Impact assessment

Aligning gender-related activities to EU regulations: an overview of EU reporting and disclosure topics, January 2025

Published 27 March 2025

Objectives of the report                                   

This report aims to demonstrate how businesses and organisations can enhance their gender reporting against current EU reporting metrics. It has been compiled by sustainability experts on the Work and Opportunities for Women (WOW) programme, which is funded by the UK Government’s Foreign, Commonwealth and Development Office (FCDO).

This report summarises the key sustainability reporting regulations which impact (or will soon impact) entities based in, or trading in, the European Union (EU). The key regulation discussed in this report is the EU Corporate Sustainability Reporting Directive (CSRD), which encompasses a wide range of ESG topics. Other, more specific, regulations have also been highlighted, such as the EU Corporate Sustainability Due Diligence Directive (CSDDD), the EU Regulation on Deforestation-free Products (EUDR), and the EU Sustainable Finance Disclosure Regulation (SFDR).

Reader notes

(a) This report is accurate as of January 2025. (b) This report is not a statement of UK Government policy. Rather, it is a piece of guidance which can be used to support organisations with their current and/or future reporting commitments.

Why is this important?

Organisations should report on gender-related activities that not only mitigate risks but also create meaningful opportunities for women, whether as employees, within their value chains, or in the communities impacted by their business activities.

A key reason for gender-related reporting is compliance; many sustainability reporting regulations, such as the CSRD and CSDDD, now incorporate gender and human rights disclosures within their mandatory criteria. For example, all companies subject to CSRD must disclose the gender composition of their Board. As such, for many entities, sharing information on gender metrics and activities is now a legal requirement.

However, motivations for reporting on gender-related activities ought to go beyond mere compliance.

On the one hand, effective gender-related reporting can provide organisations with a strategic advantage. For example, disclosing gender-related activities which either prevent gender-based risks or promote gender-positive impacts can enhance an organisation’s attractiveness to socially conscious investors who are looking to prioritise gender equality as part of their own ESG goals, and who need to account for gender-based risks as part of their own regulatory requirements. Gender- related disclosures also enable organisations to highlight their innovations and therefore position themselves as front runners in the market, thereby enhancing their reputation and brand amongst consumers. On the other hand, these reporting requirements have been introduced to not only improve transparency in ESG activities, but to turn disclosure into a powerful driver of positive change. Effective gender-related reporting can therefore encourage businesses to undertake effective gender-related activities which have a positive societal impact, especially in the context of women’s economic empowerment.

It is within this context that this report offers key insights into how organisations can use current EU sustainability reporting regulations to showcase their commitment to gender equality and women’s empowerment.

How do gender-related activities align with EU reporting regulations?

CSRD

The CSRD comprises 12 European Sustainability Reporting Standards (ESRS). Two of these standards (ESRS 1 and ESRS 2) are cross- cutting. As such, they require organisations to report on central business information, such as gender representation at Board, as well as supply chain information, such as ‘actions to prevent, mitigate and remediate actual and potential sustainability impacts.’ The remaining 10 standards (ESRS E1 – E5, ESRS S1 – S4 and ESRS G1) are subject-specific and are only applicable to an organisation if proven to be material. It is within these standards that organisations can report any further gender-related efforts.

CSDDD

The CSDDD comprises 39 Articles which require organisations to identify and address adverse human rights and environmental impacts in their own operations, and within their supply chain. Whilst CSDDD does not specifically mention gender, organisations have an opportunity to report against gender-based actions under six key articles (Articles 8, 10, 11, 13, 14, 15). Against these articles – which focus on identifying, assessing, preventing, monitoring and ending adverse impacts – organisations can report gender-related efforts such as advancing women’s employment opportunities, and supporting equal pay for equal work.

SFDR

The SFDR is intended to increase sustainability transparency amongst financial institutions (such as banks, insurers and asset managers) operating within the EU. Certain requirements within the SFDR relate to human rights topics. For example, for select organisations, the SFDR mandates reporting on gender pay gaps and gender diversity at Board. Non-EU entities will be affected by SFDR indirectly through EU subsidiaries, provision of services and market pressure. Similarly, entities outside of the financial sector will also be affected by SFDR, as it is fair to assume that alignment with these requirements will increase their access to funding opportunities from investors who are, themselves, reporting against this regulation.

EUDR and EU Forced Labour

The EUDR requires large companies trading in seven key commodities (cattle, cocoa, coffee, oil, palm, rubber, soya, wood) to conduct extensive due diligence on their supply chains. The regulation has been introduced to limit the EU market’s impact on global deforestation, and to protect human rights and the rights of indigenous people. Meanwhile, the EU Forced Labour Regulation – which will prohibit the sale, import and export of any good made using forced or child labour – will apply to products across all sectors. Whilst neither regulation makes explicit reference to gender, nor does it require the level of reporting as the previous regulations, it is important for organisations to be aware of these requirements, given the inherent gender-specific risks associated with each topic.

In the text below, a brief description has been provided for each regulation, alongside a high- level summary of the associated gender references – both implicit and explicit. The regulations have been ordered to demonstrate the scope and importance of gender-related reporting requirements relevant to each regulation.

EU Corporate Sustainability Reporting Directive (CSRD)

Description

The CSRD is a requirement for certain companies to include, in their management report, an assured non-financial statement which outlines:

• the company’s impact on sustainability and
• the ways in which sustainability affects the company’s development, performance and positions

Applies to:

• large EU companies that meet 2 of the 3 following criteria for 2 consecutive financial years:
  • over 250 employees and/or
  • over €25 million in balance sheet assets and/or
  • over €50 million in net turnover
• non-EU companies with large subsidiaries/branches and substantial activity in the EU (€150 million+ generated in the EU)
• large undertakings and small-to-medium sized enterprises (SMEs) listed on EU-regulated markets
• certain financial institutions

Status

The CSRD entered into force on 5 January 2023 by the European Commission. However, the implementation dates are staggered according to the size, type and domicile of in-scope companies.

The first group of companies to report will be required to do so in 2025 for calendar year 2024.

The CSRD ESRS were finalised in July 2023. EU Member States had until 6 July 2024 to transpose the CSRD into national laws. However, several countries missed this deadline. As a result, member states cannot penalise organisations within these areas for late disclosure until the directive is transposed into national law. Nevertheless, it is advised that entities comply with original timelines to avoid reputational risk.

Direct gender references

Companies subject to the CSRD must report according to the European Sustainability Reporting Standards (ESRS). These standards include several gender-related disclosures.

It is mandatory for all companies subject to the CSRD to disclose the composition and diversity of their Board, including percentage by gender and any other aspects of diversity that the company considers relevant.

If material to them, companies will have to disclose matters such as “equal treatment and opportunities for all, including gender equality and equal pay for work of equal value, training and skills development, the employment and inclusion of people with disabilities, measures against violence and harassment in the workplace, and diversity”.

If material to them, companies will have to disclose details regarding “gender diversity at top management and the number of members of the under-represented sex on their boards,” as well as the implementation of gender diversity policies.

If material to them, companies will have to disclose the “percentage gap in pay between male and female colleagues, this may be broken down by employee category, country etc.” Any actions taken to rectify the gender pay gap must also be disclosed.

Indirect gender references

In addition to direct gender references outlined in the previous column, organisations can also report against gender-related activities through the following requirements:

Mandatory reporting requirements under ESRS 1 and 2 that all companies subject to CSRD have to report against:

• MDR-A: actions taken and/or planned to prevent, mitigate and remediate actual and potential sustainability impacts. This could include any gender-related activities aimed at preventing or mitigating gender-based risks, negative impacts, or alternatively any actions promoting positive gender impacts such as gender equality and women’s empowerment. Additionally, including women as part of wider climate mitigation initiatives could also be reported here. Women’s involvement in climate action has proven to be integral to successful climate outcomes, addressing both environmental and social impacts which aligns with this area of reporting
• MDR-M: metrics used to track the effectiveness of aforementioned prevention, mitigation or gender equality initiatives. This would include any gender disaggregated data that is collected by the organisation to monitor these gender-related activities. Efficiencies could also be made in relation to wider climate mitigation activities that incorporate gender aspects. Initiatives such as these have the ability to create metrics meeting both environmental and social targets referred to in MDR-T
• MDR-T: targets used to assess the impact of sustainability-related actions and policies put in place under MDR-A. These would be linked to the metrics set out in MDR-M, using gender disaggregated data to understand whether gender-related targets such as gender pay gap, number of women in leadership roles and other relevant goals have been successfully met

Topical reporting requirements under ESRS E, S and G that are applicable if proven material to an organisation:

• ESRS E1-3 and E4-3: organisations should describe the actions and resources put in place for climate change mitigation/adaptation and activities contributing to biodiversity and ecosystems in relation to policy objectives. Activities aimed at improving women’s leadership in climate mitigation/adaptation and biodiversity activities, could be reported under this requirement, as it has been shown that their involvement leads to more successful outcomes. Therefore, these activities could be highlighted as a key part of climate mitigation, adaptation and biodiversity action plans

• ESRS S2-4 and S2-5: organisations should describe the actions taken and/or planned, alongside relevant targets, to prevent or mitigate material negative impacts and advance positive impacts on value chain workers. This disclosure will include reference to women within an organisation’s supply chain, therefore any gender-related activities to reduce negative impacts or promote positive outcomes for women within the value chain could be reported against under this requirement. Additionally, organisations could also report on how they have involved women as part of wider climate mitigation activities that are already in place as part of their net zero/decarbonisation strategies

• ESRS S3-2 and S3-3: organisations should describe their processes for engaging with affected communities about the actual or potential impacts of their activities and explain how the views of these communities are considered in decision-making processes. Disclosures also require organisations to outline channels that have been created for affected communities to raise concerns and the remediation processes in place to address negative impacts. Under these requirements organisations will be able to include any specific processes in place that ensure women within these affected communities are able to contribute their perspectives throughout defined communication channels. Organisations can also show how gender-specific concerns or issues that are raised can be addressed through these channels

• ESRS S3-4 and S3-5: organisations should disclose how they address material impacts on affected communities and any actions taken to mitigate/manage risks and pursue opportunities for these groups, including relevant targets associated with these activities. Any gender-related activities that contribute to the mitigation of gender- based risks or support positive opportunities for women in affected communities could be reported under this disclosure requirement, alongside gender-disaggregated data collected to support the monitoring of specific targets

EU Corporate Sustainability Due Diligence Directive (CSDDD)

Description

A legal duty for large companies active in the EU market to identify, prevent and mitigate adverse human rights and environmental impacts connected with a companies’ own operations, subsidiaries and chain of activities.

Applies to:

• companies operating in the EU with more than 1,000 employees and a turnover of more than €450 million
• franchise chains and license-based companies, if their royalty income exceeds €22.5 million and a global turnover of more than €80 million
• parent companies operating in the EU, if the group has more than 1,000 employees and the group’s turnover is more than €450 million
• non-EU companies with a turnover of more than €450 million generated in the EU or ultimate parent companies of a group that reached that threshold

Status

The European Parliament approved the final text on 24 April 2024. The final document was then published on 5 July 2024. Member states must transpose the Directive into national law by July 2026.

After the CSDDD has been transposed into member state laws, then companies who are within scope and located in these states will have to start report against the CSDDD requirements.

Direct gender references

The CSDDD regulation generally focuses on broader human rights, and thus does not include specific reference to gender activities. However, gender-related activities could be indirectly reported under various disclosures, as outlined in the next column.

Indirect gender references

The main CSDDD requirements under which gender-related activities could be reported include:

• Article 8: organisations should identify and assess actual and potential adverse social and environmental impacts arising from their own operations and value chain activities. Within this reporting requirement, organisations can include activities such as gender and social inclusion (GESI) analysis or any studies that have been carried out to understand the social and gender-related issues within an organisation’s operations and supply chain. Any monitoring activities that collect gender-disaggregated data could also be appropriate to cite here
• Article 10: organisations should report on measures used to prevent, or adequately mitigate, potential adverse social and environmental impacts, in addition to supporting Small and Medium-sized Enterprises (SME) within the value chain, to enable access to capacity-building, training or upgrading management systems, and where appropriate providing financial support. Under this disclosure requirement, organisations would be able to report against any gender-related training that has been facilitated by the entity to support the prevention and mitigation of adverse human rights impacts, such as the unequal representation of women within stakeholder engagement. Organisations could also report on other more practical initiatives, such as encouraging and facilitating women to take on leadership roles within the community, or through supporting women-led enterprises in the value chain
• Article 11: organisations should take appropriate measures to bring actual adverse impacts that have been identified to an end. Where actual adverse impacts cannot be brought to an end then measures should be in place to minimise the extent of the impact. Any gender- specific actions that have been put in place to tackle issues such as gender pay gap, equal employment opportunities and other relevant gender risks within an organisation’s operations or supply chain could be reported under this article
• Article 13 and 14: organisations should take appropriate measures to carry out effective engagement with stakeholders, providing them with relevant and comprehensive information to undertake effective and transparent consultations. Additionally, entities must ensure that they have accessible complaints procedures to persons that have legitimate concerns regarding actual or potential adverse impacts. Any activities that encourage the involvement of women within consultations and decision-making processes or provide an accessible communication channel for women to voice specific gender-related perspectives or concerns would be appropriate for disclosure under this requirement
• Article 15: organisations should carry out periodic assessments to assess implementation and monitor adequacy and effectiveness of the actions put in place to prevent/mitigate adverse social and environmental impacts. Under this reporting requirement organisations can disclose any monitoring procedures in place to collect gender-disaggregated data and how this is used to assess the success of gender-related initiatives that have been implemented

EU Sustainable Finance Disclosure Regulation (SFDR)

Description

The SFDR is a transparency framework which sets out how financial market participants must disclose sustainability information.

Applies to: financial market participants, financial advisors and some financial products within the EU.

Status

SFDR was brought into effect on 10 March 2021 by the EU Commission.

Direct and indirect gender references

Within the SFDR, financial market participants and advisors that consider and disclose Principal Adverse Impacts will need to report on human rights topics such as gender pay gaps and board gender diversity. Beyond this, there is minimal inclusion of direct gender-related reporting.

However, the SFDR aims to help investors make informed decisions by providing information about the sustainability characteristics of financial products, which would include any gender-related activity implemented to prevent gender-based risks or support positive gender opportunities.

Indirect gender references within the SFDR are included within the classification of Article 8 and 9 financial products which promote environmental & social characteristics, thus including gender-related activities. If an organisations’ initiatives align with the requirements outlined in Article 8 & 9 classifications of the SFDR, it can be assumed that they would be more likely to gain funding as they would be classified as promoting sustainable benefit impacts.

EU Regulation on Deforestation-free Products (EUDR)

Description

Promotes the consumption of ‘deforestation-free’ products and reduces the EU’s impact on global deforestation and forest degradation.

Applies to: any person importing, placing on the market, exporting or trading in the supply chain of cattle, cocoa, coffee, oil palm, rubber, soy, and wood, and resulting products (for instance certain paper) in the EU will have obligations, which vary by company size and position in the supply chain.

Status

The Regulation entered into force on 29 June 2023 by the European Commission. Operators and traders will need to start complying with the EUDR on 30 December 2025. Micro and small enterprises will have to comply from 30 June 2026.

Direct and indirect gender references

Gender is not the central focus of the EUDR regulation. However, organisations do need to state that products meet ‘relevant legislation of the country of production’, which will include human rights and labour laws that refer to gender. Nonetheless, specifically reporting on initiatives aimed at preventing or mitigating gender-based risks or those promoting positive gender outcomes would not be aligned to EUDR requirements.

Despite this, it is important for organisations to be aware of the EUDR as combatting deforestation is inherently linked with local communities in an organisation’s supply chain. Without working with local groups, and particularly local women, mitigating deforestation and forest degradation will not be successful in the long term.

EU Forced Labour Regulation (Political Agreement)

Description

Prohibitions on placing and making available any products made with forced labour on the EU market or exporting from the EU market.

Applies to: all companies placing or making available or exporting goods in/from the EU.

Status

On 5 March 2024, the European Parliament and the European Council reached a provisional agreement on the text. On 13 March 2024, the European Council approved the adoption of the Regulation. The Regulation was published in the Official Journal of the EU in November 2024 and was brought into force on 13 December 2024.

Direct and indirect gender references

Although this regulation does not require specific gender-related reporting, it is important to be aware that the EU Commission will now provide a public website sharing information on sex-and age-disaggregated data for products traded in the EU, including any reasons for banning the trading of these products due to forced labour activity.

Due to this, it is important for organisations trading in the EU to be aware of this regulation and have actions in place to mitigate and prevent any potential forced labour risks, including any gender-specific risks associated with this activity. Reporting on any risk mitigation actions or activities promoting positive work environments for women could therefore support an organisation to prove their products do not involve forced labour.

This text below provides a non-exhaustive, illustrative list of the types of gender activities that a company might be supporting in its supply chain, and hence, may be able to report against.

Prevent gender inequality

• using sex-disaggregated data to understand the number of women participating in project/community engagement/value chain roles. This data might be gathered by a third party (ie via auditors), or directly by the company alongside implementing partners
• gender mapping of projects/value chains to assess the numbers of women and the levels of inequality within the value chain. This might be part of a wider socio- economic assessment or Human Rights Due Diligence assessment
• campaigning or lobbying for changes to laws or practices which prohibit gender equality in a particular supply chain (eg land titles, or women’s rights to hold bank accounts)
• adopting gender-sensitive living wage projects and programmes, including with suppliers
• implementing, sourcing and procurement targets to buy from women owned enterprises and suppliers.

Mitigate impacts of gender inequality

• assets: enhancing women’s access and control over assets, eg encouraging their participation in Village Savings and Loans schemes, and/or supporting their access to digital or mobile money
• skills/training: delivering financial skills or business/ entrepreneurship training, as well as wider health or literacy programmes which enable women’s participation in the labour force
• work: setting targets to increase women’s ability to participate across the supply chain including in supervisory, management and other higher paid jobs
• access to products and knowledge: supporting women’s access to alternative energy sources, climate smart agriculture training, drought resistant seeds etc
• social norms: supporting efforts to address unpaid care responsibilities to enable greater participation by women in projects/training/jobs
• actions to address gender-based violence and harassment (GBVH) in projects or workplaces
• actions to engage men and boys in support of gender equality

Remediate abuses of gender inequality

• establishing workplace or community forums to enable workers to input/hold employers accountable on a variety of issues including pay, representation and GBVH (eg Community Development Forums or Worker- Management Committees)
• establishing GBVH policies and practices in workplaces
• designing and implementing action plans to address gender pay gaps across the organisation and report on progress

Disclaimer

This document is an output from a project funded by UK aid from the UK government. However, the views expressed, and information contained in it are not necessarily those of or endorsed by the UK government who can accept no responsibility for such views or information or for any reliance placed on them. This publication has been prepared for general guidance on matter of interest only and does not constitute professional advice.

The information contained in this publication should not be acted upon without obtaining specific professional advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication, and, to the extent permitted by law, no organisation or person involved in producing this document accepts or assumes any liability, responsibility or duty of care for any consequences of anyone acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.