Double Materiality Disclosure Architectures Under European Sustainability Reporting Standards: Evidence from European Oil and Gas Companies

This study examines how double materiality is structured and disclosed during the early implementation of the European Union’s Corporate Sustainability Reporting Directive (CSRD) and the corresponding European Sustainability Reporting Standards (ESRS). While prior research has primarily focused on the identification of material topics, less attention has been given to the way these elements are organized within corporate reporting systems. To address this gap, the concept of disclosure architecture is adopted as an analytical lens. The analysis is based on sustainability statements published for the 2024 reporting period by seven large European oil and gas companies. Employing qualitative content analysis, the study applies an ESRS-based analytical framework operationalized through a structured coding scheme. Given the transitional nature of the 2024 reporting cycle, this framework provides a common analytical basis for examining how companies structure and present double materiality disclosures despite differences in reporting approaches. The framework captures two related aspects of reporting: disclosure content, specifically impact and financial materiality, and disclosure structure, including formal double materiality framing and the use of transition-related tools. The findings indicate a clear asymmetry in double materiality disclosure. Impact-related disclosures are highly standardized across companies, reflecting a shared reporting baseline shaped by regulatory expectations and industry norms. In contrast, notable differences emerge in financial articulation, formal double materiality framing, and the positioning of transition-related tools. These patterns suggest that differences emerge less in the disclosed topics themselves and more in how disclosure elements are structured and connected within sustainability statements. Building on these observations, the study identifies recurring disclosure architecture configurations observed within the sample, described as Structured Integrators, Emerging Integrators, and Selective Adopters. These recurring disclosure patterns help illustrate the different ways companies present and connect regulatory requirements, financial considerations, and transition-related elements within disclosures. The study contributes to the literature by shifting the focus from disclosure content to disclosure structure. In doing so, it provides a framework for examining how double materiality is represented and structured within reporting systems and offers insights into the coexistence of convergence and variation in sustainability disclosures examined through an ESRS-based analytical lens during the early phase of CSRD implementation.