The Framework

The Three-Layer
Framework

The comparison between 2021 and 2025 is shaped by changes in reporting rules, disclosure standards and the wider operating environment.

01

Structural

Compliance and Reporting Architecture

The structural context is defined by the transition from voluntary reporting to a mandatory, integrated framework. Under the CSRD, companies are now required to include sustainability information within a dedicated section of the management report. This architecture is governed by the ESRS and the principle of double materiality, requiring companies to assess both their impact on the environment and the sustainability matters affecting their financial position. Additionally, the EU Taxonomy mandates specific disclosures regarding the share of activities that are taxonomy-eligible and aligned.

This layer examines how sustainability is physically and strategically positioned within the report, including the choice of reporting frameworks and regulatory alignment. It serves to illustrate how the shift in the regulatory landscape has reshaped the "skeleton" of sustainability reporting between 2021 and 2025. By analyzing the reporting architecture, we can assess the degree to which sustainability has been integrated into the core governance and management of the organization.

Voluntary → mandatory reporting
Double materiality principle
EU Taxonomy alignment required
Integrated into management report
02

Narrative

Language, Framing, and Corporate Role

The narrative context has shifted significantly as the external environment places increased attention on energy security, supply chain resilience, and industrial competitiveness. ESRS requirements now formalize a stronger link between sustainability reporting and a company's business model, strategy, and due diligence. This regulatory shift demands that companies move away from vague, vision-led stories toward a more clinical and operational explanation of their role and strategic direction.

This layer examines the specific language, recurring themes, and rhetorical emphasis used to describe sustainability in words. It captures the "headline messages" and the broader role that sustainability is assigned within the report. This is the layer where the influence of societal shifts can be expected to become most visible.

Operational framing
Formalized strategy linkage
Choice of headlines and highlights
CEO words
03

Data

Metrics, Evidence, and Disclosed Priorities

The data context has evolved from a reliance on diverse frameworks like GRI, SASB, and TCFD toward the standardized requirements of the ESRS. Companies must now disclose granular data on Scope 1, 2, and 3 greenhouse gas emissions, as well as topical standards covering biodiversity, water, and social sustainability across the value chain. Crucially, this data is no longer self-reported without oversight; under CSRD, sustainability information is subject to limited assurance by a statutory auditor to ensure its accuracy and reliability.

This layer examines the disclosures used to provide evidence for the company's sustainability claims. It assesses how changing risk assessments and regulatory requirements are reflected in what companies choose to measure and disclose.

GRI/SASB/TCFD → ESRS standards
Scope 1, 2 & 3 mandatory
Limited assurance required
Biodiversity & social metrics added

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We approach this research with curiosity, not judgement.

Research & analysis by Miltton Sweden · Published April 2026