Ethics at the core of public intervention: a comparison in sustainability reporting practices in the EU and in the USA.

Abstract

This paper compares the EU and US approaches to sustainability reporting, exploring the underexamined role of public ethics in this field. By combining a comparative legal analysis with critical theory approach, the paper explores how Sustainable Development Goals (SDGs) and the concept of double materiality provide a moral and operational framework for sustainability reporting frameworks. The findings reveal a stark contrast: the EU embeds ethics into mandatory, impact-oriented reporting, while the US relies on voluntary, financially focused disclosure. The study concludes that public authorities must leverage ethical norms to ensure sustainability reporting produces measurable social and environmental outcomes.