Who may be affected
edie and Bureau Veritas held an online webinar on sustainability disclosure for UK businesses with EU activity. The session examined draft third-country European Sustainability Reporting Standards, known as ESRS 40A, which are intended for non-EU parent companies meeting thresholds linked to EU revenue, subsidiaries or branches.
Speakers cited preliminary analysis indicating that about 1,200 companies worldwide could ultimately be covered, including an estimated 150 to 200 UK-headquartered groups. They advised businesses to review their EU revenue sources and corporate footprint rather than relying on headquarters location alone.
How the proposed approach differs
Full ESRS applies double materiality: companies consider their effects on people and the environment alongside sustainability-related financial risks and opportunities. The third-country proposals put more emphasis on sustainability impacts.
Potential routes discussed included global reporting, a blend of EU-specific and global information, and voluntary adoption of full ESRS. Organisations should select an approach that reflects their structure, available data and established reporting processes.
Steps for reporting teams
The webinar positioned EU and emerging UK Sustainability Reporting Standards as distinct requirements with shared building blocks, including governance, strategy, risk management, metrics and data. A reporting architecture serving more than one framework may limit duplicated work.
Speakers recommended assessing exposure across CSRD, developing third-country ESRS and UK developments; assigning clear ownership; strengthening data controls; and involving finance, risk and leadership teams. They also identified double materiality assessment as a useful evidence base for addressing multiple disclosure needs.
