Social and environmental disclosures in the European insurance industry in conditions of flexibility in the mandatory reporting regime

Denčić-Mihajlov, Ksenija; Spasić, Dejan Article Social and environmental disclosures in the European insurance industry in conditions of flexibility in the mandatory reporting regime Amfiteatru Economic Provided in Cooperation with: The Bucharest University of Economic Studies Suggested Citation: Denčić-Mihajlov, Ksenija; Spasić, Dejan (2025) : Social and environmental disclosures in the European insurance industry in conditions of flexibility in the mandatory reporting regime, Amfiteatru Economic, ISSN 2247-9104, The Bucharest University of Economic Studies, Bucharest, Vol. 27, Iss. 70, pp. 1069-1089, https://doi.org/10.24818/EA/2025/70/1069 This Version is available at: https://hdl.handle.net/10419/328036 Standard-Nutzungsbedingungen: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Zwecken und zum Privatgebrauch gespeichert und kopiert werden. 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If the documents have been made available under an Open Content Licence (especially Creative Commons Licences), you may exercise further usage rights as specified in the indicated licence. https://creativecommons.org/licenses/by/4.0/ Sustainability Reporting: Catalyst for Organisational and Professional Change AE Vol. 27 • No. 70 • August 2025 1069 SOCIAL AND ENVIRONMENTAL DISCLOSURES IN THE EUROPEAN INSURANCE INDUSTRY IN CONDITIONS OF FLEXIBILITY IN THE MANDATORY REPORTING REGIME Ksenija Denčić-Mihajlov1 * and Dejan Spasić2,1 1) University of Niš, Niš, Serbia 2) University of Belgrade, Belgrade, Serbia Please cite this article as: Denčić-Mihajlov, K. and Spasić, D., 2025. Social and Environmental Disclosures in the European Insurance Industry in Conditions of Flexibility in the Mandatory Reporting Regime. Amfiteatru Economic, 27(70), pp. 1069-1089. DOI: https://doi.org/10.24818/EA/2025/70/1069 Article History Received: 26 March 2025 Revised: 20 April 2025 Accepted: 25 June 2025 Abstract Insurance companies are expected to play a critical part in the transition to a net-zero, resilient, and socially just economy. Not only can they impact changes through sustainable investing and underwriting, but they can also make a contribution with their own sustainable and inclusive operations that go beyond traditional corporate social responsibility approaches. Both market and regulatory drivers in different European jurisdictions lead to various stages of the sustainability maturity of the insurance companies. Mandatory nonfinancial reporting in the European Union (EU) is codified by Directive 2014/95/EU, which allows a high level of flexibility, particularly in the choice of reporting standards/guidelines and disclosure methods. Although the Community Law has been further developed in the meantime, only with the adoption of Directive (EU) 2022/2464 a uniform reporting methodology based on the European sustainability reporting standards (ESRS) was established. The paper explores how European insurers have made progress in the sustainability agenda ahead of the adoption of Directive 2022/2464, in the flexibility regime of mandatory non-financial reporting. In a sample of 20 internationally active European insurance groups, we find that leading European insurers responded to the demands of stakeholders and society as a whole and provided high-quality information on social and environmental issues during the period 2016-2021. There is a significantly stronger focus on environmental issues, with the level of disclosure depending on the sustainability maturity stage and size of the insurance company. Keywords: Sustainability reporting; insurance industry; sustainability performance disclosure index; hierarchical cluster analysis. * Corresponding author, Ksenija Denčić-Mihajlov – e-mail: ksenija.dencic-m[email protected] This is an Open Access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited. © 2025 The Author(s). AE Social and Environmental Disclosures in the European Insurance Industry in Conditions of Flexibility in the Mandatory Reporting Regime 1070 Amfiteatru Economic JEL Classification: M41, M14, Q56, G22. Introduction One of the most important developments in the financial markets over the past ten years is sustainability, along with artificial intelligence, RegTech, and cyber security. In their capacity as businesses, risk managers, risk carriers, and investors, insurers contribute significantly to the promoting of sustainability. Due to a dual role of insurance companies, their direct (at the corporate level) and indirect (as institutional investors, risk carriers, and managers) sustainability impacts, insurers should meet the multiple sustainability reporting requirements. The EU sustainable finance regulation package includes, among others, the Corporate Sustainability Reporting Directive (CSRD, Directive (EU) 2022/2464), the Sustainable Finance Disclosure Regulation (SFDR, Regulation 2019/2088), Taxonomy regulation (Regulation (EU) 2020/852), as well as the Insurance Distribution Directive (IDD, Directive (EU) 2016/97). The predecessor of the CSRD, Directive 2014/95/EU (Non-Financial Reporting Directive – NFRD), required from companies to report on the environmental and social matters by using key performance indicators relevant to their business. It leaves a fair amount of flexibility in the implementation of its provisions, not requiring the use of a non-financial reporting standard or framework, nor imposing detailed disclosure requirements (such as lists of indicators per sector). In other words, “provisions set forth by the NFRD soon proved to be inadequate in scope and content to keep up with the regulatory development” (Baumüller and Grbenic, 2021, p. 370). The CSRD was adopted in 2022 aiming to improve the regulatory framework for sustainability reporting. Nevertheless, by giving companies significant flexibility to disclose relevant information in the way they consider most useful, the NFRD represents the first significant step in the transition from voluntary to mandatory sustainability reporting. Since the “voluntary principle of sustainability reporting only provided the hoped-for impetus for corporate management geared towards sustainability aspects to a limited extent” (Stojanović-Blab and Blab, 2024, p. 241) and considering the EU's political commitment to shifting the economy and society toward sustainability is designed to direct capital flows into sustainable businesses through improved transparency, the implementation of mandatory reporting has become essential. Having this in mind, our general objective is to assess to what extent leading European insurers have responded to the NFRD requirements regarding social and environmental issues under conditions of broad reporting flexibility. Even though there is a large body of literature on the sustainability reporting practices, drivers, and impacts on the financial performances, the largest part of the research encompasses the nonfinancial sector (see: Benvenuto et al., 2023), and contributions have only recently been extended to banks or investment companies (Baradwaj et al., 2019; Gangi et al., 2019). Despite growing attention by industry leaders and regulators, literature on sustainability practices in insurance companies is still scarce (Brogi et al., 2022; Gatzert et al., 2020; Chiaramonte et al., 2020; etc.). This is also confirmed by Aburto Barrera and Wagner (2023) in the ‘systematic literature review on the research on environmental, social and governance (ESG) factors in the insurance and pension sectors’. Our research aims to fill this gap by exploring the practice of sustainability reporting about corporate operations of 20 Internationally Active Insurance Groups with the jurisdiction of Sustainability Reporting: Catalyst for Organisational and Professional Change AE Vol. 27 • No. 70 • August 2025 1071 Group-wide supervisor located in Europe (IAIS, 2021) during the period 2016-2021, for the purpose of identifying the level of the sustainability awareness. Furthermore, the aim is to examine the relationship that exists between the size of the insurance company (measured by the value of total asset and market capitalisation) and the practice of sustainability reporting (measured by the Sustainability disclosure index). The European insurance market, as a subject of our empirical research, is very important for several reasons. As one of the largest institutional investors, insurers are important participants in capital markets. The total value of insurance companies' assets worldwide was $357 trillion in 2022 (Statista Inc., 2024). At the European level, with investments of EUR 10,627bn in the economy and a portfolio of 61% of GDP in 2023, the insurance industry is the largest institutional investor (Insurance Europe, 2025). In 2023, EU insurance companies had a global market share of 16.67% and their contribution to European GDP was 6.2% (Swiss Re Institute, 2024, p. 41). According to the European Insurance and Occupational Pensions Authority (EIOPA, 2023), with a total balance sheet of approximately EUR 8 trillion, insurers within the European Economic Area have the potential to contribute substantially to directing European economies towards a more sustainable trajectory through their long-term investments. In alignment with our objectives, the contribution of our research is two-fold. Theoretically, we advance the understanding of sustainability disclosure practices within the insurance industry during the initial phase of mandatory reporting in the EU, when regulations allowed for significant flexibility. Beyond comparing our findings with existing literature, we establish a foundation for future comparative analyses of reporting quality — contrasting the current period with the upcoming one, which will be subject to stricter reporting requirements under the CSRD. Practically, our research aims to raise awareness of the need for improved ESG reporting, not only among the insurers analysed in this study but also among other organisations committed to sustainability. The remainder of this paper is structured as follows. First, we provide a literature review on the theoretical framework and specificities of sustainability reporting in the insurance industry. Second, we explain the sample, hypotheses, and methodology. Third, we present the results with a discussion. The last Section concludes with the policy implications. 1. Literature review 1.1 Theories underlying sustainability reporting Reporting on the key elements of sustainability is an inherent function of an accounting information system that gathers, systematises, and discloses a company's performance indicators. Dealing with sustainability issues, crucial for the public interest, “accounting potentially offers one important avenue for influencing peoples’ behaviours towards such critical agendas, as well as enabling personal, organisational, and social flourishing” (Carnegie, Parker and Tsahuridu, 2021, p. 70). To achieve the public interest mission, it is essential to have a multidimensional approach to reporting that inevitably includes sustainability issues (Carnegie et al., 2024). In the earlier stages of the evolution of sustainability reporting practice, during the 1970s and 1980s, within the voluntary disclosure regime, theories that mostly support the efforts of AE Social and Environmental Disclosures in the European Insurance Industry in Conditions of Flexibility in the Mandatory Reporting Regime 1072 Amfiteatru Economic companies to be portrayed as "responsible corporate citizens" were most commonly highlighted. However, the rapidly growing interest in this issue in academia, accounting profession, industry, and society in general has led not only to the development of reporting guidelines, but also to interpretations of the theories underlying the disclosure of sustainability information (see: Del Gesso and Lodhi, 2024). Some researchers also focused on grouping of theories by applying appropriate classification criteria. Zyznarska-Dworczak (2018) highlight two groups of sustainability accounting studies - "studies which represent a positive approach (‘what is?’), for example: legitimacy, stakeholder, institutional, signaling, and decision usefulness theory" and studies with “normative approach (‘what ought to be?’), for example: ethical, pragmatic, or conditionalnormative theories” (pp. 160-161). Bartolacci et al. (2022) differentiate "main" and "minor, i.e. emerging" theories of sustainability disclosure, and show that "legitimacy, institutional, and stakeholder theories are by far the most used and popular for informing empirical or conceptual studies" (p. 106). Most of the above-mentioned and other theories were developed in the era of voluntary sustainability disclosures (mostly regarding environmental and social issues). Without undermining the significance of other theories, the findings of our research will be analysed through the lens of stakeholder, legitimacy, institutional, signaling, and agency theories, which will be briefly discussed. According to stakeholder theory, founded by Freeman (1984), the focus is on the interests of all relevant stakeholders and satisfying their wants (Dyllick and Hockerts, 2002). The company should, therefore, prioritise the values promoted by various interest groups or individuals who have the capacity to affect the achievement of the company's objectives or whom the company can affect. The reports should contain both financial data, and in particular information related to ESG issues (Lozano, Carpenter and Huisingh, 2015). Accordingly, disclosing information about social and environmental performance can be a way to establish a “democratic dialogue” with stakeholders (Brown and Fraser, 2006, p. 109) and help build trust and loyalty. The basic premise of the legitimacy theory is that companies do not possess an intrinsic entitlement to existence unless their value system aligns with the norms, values, and beliefs of the society. There is a kind of "social contract" between the company and society about how the company should conduct its business activities in order to gain legitimacy and thus avoid regulatory sanctions if it does not meet society's expectations. Through such an implicit agreement, society grants the company a “license to operate” (García-Meca et al., 2024). In the circumstances of the growing resources scarcity or their degradation globally, there is a need – which is increasingly becoming an obligation – to communicate the responsible management of an organisation to its wider environment (Zyznarska-Dworczak, 2018). The main focus for companies (and their owners) is not on making profits, but rather – according to institutional theory – on gaining legitimacy from the wider social community (Griffin and Youm, 2018). Achieving this goal requires the company to comply not only with external norms and regulations, but also with the generally accepted practices and procedures in the institutional environment. Every organisation is inevitably exposed to the pressures of the environment in which it operates. Institutional pressures may be externally caused “such as government, markets and society (e.g., constituency groups and industry associations)”..., [whereas within the organisation],... “institutional pressures also arise from the culture, Sustainability Reporting: Catalyst for Organisational and Professional Change AE Vol. 27 • No. 70 • August 2025 1073 shared belief systems, and political processes, and shareholders” (Darnall, Henriques and Sadorsky, 2008, p. 366). Disclosure of sustainability issues demonstrates compliance with social norms, even if there is no legal obligation. Namely, apart from affirmative achievements in ESG activities, “company applying the institutional approach could mention a negative event and provide ideas, intent or measures for tackling or avoiding it in the future” (Turzo et al., 2022, p. 8), which is one of the essential steps in achieving the legitimacy of the company and thereby ensuring the conditions for stable long-term business and maintaining a company's competitiveness (Tăchiciu et al., 2020). Signaling information on financial and ESG performance reduces the information gap between company management and capital market participants (Chen et al., 2023; Liu et al., 2024) and other interested parties (Kandpal et al., 2024; Bolognesi and Burchi, 2023). Agency theory is most commonly used in the literature to explain the factors influencing the voluntary disclosure of ESG indicators, for example: size, gender, educational background or age structure of board, compensation policy, quality of the internal control, etc. (Yan, Hu and Hu, 2024). In addition, incentives for (voluntary) sustainability disclosure are interpreted by signalling and agency theories from the perspective of possible abuses (manipulation) by management. Such circumstances may particularly contradict the idea of legitimacy theory. Melloni, Caglio and Perego (2017) suggest that ‘companies that demonstrate high ESG performance are motivated to signal their exceptional sustainability performance to the market through ESG disclosure’. However, the opportunistic behaviour of managers to cover up failures and emphasise (desirable) successes implies "the so-called obfuscation hypothesis", which is based on the suspicion that managers are not neutral in the disclosure of accounting information (Brennan, Guillamon Saorin and Pierce, 2009). In other words, in accordance with agency theory, managers of “poorly performing” firms are likely to provide information that presents the firm in the most favourable light (Merkl-Davies and Brennan, 2007) in order ‘to conceal their true performance while trying to maintain their legitimacy’ (Melloni, Caglio and Perego, 2017, p. 231). 1.2. Sustainability disclosures in the insurance industry As risk managers, risk carriers, and investors, insurers need to incorporate ESG issues into their risk value chain to ensure their own sustainability, as well as the sustainability of their customers and investees, and indirectly other stakeholders. Insurers should consider various risks associated with their clients' businesses, including sustainability aspects, thereby significantly contributing to climate sustainability and green investments in recent times (Goel, Bassi and Pankaj, 2023). Hovewer, the intrinsic characteristics of insurance intermediation activities make the social and environmental impacts less noticeable or completely invisible (Ullah, Muttakin and Khan, 2019), which further reinforces the need for sustainability reporting. In accordance with the theoretical framework analysed previously, insurers strive to meet the expectations of both customers (policyholders) and other stakeholders. Since the insurance industry’s business model is based on trust (Heidinger and Gatzert, 2018), the social and environmental practices of insurance providers can significantly enhance a company's reputation and brand value (Lee et al., 2022). On the other hand, inadequate ESG risk underwriting increases the likelihood of reputational damage or loss, while concurrently threatening the financial performance of the insurance company (Nogueira et al., 2018). AE Social and Environmental Disclosures in the European Insurance Industry in Conditions of Flexibility in the Mandatory Reporting Regime 1074 Amfiteatru Economic There are also studies that the initial expenditure on social and environmental initiatives is compensated for by positive effects in the medium and potentially long term (Fatemi et al., 2015), albeit with limited financial effects (Brooks and Oikonomou, 2018). Customers' awareness of the insurance company's social responsibility, especially in the life insurance sector, influences their stronger loyalty and indirectly the satisfaction effect (Lee, 2018). Therefore, clear, fair, and non-misleading information provided by insurance distributors to existing and potential customers (beneficiaries) is also an indispensable source of information on issues relating to the sustainability of the insurance company and the insurance products offered (EIOPA, 2024). From a behavioural economics perspective, Apicella, Carannante and D'Amato (2023) argue “that policyholders may assign a remarkable value to the insurers’ commitment towards social sustainability” (pp. 8-9). In addition to direct communication with customers, insurers should pay special attention to the disclosure of publicly available, comprehensive sustainability reports. Empirical evidence indicates that European companies are committed not only to providing sustainable products, but also to providing reliable and relevant ESG disclosures. Gatzert and Reichel (2024), based on a sample of 1,215 annual sustainability and investment reports from 77 insurance companies in the US and Europe for the period 2013–2018, find that the concept and principles of sustainable investments are disclosed much more comprehensively in the reports of European insurers than in those of US insurers. The need for our research on the disclosure of social and environmental issues is justified by the growing importance of these two pillars for the sustainability of insurance companies. This could be supported by research of Chiaramonte et al. (2020), who on a sample of 94 US listed insurers for the period 2006-2018 find “that the overall ESG scores were positively associated with insurer stability, and that this relationship was significant for the environmental and, especially, the social pillars” (p. 15). A much more common research topic concerns the disclosure of environmental information, particularly with regard to climate-related risks (Kraus, 2024; Amar et al., 2022). For example, using a sample of 15 large insurance companies in the United Kingdom, Klumpes et al. (2019) observe that the majority of sampled insurers took into account the impact of climate change on their investment strategies, albeit with varying frequency and nature of issues considered. Gatzert and Reichel (2022) indicate that larger European insurers are more aware of business risks and opportunities arising from climate change compared to insurers in the US. In addition to examining the scope and content of sustainability reports, researchers also focus on identifying factors that influence the awareness of sustainability of insurance companies. The main determinants of a high level of ESG awareness are most often: the size of the insurance company, its profitability, and solvency (Brogi et al., 2022; Brasch and Eckert, 2024). As expected, the higher the values of these determinants, implies the higher the ESG awareness of the insurer. The development of the market, i.e., the country of origin, foreign ownership, board independence, as well as institutional pressures, also play an important role in shaping insurers' ESG awareness and the need for disclosure (Ullah et al., 2019). However, as already mentioned, the disclosure of non-financial information may be motivated by questionable motives of signaling and gaining legitimacy. Some research also highlights the tendency to conceal information that could damage an organisation's reputation Sustainability Reporting: Catalyst for Organisational and Professional Change AE Vol. 27 • No. 70 • August 2025 1075 while disclosing positive information about sustainability performance (Haffar and Searcy, 2020; Diouf and Boiral, 2017). In some cases, therefore, the disclosure of sustainability information may have not only an unethical, but also an unlawful dimension. Inadequate disclosures and related ESG controversies can have long-term implications for the sustainability of an insurance company’s business. "ESG (or CSR) decoupling” denotes the divergence between the actual effects of ESG (or CSR) initiatives and their external disclosure (Chao, Yifei and Shuai, 2025), which is particularly apparent in "greenwashing" practices (Bothello et al., 2023; Sneideriene and Legenzova, 2025). Therewith, the governance (G), as a pillar of ESG practices, is essential in mitigating the effects of that controversies on the insurers' insolvency risk (Giráldez-Puig et al., 2025). 2. Sample, hypothesis and methodology The empirical study was conducted on a sample of 20 Internationally Active Insurance Groups with jurisdiction of Group-wide supervisor located in Europe. According to the International Association of Insurance Supervisors, in order to be qualified as Internationally Active Insurance Group, the insurance company have to fulfill two criteria: 1) ‘to be internationally active (premiums are written in three or more jurisdictions and gross written premiums outside of the home jurisdiction are at least 10% of the group’s total gross written premiums)’, 2) to have a defined ‘size based on a three-year rolling average (total assets are at least USD 50 billion; or total gross written premiums are at least USD 10 billion)’ (IAIS, 2021). The focus was on 20 insurers in five key European markets: France (3), Germany (3), the Netherlands (3), Switzerland (4), and the UK (3). To identify the level of the sustainability awareness among selected insurers, the empirical analysis covered the six-year period, 2016– 2021. Taking into account the structure of the sample companies, significant pressure by stakeholders, the nature of the sustainability reporting requirements, and the analysed theoretical and normative framework, two hypotheses are formulated: Hypothesis 1: In accordance with the practice of social and environmental performance disclosure, it is possible to group companies according to the level of sustainability awareness and the scope of sustainability reporting practices. Hypothesis 2: The size of the leading European insurance companies is relevant for the sustainability disclosure practice. Although there are different frameworks for sustainability reporting (Bose, 2020; Afolabi, Ram and Rimmel, 2022; Albu et al., 2013), we consider the GRI standards as a relevant framework for our modelling, as they are one of the most widely used sustainability reporting guidelines worldwide (IFAC, 2024). The reporting principles underlying the GRI Framework, i.e., "accuracy, balance, clarity, comparability, completeness, sustainability context, timeliness, and verifiability" (Abeysekera, 2022, p. 1389), ensure the relevance of the indicators we use to create our disclosure indices. Additionally, García-Sánchez et al. (2022) prove that the use of GRI reduces SCR decoupling. In order to assess the scope and the quality of sustainability reporting, 3 indices have been designed. Socially performance disclosure index (SPDI), Environmental performance disclosure index (EPDI), and composite, Sustainability performance disclosure index (SusPDI). The social dimension of sustainable development has been covered by 17 social AE Social and Environmental Disclosures in the European Insurance Industry in Conditions of Flexibility in the Mandatory Reporting Regime 1076 Amfiteatru Economic indicators belonging to the GRI 400 standards (see Table no. 1). The environmental dimension is assessed by encompassing 14 indicators from the GRI 300 Standards (see Table no. 2). Table no. 1. Analysed social indicators belonging to GRI 400 GRI 401: ‘Employment’ 401-1 ‘New employee hires and employee turnover’ 401-2 ‘Benefits provided to full-time employees that are not provided to temporary/ parttime employees’ 401-3 ‘Return to work and retention rates after parents leave, by gender’ GRI 402: ‘Labor /Management Relations’ 402-1 ‘Minimum notice periods regarding operational changes’ GRI 403: ‘Occupational Health and Safety’ 403-1 ‘Occupational health and safety management system’ 403-2 ‘Hazard identification, risk assessment, and incident investigation’ GRI 404: ‘Training and Education’ 404-1 ‘Average hours of training per year per employee’ 404-2 ‘Programs for upgrading employee skills and transition assistance programs’ 404-3 ‘Percentage of employees receiving regular performance and career development reviews’ GRI 405: ‘Diversity and Equal Opportunity’ 405-1 ‘Diversity of governance bodies and employees’ 405-2 ‘Ratio of basic salary and remuneration of women to men’ GRI 406: ‘Nondiscrimination’ 406-1 ‘Incidents of discrimination and corrective actions taken’ GRI 412: ‘Human Rights Assessment’ 412-3 ‘Significant investment agreements and contracts that include human rights clauses/ underwent human rights screening’ GRI 413: ‘Local Communities’ 413-1 ‘Operations with local community engagement, impact assessments, and development programs’ GRI 414: ‘Supplier Social Assessment’ 414-1 ‘New suppliers that were screened using social criteria’ GRI 415: ‘Public Policy’ 415-1 ‘Political contributions’ GRI 418: ‘Customer Privacy’ 418-1 ‘Substantiated complaints concerning breaches of customer privacy and losses of customer data’ Table no. 2. Analysed environmental indicators associated with GRI 300 GRI 301: ‘Materials’ 301-1 ‘Materials used by weight or volume’ 301-2 ‘Recycled input materials used’ GRI 302: ‘Energy’ 302-1 ‘Energy consumption within the organisation’ 302-3 ‘Energy intensity’ 302-4 ‘Reduction of energy consumption’ GRI 303: ‘Water and Effluents’ 303-5 ‘Water consumption’ GRI 305: ‘Emissions’ 305-1 ‘Direct (Scope 1) GHG emissions’ 305-2 ‘Energy indirect (Scope 2) GHG emissions’ 305-3 ‘Other indirect (Scope 3) GHG emissions’ 305-4 ‘GHG emissions intensity’ 305-5 ‘Reduction of GHG emissions’ GRI 306: ‘Waste’ 306-2 ‘Management of significant waste-related impacts’ 306-3 ‘Waste generated’ 306-5 ‘Waste directed to disposal’ The calculation of the Disclosure Index, ‘as one of the approaches to content analysis, implies that the presence or absence of certain information is determined primarily by a simple binary coding method and then the index is calculated based on the summary result of all selected information’ (Ehsan et al., 2018). The positions of an Index in this paper are coded with 0 (if the information about indicators is not disclosed), 1 (if the information in the report exists, descriptively, or quantitatively). The index value is determined as a sum of equally weighted Index positions, giving the possible maximum of SusPDI value of 31. Furthermore, disclosure rates have been calculated as a ratio of calculated and maximum index value. Sustainability Reporting: Catalyst for Organisational and Professional Change AE Vol. 27 • No. 70 • August 2025 1083 References Abeysekera, I., 2022. A framework for sustainability reporting. Sustainability Accounting, Management and Policy Journal, 13(6), pp.1386-1409. https://doi.org/10.1108/SAMPJ08-2021-0316 Aboud, A., Saleh, A. and Eliwa, Y., 2024. Does mandating ESG reporting reduce ESG decoupling? Evidence from the European Union's Directive 2014/95. 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