journal of International Accounting
Research 2022.
 Accounting in Europe 21

Notes
1
As firms have begun disclosing information on their environmental and social policies not only in their annual reports
but in stand-alone reports, one often refers to so-called ‘CSR reports’ (Michelon et al., 2015).
2
This ‘ESG investing eco-system’ can also be considered critical given the debatable underlying motives of such parties
(Adams & Abhayawansa, 2022).
3
Owing to the NFRD, large EU public-interest companies have been required to disclose non-financial information since
2018 but without a mandate to use specific standards or a particular framework.
4
In September 2020, the five organisations including the Carbon Disclosure Project (CDP), Climate Disclosure Stan-
dards Board (CDSB), Global Reporting Initiative (GRI), International Integrated Reporting Council (IIRC) and Sus-
tainability Accounting Standards Board (SASB) announced that they would work together (Carbon Disclosure
Project et al., 2020), and the World Economic Forum (WEF) published a set of universal sustainability metrices
and disclosures (World Economic Forum, 2020). Furthermore, in November 2020, the IFRS Foundation Trustees
announced the International Sustainability Standards Board (ISSB) to set international sustainability standards
(IFRS Foundation, 2021). They created the Technical Readiness Working Group (TRWG), designed to integrate
and build on the work of initiatives and provide technical recommendations for consideration by the ISSB (Technical
Readiness Working Group, 2021). In August 2022, the consolidation of the Value Reporting Foundation (previously
the SASB Foundation and the IIRC) into the IFRS Foundation was completed (IFRS Foundation, 2022).
5
The number of companies in the EU required to follow EU sustainability reporting standards will increase from 11,000
to nearly 50,000 (European Commission, 2021d).
6
We limited our analysis to the CO2 intensity of GDP; it is a factor of environmental and resource productivity that,
together with the energy, non-energy material and environmentally adjusted multifactor productivity are part of the
Organisation for Economic Cooperation and Development (OECD) Green Growth Indicator ‘environmental and
resource productivity’. This indicator captures ‘whether economic growth is becoming greener with more efficient
use of natural capital’ and ‘aspects of production which are rarely quantified in economic models and accounting frame-
works’ (OECD. Stat., 2021). Though this rather crude measure has limitations, it provides important insights into cross-
country differences.
7
The SDG index score is a measure of a country’s total progress towards the achievement of the 17 SDGs (a maximum
of 100 indicates all goals have been achieved).
8
Non-EU companies having at least one subsidiary or branch in the EU and generating a net turnover of €150 million in
the EU are also subject to the CSRD (cf. European Council, 2022b).
9
Before excluding studies with a non-European focus, our sample consisted of more than 200 studies. This is compar-
able to Christensen et al. (2021) who analyse 380 studies, but with no geographic or time restrictions as in our scoping
review. The specific focus on the European setting explains the fairly low number of studies to date and shows the
potential for future research.
10
Going beyond Europe, there are more international studies using textual analysis in sustainability reporting research (e.
g. Caglio et al., 2020; Clarkson et al., 2020; De Franco et al., 2015; Lang & Stice-Lawrence, 2015).
11
One of the few studies employing an interview research design while focusing on the external perspective is the paper
by Slack and Tsalavoutas (2019), which provides evidence on how useful 22 equity market actors consider integrated
reporting.
12
In a recently published paper, Hummel and Szekely (2022) analyse the SDG disclosures in the annual reports of Euro-
pean companies using content analysis. They show that SDG reporting quality substantially increased over time, and is
associated with environment-related public pressure, customers and socially responsible investors.
13
The Equator Principles are a voluntary framework that intends to support ‘financial institutions to identify, assess and
manage environmental and social risks when financing projects’ (Equator Principles Association, 2022). Of the other
studies reviewed in our sample, excluding O’Sullivan and O’Dwyer (2015), only Hummel et al. (2021) consider the
Equator Principles in their analyses but as a control variable.
14
Hummel et al. (2021) measure environmental and social performance of 50 European banks according to five cat-
egories: GRI reporting, issuance of sustainability report, specification and quantification of greenhouse gas emissions,
products or services with societal respective ecological benefit as well as positive and negative environmental and
social screening of assets. However, the overall sustainability quality of the lending portfolio is not considered.
15
Haller et al. (2018) analyse the value-added information disclosed based on a sample of 122 listed and 52 non-listed
companies (17 firms not classified), of which 162 are large or multi-national companies and 20 are SMEs (9 firms not
classified).
16
As the study was published after the cut-off for our analysis, that is, early June 2021, it is not considered in supplement-
ing tables and appendices. Findings are presented here for completeness.
17
C.f. footnote 16.
22 T. Dinh et al.
18
Given that the EU Emission Trading Scheme has been in operation since 2005, there are several studies on the topic
published pre-2015. These discuss accounting and reporting issues of carbon trading or analyse allowance prices
amongst others (e.g. Bebbington & Larrinaga-González, 2008; Daskalakis et al., 2009; Giner, 2014; Paolella &
Taschini, 2008). A comprehensive discussion of these studies is out of the scope of this review.
19
According to Aguilera et al. (2006) as cited in Ayuso et al. (2014), UK is an exception to the scheme, potentially owing
to the high pressure from the government or institutional investors to integrate sustainability into corporate activities.
20
Cooperative bank members include employees, customers and local community members.
21
Furthermore, despite the studies reviewed focusing on stakeholders, there is some literature on the role of the company
in society that analyses external social accounting (i.e. counter and shadow accounts) (e.g. Boiral, 2013; Laine &
Vinnari, 2017; Ruffing, 2007). A comprehensive discussion on this literature stream is beyond the scope of this study.
22
In the governance literature, four governance mechanisms are commonly used: board, compensation and ownership,
audit and anti-takeover provisions (e.g. Aggarwal et al., 2011; Gao et al., 2016).
23
As of 2023, companies falling under the regulation have a due diligence obligation to identify, prevent or minimise
environmental and social risks along the supply chain. Companies will need to integrate these risks into management
systems and are required to report on those (German Federal Ministry of Labour and Social Affairs, 2021).

Disclosure Statement
No potential conflict of interest was reported by the author(s).

ORCID
Tami Dinh http://orcid.org/0000-0003-4416-9943
Anna Husmann http://orcid.org/0000-0002-2736-2007
Gaia Melloni http://orcid.org/0000-0002-6662-2887

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