After spending years helping organisations navigate ESG reporting, I have noticed something that has become increasingly difficult to ignore. Every year we become better at measuring carbon emissions. At the same time, we build an ever larger industry dedicated to measuring them. Strangely, almost nobody asks what the footprint of that industry looks like.
This is not an argument against ESG reporting. Quite the opposite. Transparency is essential. Investors deserve reliable information and companies should be held accountable for their environmental impacts. But accountability should apply to the entire system - including the people and processes responsible for producing it.
The first thing that strikes me is the sheer scale of the reporting ecosystem. Sustainability teams have grown. Consultants have multiplied. Assurance providers, software vendors, framework specialists, and auditors all play important roles. Add conferences, workshops, verification visits, and international travel, and the reporting process starts to resemble an industry. None of this is free from an environmental perspective. It consumes energy, mobilises thousands of professionals, and generates emissions that, ironically, are rarely measured.
The second issue is duplication. I have seen organisations produce essentially the same information in multiple formats for different frameworks, questionnaires, and stakeholders. Each request makes sense when viewed in isolation. Together they create a system where effort is repeatedly spent reformatting, validating, and assuring largely identical data. We have become remarkably good at reporting, but I am not convinced we have become equally good at simplifying.
Finally, there is the question of materiality. Sustainability professionals spend countless hours deciding which impacts are significant enough to disclose. That is exactly as it should be. But at what point does the reporting infrastructure itself become material? If the combined footprint of reporting teams, assurance activities, digital platforms, and travel reaches meaningful levels, should we not apply the same standards of transparency to ourselves that we ask of everyone else?
I am not suggesting we report less. In fact, I suspect reporting will only become more important as regulation evolves and investors demand greater consistency. What I am suggesting is that good governance begins with intellectual honesty. Every system has a cost, including systems designed to improve sustainability.
Perhaps the next evolution of ESG reporting is not another framework or another disclosure requirement. Perhaps it is something much simpler: measuring the environmental footprint of the measurement process itself. If we truly believe that what gets measured gets managed, then maybe it is time the reporting industry turned that principle on itself.