Regulating EU Sustainability Reporting: Learning From Failure and Success advances a forceful and analytically rich argument. Its central claim is deliberately provocative: sustainability reporting (SR) has repeatedly failed as a regulatory project due to a ‘structural fallacy’ in how accounting itself is conceived (p. 3). Rather than attributing shortcomings to weak implementation or insufficient disclosure, the author locates the problem at the level of epistemic and institutional design.
The argument is developed through a careful reconstruction of what is termed the ‘SR conundrum’. Sustainability reporting is presented as inherently unstable and contested, characterised by plural definitions, multiple audiences, and competing accountability demands. Tensions persist not only between financial, social, and environmental priorities, but also across institutional domains and regulatory logics. Against this backdrop, the book offers a historical account that challenges linear narratives of progress. Instead, SR is shown to evolve cyclically.
The first wave, in the 1960s and 1970s, saw strong advocacy for mandatory social reporting aligned with welfare state governance and industrial relations, yet this momentum dissipated in the 1980s without substantive legislative transformation. A second wave emerged in the 1990s and 2000s, but largely detached from accounting law and dominated by voluntary standards, resulting in fragmentation, weak comparability, and limited enforcement. Following the 2008 financial crisis, a third wave introduced stronger regulatory ambitions, particularly within the European Union, culminating in the transition from the Non-Financial Reporting Directive to the Corporate Sustainability Reporting Directive (CSRD) and the development of the European Sustainability Reporting Standards (ESRS). In comparison with earlier waves of SR reform, this recent wave, as the book contends, has shifted from information demands by civil society to governmental demand for information. SR is now positioned as a tool to enable public authorities to monitor, compare, and steer corporate behaviour in relation to environmental and social objectives. In this sense, SR is no longer framed solely as a mechanism of external accountability to civil society, but as part of a broader regulatory infrastructure supporting state-led governance of the economy. This shift marks a significant reorientation: from transparency as an end in itself to information as an instrument of policy coordination and economic management.
The book offers a detailed examination of the CSRD as a regulatory milestone. By mandating sustainability disclosure within annual reports and requiring firms to align their business models with ‘the transition to a sustainable economy’ (p. 8), the directive signals an important shift. Yet the author identifies several limitations that may undermine its transformative potential. First, the complexity and scope of reporting requirements risk turning SR into a compliance exercise, a ‘tick-the-box’ practice lacking substantive impact (p. 13). Second, despite formal integration, sustainability disclosures remain effectively ‘an add-on’, with limited guidance on how to connect them to financial information (p. 14). Third, firms must navigate a fragmented landscape of overlapping standards, including the European Sustainability Reporting Standards (ESRS), the International Financial Reporting Standards Sustainability Disclosure Standards (IFRS Sustainability Standards), and the Global Reporting Initiative (GRI) Standards, creating what is described as a ‘multiverse’ of reporting regimes. Fourth, standard-setting processes remain dominated by accounting professionals and financial institutions, raising concerns about institutional bias. Finally, the 2025 Omnibus reforms, which propose significant reductions in scope and reporting requirements, illustrate the fragility and reversibility of regulatory progress.
This diagnosis leads to a deeper theoretical intervention. Drawing on critical accounting scholarship, the book challenges the conventional view of accounting as neutral and objective. Instead, accounting is understood as constitutive of economic reality and as ‘a powerful tool for political economy having socio-ecological systemic effects’ (p. 18). From this perspective, the failure of SR is not incidental. Existing accounting systems are not designed to accommodate sustainability objectives; rather, they reinforce a financialised logic that produces what is described as a ‘predatory model of value creation’, marginalising human rights concerns and ecological degradation (p. 19).
Through this analysis, the book advances a compelling conclusion: the limitations of SR are structural rather than technical. Sustainability cannot be reduced to ‘a set of additional KPIs’ but instead constitutes ‘overarching morally committed and political constitutional objectives’ (p. 18). The central issue is therefore not the availability of data, but the underlying definition of value embedded within accounting systems.
The book’s contribution is particularly significant when situated within the Business and Human Rights (BHR) literature. BHR scholarship has long recognised the limitations of transparency-based governance. The adoption and implementation of the UN Guiding Principles on Business and Human Rights (UNGPs) has been accompanied by sustained scepticism regarding the effectiveness of voluntary reporting in delivering meaningful accountability. While disclosure remains an essential component of corporate accountability, it is widely acknowledged as insufficient for ensuring the prevention and remediation of harm.
This book deepens that critique by demonstrating that reporting is not merely incomplete but structurally constrained by the architecture of financial accounting. It thus provides a compelling explanation for the persistent gap between disclosure and substantive human rights protection. This gap is not simply the result of weak enforcement or insufficient transparency, but it is embedded in how corporate accountability is conceptualised and operationalised. The discussion of double materiality is particularly relevant in this regard. By requiring firms to disclose both financial risks and societal impacts, the CSRD appears to align with the logic of human rights due diligence. Similar principles are reflected in reporting frameworks such as GRI, which operationalise the expectation that firms should ‘know and show’ their respect for human rights. However, a critical distinction remains. Whereas BHR emphasises prevention, mitigation, and remedy across value chains, SR continues to privilege visibility and disclosure. Human rights, grounded in normative claims of dignity and justice, risk being translated into measurable impacts or risk categories, thereby weakening their normative force.
This shift from civil society–driven transparency to state-centred monitoring further complicates the relationship between SR and BHR. While enhanced reporting may improve the informational capacity of regulators, it does not necessarily strengthen the position of rights-holders or ensure effective access to remedy. Instead, accountability becomes increasingly mediated through institutional mechanisms of monitoring and comparison. Human rights concerns risk being reframed as objects of governance rather than claims demanding justification and redress.
The book’s analysis of fragmentation further reinforces its relevance for BHR scholarship. Just as SR is divided across financial, non-financial, voluntary, and mandatory regimes, human rights concerns are often dispersed across disciplinary domains, appearing as risk in international business, compliance in law, and disclosure in accounting. While such translation facilitates operationalisation, it also fragments the normative coherence of human rights. The book suggests that sustainability issues are not merely implemented within accounting frameworks but reshaped by them. A similar dynamic can be observed in BHR, where human rights may be re-specified in ways that align with calculative logics and domesticated and co-opted through corporate CSR strategies and processes.
The analysis of financialisation introduces a further challenge. By demonstrating how accounting standards have evolved to prioritise capital providers, the book calls into question a central assumption within BHR scholarship, namely that stronger regulation and improved due diligence can align corporate conduct with human rights norms. If corporate governance remains embedded within a financialised system oriented towards value extraction, such reforms may face structural limits. This shifts the analytical focus from improving corporate behaviour within existing frameworks to interrogating how those frameworks themselves generate and sustain harm.
The book’s insistence on the political nature of accounting also resonates with emerging engagements between BHR and political theory (e.g., political corporate social responsibility). If accounting determines what is visible and measurable, it also shapes whose claims are recognised as legitimate. In this sense, corporate reporting forms part of a broader justificatory order. Yet, current reporting frameworks prioritise standardisation and comparability over contextualised accounts of harm, producing forms of accountability that are procedurally robust but normatively thin.
Notwithstanding its strengths, the book leaves several questions open from a BHR perspective. While the structural critique is persuasive, pathways for integrating financial accounting, sustainability metrics, and human rights obligations remain underdeveloped. The emphasis on the ‘right to information’ does not adequately address situations where rights are violated, nor does it foreground the role of rights-holders as active participants. Instead, reporting frameworks risk positioning the public as passive recipients of information. Moreover, governance models based on regulator–intermediary–target relationships may reinforce asymmetries between those who define norms and those subject to them, leaving rights-holders marginalised in processes of accountability.
In sum, Regulating EU Sustainability Reporting makes a substantial contribution to both accounting and BHR scholarship. Its central insight, that the limitations of sustainability reporting are rooted in the underlying logic of accounting, offers a powerful explanation for the enduring gap between disclosure and substantive accountability. For BHR scholars, the book serves as both a caution and an invitation. It cautions against over-reliance on reporting and transparency as tools of governance, while inviting deeper engagement with the calculative infrastructures that shape corporate behaviour. Advancing business respect for human rights requires more than better reporting frameworks. It requires a fundamental rethinking of how value and accountability are defined, measured, and governed. It becomes apparent that SR and BHR are, in many respects, advancing along parallel trajectories, each calling for a transformation in the epistemic foundations and methodologies of accounting and corporate accountability. Rather than remaining fragmented across disciplinary and regulatory domains, these fields could benefit from forming ‘a chain of equivalence’, to articulate their shared critique of financialised value and disclosure-based governance into a broader counter-hegemonic project.
