The emergence of ESG frameworks in various national regulations and their impact on competitiveness
摘要
Environmental, Social, and Governance (ESG) has emerged as a key framework for corporate sustainability activities, influencing the design of corporate processes and related disclosures. One of the most advanced regulatory frameworks in this area is the European Union’s Corporate Sustainability Reporting Directive (CSRD), which became mandatory in 2024. While the Draghi report and the Competitiveness Compass highlight concerns regarding the impact of regulatory complexity on EU competitiveness and call for reducing administrative burdens, other major economies, including the United States, China, and India, are simultaneously developing their own ESG regulatory frameworks and sustainability taxonomies. This paper examines the evolution, maturity, and implementation timelines of ESG-related legislation across these jurisdictions. It applies a structured comparative analytical framework to analyse how differences in regulatory design may translate into competitiveness implications, with particular attention to the European Union. The findings indicate that the EU represents a highly advanced and operationalised ESG regulatory model, characterised by legally binding requirements, high levels of data standardisation, and the integration of double materiality. At the same time, the analysis reveals that this regulatory sophistication creates both opportunities for enhanced transparency and long-term competitiveness, as well as challenges related to compliance complexity and administrative burden. The study contributes to the literature by developing a structured comparative analytical framework for examining ESG regulatory architectures across jurisdictions and by providing a conceptual foundation for future empirical research on their competitiveness implications.