The BSB EDGE Blog

Why ESG frames differ across regions—and what it’ll take to build consensus in business education
By Katyayani Mishra

If you ask a European CFO, a U.S. general counsel, and an Indian head of sustainability what “ESG reporting” actually means, you’ll get three confident—yet noticeably different—answers.

• In Brussels, ESG evokes mandatory, audited disclosures across climate, workforce, and value-chain impacts.
• In New York, it conjures investor-material climate risks filtered through securities law—currently under legal clouds.
• In Mumbai, it points to SEBI’s evolving BRSR regime and a pragmatic push to extend reporting into the supply chain without crushing smaller vendors.

The same three letters; three operating realities.

That gap isn’t just a compliance headache. It’s a strategic problem for global companies, a comparability problem for investors, and a curricular problem for business schools trying to prepare students for a world that wants one sustainability language but speaks many dialects.

This article unpacks why ESG still isn’t “global,” where the lines are starting to converge, and how management education can help close the distance.

One planet, many rulebooks

Europe’s “hard law” turn. The EU’s Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS) have redefined the bar by including detailed, mandatory disclosures, phased in across thousands of companies—including many non-EU multinationals with significant EU footprints. CSRD goes beyond climate to social and governance topics, pushing “double materiality” (what affects the company and what the company affects).

The investor baseline. Globally, the International Sustainability Standards Board (ISSB) has launched IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures), pitched as an investor-focused “global baseline.” Adoption is advancing country by country, ensuring capital markets receive consistent, decision-useful sustainability information.

India’s “build-capacity-while-you-report.” SEBI’s Business Responsibility and Sustainability Reporting (BRSR) has become the lingua franca for listed companies, with BRSR Core introducing limited assurance and a path to value-chain coverage. Regulators have extended timelines to avoid overburdening smaller suppliers while preserving credibility—showing how emerging markets balance ambition with feasibility.

The quiet work of stitching systems together

It’s tempting to frame ESG as a regulatory cage match. In reality, standard-setters have been doing patient interoperability work:

• ISSB & GRI. Collaboration now allows companies to meet investor needs (ISSB) and broader impact reporting (GRI) without duplication.
• ISSB & ESRS. Joint efforts aim to ease compliance for entities reporting under both frameworks.
• Climate & nature. The Taskforce on Nature-related Financial Disclosures (TNFD) is pushing integration of biodiversity and ecosystem risks into reporting.

Why the gaps persist (and might for a while)

Three forces keep ESG fragmented:

1. Different policy purposes. Europe legislates for market efficiency and social outcomes, ISSB focuses on investor materiality, India balances transparency with industrial development, while the U.S. treats climate as a security risk.
2. Data realities. Double materiality requires value-chain data (e.g., Scope 3 emissions), which is difficult in regions with limited supplier digitisation.
3. Assurance and liability. EU requires early assurance, the U.S. faces litigation risks, and India experiments with limited assurance under BRSR Core.

The business-school problem: teaching one subject with four textbooks

A global ESG course shouldn’t pretend there’s one universal standard. Instead, students should learn how to navigate a standards stack:

• Start with the investor baseline (ISSB S1/S2).
• Layer on regional overlays (CSRD/ESRS, BRSR, U.S. market pressures).
• Integrate thematic frameworks (TNFD, GHG Protocol updates).
• Teach interoperability as a design challenge—building one evidence base that feeds multiple disclosures.

A pragmatic roadmap for business education

Business schools can shift from slogans to skills:

• Comparability as a hands-on sport. Students produce multiple ESG reports from the same data.
• Teach version control. Practice adjusting inventories when GHG Protocol updates arrive.
• Integrate assurance thinking. Simulate auditor and board-level attestations.
• Cultivate regulatory watchfulness. Use “living memos” to track and update disclosure strategies as regulations evolve.

So, why isn’t ESG global yet?

Because the world is not. Regions are solving different problems with different tools. Yet the distance is narrowing—through baselines, bridges, and pragmatic pilots.

For companies, this means building reporting systems that can serve multiple masters without losing integrity. For investors, it promises better comparability. For business schools, it’s a leadership opportunity: teaching future managers to be translators and system builders, not just reporters.

Consensus won’t arrive via one grand bargain. It will come through iterative interoperability, credible assurance, and relentless alignment with decision-useful information.

And that’s how ESG becomes more than three letters—it becomes a global management practice fit for a planetary economy.