Sustainability Reporting in the European Union and Australia: A Comparative Analysis of Regulatory Frameworks and Reporting Practices

This thesis provides a comparative analysis of sustainability reporting frameworks in the European Union and Australia, examining both their regulatory foundations and their practical implementation. The study focuses on the European Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), and compares them with the Australian Sustainability Reporting Standards (AASB S1 and AASB S2), which are aligned with the ISSB global baseline. The research first outlines the historical evolution of sustainability reporting, from voluntary frameworks such as the GRI and TCFD to the emergence of mandatory and internationally harmonized standards. Particular attention is given to key conceptual pillars, including materiality (with a distinction between impact, financial, and double materiality), value chain disclosures, interoperability, and sustainability assurance. The core of the thesis consists of a systematic comparison between the EU and Australian regulatory approaches, highlighting differences in scope, implementation timelines, materiality assessment, thematic coverage, and assurance requirements. The EU framework adopts a double materiality perspective, integrating both inside-out and outside-in dimensions, while the Australian system primarily reflects a financial materiality approach aligned with ISSB standards. An empirical analysis of selected corporate sustainability reports from both jurisdictions complements the regulatory comparison. The analysis evaluates reporting practices across specific criteria, including materiality assessment processes, ESG-linked executive incentives, Scope 3 emissions disclosure, net-zero commitments, human rights due diligence, assurance type, and report structure The findings reveal both areas of convergence and structural divergence, reflecting distinct regulatory philosophies and policy priorities. The thesis concludes by discussing the practical implications for multinational companies, the transition challenges of the Australian reporting system, and potential future developments toward greater global harmonization in sustainability reporting