ESRS, CSRD Demand Disability Focus

Businesses under pressure to provide increased transparency across the full scope of social and human rights.  

Corporates subject to new and incoming EU sustainability disclosure rules must be prepared to report on their practices for the inclusion of persons with disabilities and other marginalised groups.  

“Companies need to account for all social and human rights factors, and that includes people with disabilities,” said Gemma Sanchez Danes, Lead of the European Financial Reporting Advisory Group’s (EFRAG) Central Project Management Office (PMO). 

“We have a clear mandate in the Corporate Sustainability Reporting Directive (CSRD) that talks about equal opportunities for equal work […] it’s about empowering people with disabilities and non-discrimination,” she said. 

She was speaking at a recent webinar considering the pivotal role of sustainability reporting in advancing inclusive business practices, presented by the Global Reporting Initiative (GRI) and Fundación ONCE as organisations involved in Disability Hub Europe (DHUB), a European multistakeholder initiative aimed at building a reference space to promote disability and sustainability.  

CSRD, which came into effect earlier this year, with first disclosures expected from 2024, will be underpinned by the first set of sector-agnostic European Sustainability Reporting Standards (ESRS), which specify how companies report on sustainability matters and are designed to reflect sustainability report users’ growing needs for comparable, relevant and reliable information. 

EU-based companies will be expected to disclose the percentage of employees with disabilities, how this data was collected, its policies to eliminate discrimination and advance diversity and inclusion (D&I), and confirmation of whether or not all employees are covered by social protection, either through public programmes or benefits offered by the company. 

Companies will also be asked to disclose the positive impacts of their actions for customers and end-users, such as product design to improve accessibility for persons with disabilities.  

Although these disclosure requirements do not force companies to change their practices, the requirement for increased transparency allows stakeholders like investors to hold companies accountable, panellists agreed.  

“The remit of the ESRS is not only EU-focused, but global,” said Sanchez Danes, noting that companies will also need to consider disability within non-EU subsidiaries. 

“Leave no one behind” 

The EU’s disability-focused disclosure rules are aligned with the 2030 Agenda for Sustainable Development, which further recognises disability awareness and support as part of the successful realisation of human rights and its core message to “leave no one behind”.  

A 2022 survey of companies in the Valuable 500 initiative, a global business partnership working to end disability exclusion, found that 58% of the companies assessed have started or invested in developing inclusive innovation opportunities. Fifty-four percent were found to have an active disability inclusion accessibility policy, and 59% said they have an executive sponsor responsible for the company’s disability inclusion performance. 

In June, DHUB also updated its ‘Disability in Sustainability Reporting’ guide to take account of these changes to the EU reporting landscape, as well as the GRI’s updates to its Universal Standards, which also includes specific disability-related content. 

“CSRD [and the ESRS] has potential to put a spotlight on discrimination according to gender, ethnic origin or disability in companies and to ultimately give better access to equal opportunities,” said Pascal Durand, European Parliament Rapporteur.  

“The business world is experiencing a new momentum, with more solidarity, more transparency, and more information sharing.” 

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