A CONFERENCE BY HEC TRANSITION

Feb 12th 2026

After CSRD, how to reconcile sustainability reporting with competitiveness ? 

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In a context of backlash against ecology, marked in Europe by the recent vote of the « Omnibus package » aiming at reducing the scope of CSRD, HEC transition- the alumni club dedicated to accelerate the ecological transition- organized a conference on February 12th, gathering :

Brian Hill, Research Director at the French National Centre for Scientific Research (CNRS) , Professor in Decision Science at HEC Paris, and lead author of a policy paper published in October 2025 by the S&O center of HEC called « Squaring Disclosure Regulation and Competitiveness »

and Bertrand Eyraud, head of CSR at Kaufman and Broad, who has a practical experience of implementing CSRD.

- Download the policy paper -

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Brian Hill pointed out that the EU regulations Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD) have faced two main criticisms : even if their sustainability goal is not contested, they are said to  create a competitive disadvantage on EU firms compared to non-EU competitors, and  impose a heavy reporting burden.

He presented the innovative framework he proposes in the HEC policy paper to solve these issues: a  "Smart Product-Level disclosure" featuring :    

1 Standardized Scorecards: Each product would have a digital scorecard with objective and verifiable sustainability metrics on key indicators of environmental or social performance : for example, CO2 or biodiversity measured in kilos, forced labor measured in percentage of employees, etc…. The score card would be accessible to all including final customers, open for both consultation and input. Similar to nutritional tables (as opposed to nutritional score), it would not be a label, but could be used in labels, recommendation apps such as Yuka, and firms reporting.

2. Distributed Reporting: Firms would only report data on their own operations, while upstream data would be integrated from suppliers' scorecards, reducing the burden of tracing supply chains. 

3. Propagated Transparency: Missing data would be flagged and replaced with default « best to worst case » ranges, ensuring transparency and incentivizing firms to report without obligation: as a specialist of decision science, Brian Hill pointed out that research has shown that when other firms disclose, silence  is perceived as a negative signal.

The proposed system would level the regulatory playing field by applying disclosure requirements uniformly to all products in the EU market, regardless of origin. It also would have no or limited additional reporting cost  through automation and integration with existing enterprise softwares (payroll, cost accounting), where the data is already present. By providing stakeholders with accessible and relevant sustainability data, this innovative framework would encourage sustainable consumption and production, while promoting EU sustainability values globally.

Bertrand Eyraud shared his experience of implementing a first CSRD reporting at Kaufman and Broad for year 2025, with mixed feelings: on one hand,  the objective of standardization, transparency of CSRD are clearly good, and the exercise was very interesting in that the company had to systematically review the entire range of Ecological, Social and Governance issues, through the EFRS , realizing for instance that in the Real Estate industry, land use change or circular economy were clearly underconsidered so far; also , the double materiality was key and helpful. But on the other hand, the organisation, description and structure of disclosure requirements and implementation guidelines issued by EFRAG guidelines for assessing and reporting the risks were way too complex ; moreover, the lack of direct connection between materiality subtopics and reporting requirements made most of the 1200 « data points » required. This was very time consuming, burdensome, and costly, and will by definition give rise to long reports with repetitive narrative, whereas it would have made more sense to report on policies , actions , and targets based on a structure related to the 30 identified material impacts, risks and opportunities.

With about 700 employees, K&B was initially part of « Wave one » of companies submitted to CSRD, but it is no longer the case, as the « omnibus » package voted at the end of 2025 by the European Parliament increased the threshold from 500 to more than 1 000 employees.  A lot of work for nothing ? maybe, but, to capitalize on this work, and because the market and investors expect this  reporting,  Kaufman and Board  may volunteer to continue to issue a sustainability report in the future based double materiality approach,  hoping that the simplification of the implementation of ESRS standards by EFRAG,  currently under review, will end up with a meaningful reporting. By then, Bertrand recommends to all CSRD practitioners to keep the « big picture » in mind, specially if consultants are involved.

A dialogue followed , including the Alumni attendants , that clarified the following points : 

Brian’s proposal does not pretend to replace the current EU CSRD reporting at company level (which is anyway required by investors), but it would considerably ease the « Scope 3 » reporting on third parties on the value chain.

It could apply to all industries, including services (like Google) . 

The scope of the score cards will at least include ecological and social data, maybe governance as well. The precise indicators are still open: Brian considers translating existing objective indicators for firm level reporting into product reporting, or using those already implemented at product level by some industries, for instance Ecobalyse for textile. 

Bertrand pointed out that in France the real estate development industry, which is very regulated, already offers an example of a reporting at product level  regarding Energy Performance and carbon, through a compulsory DPE diagnosis and Life Cycle Assessment for each building and housing. All the suppliers in France willing to be involved in the new building construction market have to file a scorecard (« Fiche de déclaration environnementale et sanitaire ») for each component (door, floor, electric wire etc…), that are published on the French national INIES data base ; any missing information is replaced by a penalizing one. This system has been running efficiently for the past 4 years and is a strong incentive to ecoconception along the value chain. It should work for other industries as well, and why not add more indicators.

The Carbon Border Adjustment Mechanism (CBAM) also offers an example of calculation at product level. This EU tool, enforced starting 2026, is meant to put a fair price on carbon emitted during the production of carbon-intensive goods that are entering the EU.

The audience remarked that Brian’s proposed reporting by product would be optional, so the robustness of his proposal lies with the absence of additional reporting cost . Brian objected that if there is some cost, the company would have to balance it with the market cost of « not reporting » , and that from interviews with firms and consultants , it seems that reporting by product is in the air.  But he accepted the idea to investigate more about costs by interviewing ERP providers.

The audience challenged the optional aspect of Brian’s proposal : on an incentive, as opposed to compulsory, basis, It can take years before a majority of suppliers report by product :  then the aggregation use of Min Max default ranges along the value chain could end up in a massive uncertainty. So the speed of propagation looks critical . Brian is confident that it can go fast through the market pressure, but some regulation could be added.