The research methodology was designed drawing from the leading reporting standards and frameworks and putting them in relation with the requirements introduced by the EU Non-Financial Reporting Directive and related guidance. The research methodology is built on six elements:

  1. Assessment of sustainability-related disclosures concerning company overall business models and governance.
  2. For the four broad sustainability areas outlined in the Directive, the methodology identifies concrete issues for which there exists specific-enough guidance in international standards. These include:
    1. Climate Change
    2. Use of Natural Resources
    3. Pollution
    4. Waste
    5. Biodiversity and Ecosystem Conservation
    6. Employee and Workforce
    7. Tax Transparency
    8. General Human Rights Disclosures with additional criteria for:
      1. Supply Chain Management
      2. Impacts on indigenous rights and communities
      3. High Risk Areas for Civil and Political Rights
      4. Conflict Resources
      5. Data Protection
    9. Anticorruption Policies
    10. Whistleblowing
  3. In the EUKI research - evaluation of sustainability reporting of 300 companies in Central, Eastern and Southern European companies in 2020 - the methodology focused specifically on Climate Change, Use of Natural Resources, Pollution, and Biodiversity and Ecosystem Conservation.
  4. For each issue, the methodology provides an assessment of whether the information provided on policies, their outcomes, risks and KPIs (which is the type of information required by the Directive) allow understanding of the individual situation of companies.
  5. Within these categories the methodology provides additional qualitative assessment criteria derived from leading reporting standards. For example, in the climate change section, the methodology looks into the alignment of company policies with the goals of the Paris Agreement, of risk descriptions with the Recommendations of the Task Force on Climate-Related Financial Disclosures, and of KPIs with the Greenhouse Gas Protocol methodology.
  6. Individual sectors are assigned relevant sustainability issues by means of a materiality matrix. Key elements concerning disclosures on climate change, employee and workforce matters, general human rights matters, and anti-corruption matters were examined in each sector.
  7. A separate set of questions is provided to examine information on sustainable business activities and sources of opportunity. This inquiry is aligned with the objectives and approach of the EU Sustainability Taxonomy.
Basis for the assessment criteria
List of standards, frameworks, guidance and resources considered in the development of the research methodology

European legislation and guidance:

  • EU Non-Financial Reporting Directive
  • European Commission’s guidelines on non-financial reporting
  • European Commission’s updated guidelines on reporting climate-related information
  • EU Eco-Management and Audit Scheme (EMAS)
  • Conflict minerals or supply chain transparency regulation

Standards and reporting frameworks:

  • FSB’s Task Force on Climate-related Financial Disclosures recommendations (TCFD)
  • UN Guiding Principles on Business and Human Rights (UNGP)
  • UN Guiding Principles Reporting Framework
  • Global Reporting Initiative Standards
  • SASB standards
  • UN Global Compact
  • CDP
  • World Federation of Exchanges ESG Guide & Metrics
  • NASDAQ ESG Reporting Guide
  • ILO Tripartite declaration
  • OECD Guidelines for Multinational Enterprises and associated OECD Guidances for general and sectoral due diligence
  • Corporate Human Rights Benchmark
  • Future-Fit Business Benchmark
Scope of the research 2019 EU Research

The countries included in the scope of the analysis represent the diversity of economic regions in Europe.

The 1000 companies included in the scope of the research have been selected from 11 sectors to ensure the relevance and representativity in the countries and markets assessed.

Similarly, the scope includes some of the biggest companies by market capitalisation as well as other companies from the lower tier falling under the scope of the EU NFR Directive. The logic behind this decision is that even if the largest companies have a bigger effect on society and the planet, smaller companies must also fulfil their obligation to report on sustainability issues to their stakeholders.

2020 EUKI Research

All 300 companies included in the scope of the research are from Southern, Central and Eastern Europe to provide more in depth information on reporting practices in European regions that are more reliant on carbon-intensive industries and where non-financial reporting is lacking.

For similar reasons, the companies were selected from 6 most important sectors from the climate change mitigation and adaptation perspective, including in particular Energy and Finance.

All companies received their individual assessment and were invited to provide feedback. Their comments were taken into account if the information provided was correct and followed the methodology designed for the project’s research.

Documentation: Which company resources have been analysed?

The project analysed the information disclosed in the corporate annual or sustainability reports as well as any document or set of information clearly linked in these statements.

The rationale behind this decision follows the principles of the EU NFR Directive and accompanying guidance, in which it is stated that the information should be easily accessible (i.e. “Cross referencing and signposting should be smart and user-friendly, for instance, by applying a practical rule of maximum one “click” out of the report”)

In the 2019 EU Research the project has assessed the information and reports covering a substantial part of the year 2018. In the majority of EU countries, the corporate reporting period corresponds with the calendar year, but in some other countries the reporting year at a different date. In some countries, the 2018 reports may be published as late as the end of September 2019. Therefore, in order to ensure the comparability of information, the project did not take into account reports from companies who have already published information covering 2019.


A majority of sustainability-related disclosures require predominantly a qualitative assessment which is inherently subjective. Furthermore, despite the project’s rigorous review mechanism, the complexity of the research implies inevitable errors and oversights. The scale of the research ensures that such errors do not significantly affect the aggregated data, but we do not recommend the use of assessment of individual companies to inform the decision-making of any stakeholders other than the companies themselves. The research has not been designed for this purpose.

We would like to thank those companies who have kindly responded to our request for feedback and helped us to correct errors in our assessment of their reports.

Frank Bold and Sustentia take responsibility for any error or inaccuracy in the 2019 EU Research and presentation of results. With regards to the 2020 EUKI Research, Frank Bold Society and Frank Bold Fundacja (Polish branch) implemented the research and take responsibility for any mistakes or omissions.

The assessment criteria employed in this research do not intend to represent a definitive or final model of best practices or legislation. They were designed to provide a general overview of how companies in specific sectors reported on some of the most important environmental and social issues. The organisations forming part of the Alliance for Corporate Transparency have engaged in the project on a pro-bono basis contributing to the design of the research methodology and overall strategy.

For any questions, complaints or suggestions, please contact us at

Project development

2018 Jan-March The Alliance is formed by leading civil society organisations working in corporate sustainability and transparency that bring in specific expertise on the different areas covered by the EU Non-Financial Reporting Directive.
March - April The research methodology is developed by project partners, identifying the most essential ESG issues as well as the reporting criteria to analyse the information disclosed by companies in different sectors.
April - June The methodology is consulted on with external stakeholders and a trial run is carried out with partner companies.
June - December An initial analysis of the reports of 105 companies from three sectors (ICT, Healthcare and Energy) is carried out. The project simultaneously develops an online database. A review mechanism is set in place. The results of this initial research are presented in Brussels and submitted to the EU Commission for their review of the framework on public reporting (Fitness Check)
2019 Feb - March The project prepares for the scale up phase by consulting, reviewing and calibrating the research methodology, which is updated and simplified (further details provided below)
March - May Project partners and key external stakeholders such as standard-setters, trade unions and investor/corporate representatives provide feedback on the methodology via consultation
May - December Assessment of the information disclosed in the annual and sustainability reports of 1000 companies from 11 industrial sectors covering all EU regions
December - January Development of the front-end database
December - January Analysis of results and drafting research report.
2020 February Key findings from the 2019 EU Research are presented in Brussels
February - September Development of specific policy proposals based on the evidence gathered in the research carried out by the Alliance. These proposals are discussed with sustainability leaders from companies and investors. The objective is to build a multi-stakeholder consensus around the reform of the legal framework and development of standards
March - June Review of the research methodology applied to assess 1000 EU companies in 2019. Selection of the criteria to be applied in the 2020 EUKI research, focusing on climate, environmental and governance reporting.
September - October Analysis of results and preparation front-end database for the presentation of the 2020 EUKI research
October - December The results and conclusions from the 2020 EUKI Research are presented in Brussels and countries in Central, Eastern and Southern Europe.