Initial Evidence on Stakeholder Participation in EFRAG’s Sustainability Reporting Standard-Setting Process

This paper investigates stakeholder participation in the European Financial Reporting Advisory Group’s (EFRAG’s) standard-setting process for sustainability reporting, with a focus on the extent of participation and the level of support across different stakeholder groups and geographical regions. Centred on EFRAG’s development of the European Sustainability Reporting Standards (ESRS), this study analyses participation in the public consultation on the first 13 exposure drafts (EDs). Employing a rational-choice framework and neo-institutional approaches in the analysis of the feedback received from the public consultation, the research tests hypotheses regarding stakeholder behaviours and country-specific differences. The findings highlight significant disparities in participation: preparers demonstrate higher participation frequencies than users, while users express greater support for additional sustainability-related disclosure requirements. Furthermore, support varies among stakeholders with different attributes, such as cultural and institutional backgrounds or simultaneous participation in other sustainability reporting consultations. These results underscore the critical role of stakeholder diversity in fostering input legitimacy and the normativity of the ESRS. By offering early empirical evidence, this paper contributes to emerging literature on sustainability reporting standard-setting and provides valuable insights into the stakeholder dynamics within the European Union (EU) sustainability reporting framework.