Environment, Social, Governance: integration is the priority

In 2023, the transition to an economy based on environmental, social and governance sustainability values can take a step forward thanks to the opportunity to integrate good practices into company processes, into the dynamics of industry internal relationships and of relationships between different industries.

In this context, the concept of "materiality" (i.e., significance for ESG) today constitutes the cornerstone of any non-financial reporting – or, better, sustainability - analysis; it is therefore necessary that it be understood by those companies that must fully integrate sustainability into their management structures, even though they are not currently subject to specific reporting obligations.

The European Union has configured a complex and stringent regulatory framework for the "sustainability revolution", which will require any country to proceed with defined times and precise methods, which will however be influenced by the operational and structural context in which this supranational regulatory framework will have to be implemented.

This revolution requires the adoption of irreversible change processes by all Italian companies, including SMEs, which are and will be increasingly affected by these transformations with regard to functions and bodies, starting from their strategy, behaviour and decisions of Boards of Directors and top management, with both internal effects and effects with respect to customers, suppliers, lenders and investors.

Therefore, starting from the Italian operational and structural context, it is necessary to better analyse the new ESG disclosure European regulatory framework and its profound consequences for Italian companies, especially SMEs, and for their strategies, their economic and financial equilibrium, and their "new" future.

Starting from the Paris Agreement (2015), which regulates the decarbonization strategy (with low carbon indicators), to the formalization of the United Nations 2030 Agenda and the EU Commission delegated acts of 21 April 2021, up to the EU Corporate Sustainability Reporting Directive, CSRD, published in the European Official Journal on 14 December 2022, sustainability has assumed an increasingly central role in the development projects of European institutions and in the strategies of the main companies and organizations according to the ambitions and objectives of the European Green Deal (December 2019). This is a new strategy that aims to transform the European Union into a fair, competitive, and carbon-neutral society by 2050. In this new context, Environmental, Social, Governance (ESG) sustainable (or "non-financial", as they were called before the CSRD Directive) aspects are expected to be increasingly more integrated into corporate reporting and financial compliance.

Italy has proved ready to align with the innovations of the international framework. Non-financial information has acquired an increasingly greater importance as a result of the mandatory reporting obligations provided by Legislative Decree 254/2016, which the sustainability policy of SMEs has been oriented to, even on a voluntary basis, towards a business model that is increasingly more careful to environmental, social and governance issues, as an essential prerogative to remain on the market.

EU Directive no. 2022/2464 concerning corporate sustainability reporting (Corporate Sustainability Reporting Directive - "CSRD") was published in the European Official Journal on 16 December 2022, which integrates and amends the provisions of Directive 2013/34/EU, concerning the obligation for large companies to report non-financial information.

The CSRD directive changes the perspective (as well as the terminology) with regard to corporate sustainability reporting, providing that sustainability information (no longer defined as "non-financial" information, as ESG issues also have a direct impact on the economic and financial results) become an integral part of the annual financial report. More precisely, the ESG factors of companies, including SMEs, must be included in the Directors’ report (and no longer in separate reports), thus also aligning overall corporate information disclosure processes.

The new obligations established by the CSRD will be applied progressively, expanding the number of concerned parties over time; however, unlisted SMEs are anyway allowed to report, on a voluntary basis, on their activities carried out in terms of sustainability. Furthermore, specific reporting standards will be introduced for SMEs, according to their needs and characteristics.

The banking system is considered as central in the transition towards a more economically and socially sustainable economy. In fact, banks are the entities that contribute financial resources to investments that can be more or less sustainable. The international and national supervisory authorities have issued a series of rules which require ESG factors to be considered in the management of a banking company.

Therefore, for a correct and complete preparation of 2023 financial statements, companies must take into account information on sustainability. By now, investors and lenders not only require the strictly quantitative data contained in the financial statements, but also other information which, although having a non-financial nature, is closely relevant to them. These are the ESG requirements and the "Sustainability Information Statement" represents their observance.

Therefore, companies will have to represent all information homogeneously and provide measurable and comparable data.