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CSR practices and reporting vary across countries and companies. Accouting studies using institutional theory show that even where there are coercive pressures to converge, local practices and traditions are other types of pressures that play a role in maintaining divergence. Similarly, legal studies indicate that harmonisation attempts made by the European Union are usually challenged by States attempting to maintain the status quo of the local context, and this may also apply to CSR reporting harmonization.

This research investigates whether or not the institutional pressure toward non-financial reporting harmonization represented by the Directive/2014/95/EU led to convergent behaviours between Member States, at least at the transposition stage. Transposition laws in Member States where CSR has historically played a limited role (i. e. Romania and Bulgaria) are compared with those issued by countries where CSR traditions are much more well developed (France, Belgium and the UK). The analysis focuses on how both mandatory and discretionary requirements have been transposed at a national level.

The transposition outcome is analysed in the face of economic-, government- and society-related factors of each country and results show that on several occasions, divergence is catalysed by differences in national business systems. This is aligned with the results of previous studies (e. g. Jamali and Neville, 2011), which argue that historical, cultural, economic and political local contexts mould the CSR conceptualisation existing in a given country, and therefore the convergence of different CSR practices is only apparent.


Inspired by the principles of sustainable finance and Environmental, Social and Governance (ESG) reporting, the European Union Directive 95/2014 on non-financial disclosure recognized that metrics and more transparency would foster internal debates, ensuring proper governance and helping to promote dialogue between management, the board and stakeholders, including civil society and non-governmental organizations (NGOs). Although significant academic attention has been paid to the -limited- space that the third sector had in the definition of the content of the Directive, not enough has been said on the way in which the Directive and ESG reporting can be leveraged by non-financial actors and what are the consequences of embracing accounting, non-financial reporting and corporate governance as tools for campaigning. This paper tries to fill the gap and asks some direct questions: are the Directive and the EU approach to sustainable finance opening spaces of engagement and confrontation that contribute to a true transition into a socially and environmentally sustainable future? Is the encounter between the financial realm and civil society a real win-win in the best interest of future generations and the planet? After presenting the background of the Directive and the three main opportunities that the ESG framework presents for civil society engagement, we conclude with a critical reflection on what is lost when civil society sits around the same table as financial institutions, uses their vocabulary and accepts that the conversation can only happen around those social and environmental causes that are financially material.