We recently published a meta-assessment of 100 U.S. voluntary sustainability and impact reports from public and private companies, published over two years. None was filed under CSRD. We coded every report against the same set of fields using the same process, so the patterns reflect the reports themselves rather than which ones we happened to read most closely. [Read the full assessment here.]
Previously, we looked at what our research said about Scope 3 emissions, report assurance, and sustainability goals. This article looks at the frameworks these companies cite, and the gulf between citing one and reporting against it.
Companies are adding IFRS standards, not replacing TCFD
The Task Force on Climate-related Financial Disclosures (TCFD) published its final status report and disbanded on October 12, 2023. The Financial Stability Board asked the IFRS Foundation to take over monitoring of companies’ climate-related disclosures.
Three years later, 58 of the 96 operating companies in our sample cite TCFD. Eighteen cite IFRS S1 or S2, the sustainability and climate disclosure standards issued by the IFRS Foundation’s International Sustainability Standards Board (ISSB).
Of those 18, 15 also still cite TCFD. Only three cite IFRS without TCFD. Another 43 cite TCFD with no mention of IFRS.
In these reports, the shift from TCFD to the ISSB standards looks less like a replacement and more like an addition. That’s a reasonable approach, since the ISSB standards were built on TCFD’s recommendations. The shift is underway, though. Among reports published in 2026, 16 of 68 cite IFRS S1 or S2, compared with two of 26 in 2025. The remaining two reports in the sample were published in late 2024.
The typical report cites three or four frameworks
Across the sample, 330 reporting framework mentions appear in 82 of 96 reports. The median report cites three or four. One cites eight, and 14 cite none.
SASB leads at 62 reports, just ahead of TCFD at 58 and GRI at 57. The UN Sustainable Development Goals (SDGs) follow at 40, then CDP at 34 and the UN Global Compact at 26. Newer standards trail: IFRS S2 at 13, ESRS at 12, IFRS S1 at seven, and TNFD at four.
SASB, the investor-focused framework, is cited slightly more often than GRI, the multi-stakeholder one. In a U.S. voluntary context, that may say something about who these reports are written for.
Citing GRI usually means a looser claim
The citation counts don’t show how strong each claim is. GRI is the one framework where we can measure that, because GRI requires companies to declare how they use it. Of the 57 reports that cite GRI, 11 claim to report “in accordance with” the standards, 32 use the weaker “with reference to,” and 14 cite GRI without stating a claim.
That means roughly one in five reports that cite GRI claims full conformance. The rest describe a looser relationship. That’s a well-defined option under GRI, but a reader scanning a framework index may not distinguish it from the stronger claim.
We can’t measure this for other frameworks. Only GRI requires a declared conformance level, and our coding of other frameworks captures how they’re presented rather than how strong the claim is. That’s a limit of the data, but it also reflects the broader point: for most frameworks, the strength of a company’s claim can’t always be determined from the report.
How a framework appears says a lot about the commitment
The format of a framework mention gives a reader a sense of what’s behind it.
SASB and GRI appear mostly as content indexes, mapped tables at the back of the report: 51 of 63 SASB mentions and 46 of 58 GRI mentions take that form. (These counts are mentions rather than reports, since a few reports reference the same framework more than once.) CDP is mostly a passing reference, at 20 of 34 mentions, which makes sense for a questionnaire filed elsewhere. The SDGs appear mostly as alignment statements: 24 of 40 mentions state alignment with no index or mapping a reader could check.
TCFD is used in the widest range of ways: 25 index entries, 15 alignment statements, and 11 reports organized around it.
Framework lists mix different kinds of instruments
One finding came out of cleaning our own data. When we first coded framework mentions, 78 of 392 landed in a catch-all category. Sixteen turned out to be disclosure frameworks that weren’t on our list, including sector templates like the EEI/AGA utility reporting template, EFRAG’s VSME standard for smaller companies, and the World Economic Forum’s Stakeholder Capitalism Metrics. The other 62 weren’t disclosure frameworks. They fell into at least eight different kinds of instrument:
- Accounting standards, including the GHG Protocol, cited by 20 reports (more than ESRS or IFRS S2)
- Target-setting initiatives, such as the Science Based Targets initiative (SBTi), RE100, and Race to Zero
- Certification schemes, such as RSPO, Cradle to Cradle, and the Fair Labor Association
- Benchmarks and ratings, such as GRESB and EcoVadis
- Assurance standards
- Management system standards
- Human rights instruments
- The NIST Cybersecurity Framework, in six reports
These do different jobs. A disclosure framework guides how to report. An accounting standard guides how to calculate. A certification confirms that a third party checked a product or supply chain. A cybersecurity framework covers data security, which is relevant to some ESG disclosures but isn’t a sustainability reporting framework. Yet they often appear together, under the same heading, as frameworks a company “aligns with.”
What reporters can do, in three steps
- Separate the list. Put disclosure frameworks, calculation standards, certifications, and benchmarks under different headings, so readers can see what you’ve committed to.
- State your conformance level. If you report with reference to GRI rather than in accordance with it, say so. A clearly stated claim is more credible than an implied stronger one.
- Don’t let an index stand in for a position. A content index at the back of a report helps readers navigate. It’s not the same as organizing disclosure around a framework.
These findings come from a larger meta-assessment of all 100 reports, covering assurance, emissions, goals, materiality, and report design. [Read the full assessment here.]
Methodology: We reviewed 100 U.S. voluntary sustainability and impact reports published between September 2024 and September 2026, each coded against the same set of fields. None is a CSRD filing. Figures cover the 96 operating companies in the sample. Framework mentions are classified by instrument type, and counts here cover reporting frameworks only unless stated. Denominators vary where a field couldn’t be determined.
John Davies is the Director of Content at thinkPARALLAX. With more than 15 years of experience in journalism, editorial leadership, and sustainability communications, he specializes in sustainability reporting, thought leadership, and executive messaging.
