Foreign Experience in the Development of Non-Financial Reporting and Prospects for its Implementation in Ukrainian Accounting Practice

The strengthening of the role of ESG factors in the global economy shifts the functional purpose of non-financial reporting, transforming it from a tool for formal information disclosure into a component of risk management, investment analysis, and strategic planning. In Ukraine, this process is controversial because, along with the gradual spread of non-financial disclosure practices, their fragmentation, declarativeness, and weak integration into accounting subsystems persist. This necessitates analyzing not so much the content of international standards as the institutional mechanisms that ensure their effectiveness across various economic models. The article is devoted to identifying the logic of operation of institutionally distinct models of non-financial reporting and to determining the possibilities of their adaptation to Ukrainian accounting practice. The research methodology combines institutional, systemic, and comparative approaches, using methods of structural-functional analysis, scientific abstraction, and formalization. The analytical basis is a comparison of the models of Switzerland, the UAE, Chile, Singapore, and Indonesia, within which the dominant institutional centers of influence, regulatory coordination mechanisms, and types of incentives for the disclosure of ESG information are identified. The results of the study show that the effectiveness of non-financial reporting is determined by the configuration of institutional incentives, and not by the level of its formal obligation. In environments where the interaction between market and regulatory mechanisms is established, the incorporation of ESG indicators into the accounting and management system is ensured. In contrast, administratively oriented models are characterized by the predominance of formal compliance over substantive analytics. The use of a matrix approach to evaluate models by level of incentives and degree of integration allowed authors to identify stable institutional patterns in their development. For Ukraine, an integration model for the formation of non-financial reporting is appropriate, combining market, regulatory, and financial instruments of influence. Such a model includes implementing the "Comply or Explain" principle, gradually expanding mandatory disclosure, integrating ESG indicators into the accounting system, and using the banking sector as an incentive mechanism through credit instruments. The scientific value of the study results lies in the shift in emphasis from the regulatory to the institutional dimension of non-financial reporting, which enables a deeper understanding of the processes of its implementation. The proposed approach can be used to develop a national model of ESG reporting, improve accounting practices, and increase the relevance of non-financial information for management and investment decisions.