ESG Disclosure Timeline: How to Plan Ahead for 2022

The CDP is a non-profit organization that administers a global disclosure system for public and corporate users to report on their risks and opportunities related to climate change, water security, and deforestation.  

The S&P Global Corporate Sustainability Assessment (CSA) is an annual evaluation of companies’ sustainability practices. Every year, S&P Global invites eligible companies to complete CSA questionnaire. The responses are then evaluated by S&P and integrated into the rebalancing of DJSI (Dow Jones Sustainability Indices) and the S&P ESG Index series.  

However, navigating the different reporting frameworks and questionnaires as well as understanding how to execute both mandatory and voluntary public reports can seem like a monumental task, especially when taking your first go at it. To help guide you through the process, we’ve created a reporting and disclosure timeline to walk you through the reporting season and everything you need to prepare for it.   

But before we get to the calendar, let’s look at the bigger picture of why reporting and disclosure is so important and some key factors to keep in mind when preparing to share your company’s ESG story.  

Why Respond to Public Disclosure Requests?    

• Transparency is important for collaboration and for reputation. We live in an age of hyper transparency, and stakeholders are increasingly seeking information about the companies they invest in, the products and services that they buy, and the suppliers they hire. It’s critical to stay proactive with information sharing and control YOUR story to the extent possible.    
• You have a great story to tell. Public disclosure highlights your sustainability programs, stakeholder engagements, and progress to goals.     
• Regular reporting keeps everyone in check. Reporting can also be a motivational driver to keep up with your organization’s initiatives and to track progress towards goals and targets.  
• Investors are using this information. The number of investors seeking ESG metrics from companies is increasing. 
• Investors are using this information to compare a company against its peers. Companies are evaluated and determined as leaders, average, or laggards based on ESG maturity on an industry curve. Investors use this information to assess future growth opportunities and competitive edge of a company.  

The Four W’s of Your Reporting Process  

1. WHY are we reporting? 

Is it simply a response to an investor or customer request, or is it a mandate by your Board of Directors? Whatever the reason, it helps to understand the business value behind your sustainability reporting efforts. Make a list of the benefits of your reporting venture – top of the list should be “telling your story on your terms.” Use this list to get buy-in from your internal stakeholders. Don’t make it an exercise to just check off boxes when you can use this process to strengthen your strategy and internal awareness of your initiatives.    

2. WHAT do we need to report?  

Create an outline of all of the aspects of your disclosures and know what have changed from year to year. Conduct an assessment to better understand what is important or material to report based on your business/stakeholders. Take the time to understand the scope so that you do not go down the rabbit hole trying to find information that might not add value or be relevant to your stakeholders. External reporting requestors like CDP will typically post documents that identify changes in questionnaires from year to year to take the guess work out of scope determination.    

3. WHEN are reports due?  

The final deadline should not be your sole focus – think about the milestones necessary to get there (final data due date, third party accreditation deadlines, internal deadlines for annual reporting, how long does your legal team need to vet the response, etc.) Think about the potential roadblocks that might get in the way and plan accordingly—in our experience, internal review, as well as data collection and auditing, tend to be two key roadblocks that can pop up at the last minute so it’s important to build in buffer time.    

4. WHO is accountable?  

Sustainability reporting is a cross-functional process, which means there are a lot of moving parts that may involve many team members across an organization. It’s important to get on each team’s calendar quickly and set accountabilities at the very beginning. 

Thinking About More Than the Deadline 

Now, let’s get to the timeline. As we said previously, the final reporting deadline should not be your sole focus. It is never too early to start planning. Let’s start with some assumptions and move into main areas of focus, beginning with what you can start doing now. 

Download the timeline to follow-along with the more in-depth explanations of the ESG reporting cycle below.  

This timeline and following recommendations are assuming the following: 

1. Company fiscal year ends on December 31. 
2. Company releases ESG reports in Q2 
3. Reporting timelines for third-party frameworks (CDP and CSA) are subject to change based on adjustments announced by scoring organizations.  

Note that if any of the assumptions do not hold for a specific company, the timeline/calendar can be updated to align with the company’s 10-K filing, proxy season, and ESG report development.   

Q4 2021 Activities – October through December 

Build Your Reporting Timeline 

The first activity you can start on NOW is identifying your reporting needs. You need to identify reporting frameworks and disclosures that are most relevant to your business. Will you be releasing an ESG report? Are you planning to align your report with Global Reporting Initiative (GRI) or SASB standards? Do you intend to complete a TCFD disclosure? Are you planning to submit response to CDP or CSA? Build a schedule for reporting and align with key decision-makers to ensure adequate support for reporting activities.  

You should confirm timelines for general reporting (e.g., ESG report, 10-K, annual report, and proxy statement) especially those which your business is planning to integrate ESG narratives into disclosures.  

Identify Internal Stakeholders 

The next activity that can happen in Q4 the year before your reporting is due is identifying key stakeholders. Think about people who are or may need to be involved in ESG reporting (e.g., marketing, legal, operations, procurement, etc.). These people may have responsibilities relating to management oversight, data monitoring, or implementation across activities connected to ESG topics. Find your internal ESG champions.   

Define Material ESG Topics 

You will need to work with stakeholders to understand and define what ESG topics are most materially relevant to your business. You can conduct a comprehensive Materiality Assessment or leverage existing tools such as the SASB Materiality Map.   

The next activity is assigning working groups. Consider creating ESG working groups for developing ESG narratives and strategies. The working groups can be divided up based on prioritized ESG topics or goals if you have any.  

Develop ESG Insights 

You can start the process of collecting data. Work with internal data owners to pull data for ESG metrics relevant to your material ESG topics. Common reporting metrics include fuel and energy usage, greenhouse gas emissions from operations, water usage, diversity and inclusion metrics, etc. Once you publicly report your data, you’ll be expected to update data through continued reporting, so make sure the metrics you have identified are most meaningful to your business and stakeholders.  

Next you can start to conduct analyses. Work with specialists to initiate ESG risk and opportunity assessments using information from datasets and observations on regulatory and macroeconomic trends. Integrate analysis results into narrative development and strategic planning for disclosures and enterprise risk management.   

Q1 2022 Activities – January through March 

Compile ESG Resources 

In the first part of 2022, you can get ahead with your planning by starting to aggregate resources. Map out available data, policies, strategies, and goals for developing reporting narratives. Identify gaps and areas of improvement for enhancing the quality and coverage of available information. If there is documentation that you anticipate will be needed as supporting documents (e.g., a supplier code of conduct), ensure the content will sufficiently meet any framework or disclosure expectations.  

Continue to gather relevant data points associated with reporting needs. As needed, conduct internal review to ensure the quality and completeness of data inventories. During this time, you should be completing all calculations and analyses required for questionnaire submission. For instance, complete a GHG emissions inventory using fuel and energy use data collected in Q4 2021 and Q1 2022.  

Planning for Specific Reporting Frameworks (CDP & CSA) 

Specifically for CDP, January or February is when CDP questionnaires guidance is released. Review and understand the latest reporting requirements relating to the disclosures and modules that you are planning to complete. Sometime in Q1 or Q2, S&P Global sends out invitations to large publicly traded companies to participate in the Corporate Sustainability Assessment (CSA). The results of this assessment are fed into the DJSI and S&P ESG Index series. 

Planning for General Reporting 

During Q1 of 2022, you can start planning for general reporting by developing content. Work with internal leaderships to develop ESG messaging and narratives in public filings and other reports. Go through internal review, audit, and approval process for ESG content to be included in the disclosures. During this time, you should also release filings and reports (e.g., 10-K, annual report) and track progress against your goals. If you have set any ESG goals or targets in the past few years (e.g., emission reduction targets, increased diversity, equity, and inclusion metrics), track progress against these goals year-to-date (YTD). Progress should be used as part of your 2022 reporting cycle. 

Q2 2022 Activities – April through June 

Planning for Specific Reporting Frameworks (CDP & CSA) 

After compiling all your resources and information, this is the time to start writing your narratives. Work with internal stakeholders to draft responses to questionnaires and begin internal review. During Q2, CDP’s online response system opens. Companies can begin submitting responses at this time. Also, during this same time, the CSA questionnaire reporting platform opens, and companies can begin submitting responses.  

Planning for General Reporting 

During Q2 of the reporting year, you want to finalize and release Q2 filings (e.g., proxy statement, ESG report) and communicate with stakeholders/shareholders on the reported content.  

Q3 2022 Activities – July through September 

Planning for Specific Reporting Frameworks (CDP & CSA) 

The CDP submission is typically due in late July (specific due date is subject to change each year). The CSA questionnaire submission is typically due in late July/early August (specific due date is subject to change each year).  

Planning for General Reporting 

You should continue communicating with stakeholders/shareholders on the reported content.  

Reporting Season Cooldown 

As submissions are due this quarter, you want to plan for a “reporting season cooldown.” Conduct cooldown meetings with internal and external stakeholders. You want to be able to discuss the process when it is fresh in your minds and identify areas for improvement in the next reporting cycle. 

Q4 2022 Activities – October through December 

Planning for Specific Reporting Frameworks (CDP & CSA) 

CDP typically releases scoring results by the end of the calendar year. CSA results will also be available around this time and be integrated into S&P’s the publication of S&P Global ESG Scores and rebalancing of DJSI and relevant ESG indices You will want to review both scoring results and identify areas of improvement.  

Planning for General Reporting 

Now that the scores have been released, it will be time to start the initial planning for the next reporting cycle. You want to confirm any changes of reporting requirements, themes, and structures of the reports for the next year.  

You will want to determine if there were any major changes to the company during the previous year (e.g., mergers, acquisitions, divestitures) that will impact data collection and reporting and start to aggregate resources. Assess the availability of new data/policy/strategy/goal that will be used for 2023 reporting. Identify gaps and areas of improvement for enhancing the quality and coverage of available information.  

Then, you can start to initiate data collection as the cycle starts all over again for the next reporting season. 

Our best advice is to plan ahead and get a process in place so you don’t get caught doing everything last minute before reporting deadlines. With so many deadlines and competing priorities, it is critical to make a plan, identify the team, and break everything down into manageable tasks in order to orchestrate and complete a polished ESG story that meets your reporting objectives and stakeholder needs. 

Feeling the ESG reporting stress even with a detailed timeline? Reach out to our sustainability reporting experts for support.   

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