CSRD spotlight: Making an informed decision on how to report
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Thought leadership from PWC. Whatever decision is made now, like while it might set some expectation for what would be disclosed in the future, it doesn't have to stay that way. So there is some flexibility then going forward as well because stakeholder needs might change or, you know,

Hello, and welcome back to our CSRD Essentials series. This is a series of videos that will help you get started on the next steps for reporting.

focused on giving you the latest that you need to know about the EU's mandatory sustainability reporting rules. This is PwC's Accounting Podcast. I'm Heather Horn, and thanks so much for joining us today.

For non-EU headquartered companies, assessing the scope of the CSRD has some inherent complexities. However, those complexities also come with some exemptions that may provide options for a non-EU headquartered company in developing its approach to fulfilling its CSRD reporting requirements.

And I know that's a mouthful, but basically we're here today to help you decide at what level in the organization it may make sense to report. Is it the individual subsidiaries that are in scope? Is it a holding company or group in scope? Or for your particular company, does it make sense to report at a global consolidated level to meet your initial CSRD requirements? Now,

Now, deciding which of these approaches is best will be driven by multiple company-specific factors, so you definitely will benefit from taking a methodical approach to the assessment. And in today's podcast, we're going to run through all of those factors and help you understand the various things you need to consider in making this decision because it's not one that you want to make lightly.

To help me with this conversation, I'm joined today by Emily Kirsch, a director in PwC's sustainability practice, who previously was part of my group in the national office. And my conversation with Emily goes in-depth into why what may seem simple on the surface actually needs a lot more evaluation and

and deserves management's attention as you move forward with your CSRD requirements. So Emily walks through some of the pros and cons of the different scenarios, as well as reasons why you may want to consider one approach over another, depending on your facts and circumstances. So definitely a lot to consider and looking forward to sharing with you my conversation with Emily.

Hello, Emily, and welcome back to the podcast. So nice to have you on this week for a topic that I think is increasingly top of mind for companies is what comes next once they figure out what companies are in scope. But really, as you're talking to companies, where are we sort of in the spectrum of CSRD questions?

Definitely are still getting a lot of questions around scope. So really just wanting still to understand what are the requirements? How could I be in scope in my organization? But we are seeing a number of companies turn more towards thinking about how they want to do this reporting under the CSRD.

And so they're really starting to ask questions around different reporting scenarios, understanding these reporting exemptions that exist and how they might apply to their facts and circumstances. Yeah, and I will point out that for the earliest reporters, they will be reporting on 2024 information in 2025. And considering that it's almost November 2023,

That means we are getting very, very close to when at least some companies will be reporting. So definitely, I think getting over the scoping hurdle is very important. But I think your point is a really good one, because as we think about scoping, once you figure out which companies are in scope, there are certain exemptions that a company can take advantage of.

And then once you start thinking about that, then it raises a whole plethora of questions about what the optimal reporting strategy is.

However, before we start talking strategy, maybe it would make sense to cover the exemption so people can understand a little bit more what we're talking about and maybe even give a teeny refresher of scoping itself. So for people who are relatively newer to this conversation, they don't have to go check some other podcast or publication for that. Yeah, so starting with scoping, because that is definitely a great place to start. And I would say in thinking about

assessing these reporting approaches and how the exemptions might apply, really first having a good understanding of how you're in scope is key. So there are three ways that companies can be in scope of CSRD. The first is that they have debt or equity securities listed on an EU regulated market. And it doesn't matter if it's an EU entity or a non-EU entity, if they have debt or equity securities listed, they're

with very limited exempt exceptions, then they would be in scope for reporting. Also, if you're an EU entity, so for example, an EU subsidiary of a US or other non EU company, or just an EU headquartered company, for example, that meets certain size thresholds, even if you're not listed, you'd still be required to report. And so those size thresholds are based on total assets, net revenue, and average number of employees.

Similarly, even if an entity doesn't meet those size thresholds on their own, if they're considered the parent of a large group, so the parent plus its subsidiaries meet these thresholds on a consolidated basis, they would also be in scope for reporting. All right. So, Emily, one key thing to quickly note here is if I think about those categories you just ran through, that first category, which is the listed companies, those are the ones that would be reporting in-house.

2025 on 2024 information. And then that next category, those next two categories, the quote large entities are reporting in 2026 on 2025 information. However, there is one more type of reporting. I'll use the word type of reporting, which is the reporting for the

non-EU parent company, and that is actually quite relevant for this discussion. So can you explain that requirement as well? Yeah, so there is an additional requirement. So in addition to any reporting that might need to be done at a subsidiary level for a non-EU headquartered company to report at a global ultimate parent level,

if certain criteria are met. So essentially, if they have at least one EU subsidiary that's in scope because it's larger listed, or if it has a branch that meets certain revenue thresholds, and if they generate at least 150 million euro of revenue in the EU, then reporting would be required at a global parent level on a consolidated basis.

Now, that requirement doesn't come into effect until a few years later. But as you mentioned, we'll talk a little bit more about it in a few minutes. It is a relevant consideration for thinking about the reporting approach. All right. And so then now that we have sort of the landscape of reporting, what are the exemptions that companies could be thinking about?

Yeah. So at a high level, the overall principle and the way I think about these exemptions is that for a company won't need to report on its own if it's included in a parent company's consolidated sustainability reporting. So...

Really, I tend to think about this as a subsidiary exemption. So there's a few different ways that these exemptions could apply. So you could be a subsidiary of an EU parent. So for a lot of our U.S. clients, other non-EU companies, this might be an EU subsidiary included within an EU holding company's consolidated sustainability reporting. So essentially, a subsidiary can be exempt if it's included in the consolidated management report of an EU parent.

prepared in accordance with ESRS. And that consolidated sustainability reporting would need to include all subsidiaries of that parent. The next way that it could apply is essentially if the subsidiary is included in a non-EU parent's consolidated sustainability reporting. And so that would need to be prepared in accordance with ESRS as well, or in a manner that's deemed equivalent by the European Commission, which right now we don't know what that will be.

And again, that would also need to include all subsidiaries of the parent. So both EU and non-EU.

And then the last exemption that exists, which is a bit unique, is what we call artificial consolidation. And so it's essentially kind of a special variant of the subsidiary exemption that's temporarily available for EU entities that have a non-EU parent. So essentially what it allows is for all of the in-scope EU entities and subgroups to essentially be combined into one kind of artificially consolidated sustainability report.

Now that exemption is only temporarily available, so it's only available until 2030. So at that time, either companies will need to go back to doing individual entity or subgroup reporting, or they'll need to essentially look at a higher level within the organization and report there. All right. And I think a key point that you made there is that in order to qualify for these exemptions, the reporting needs to be done in accordance with the SRS or the European Sustainability Reporting Standards.

And one of the questions we keep getting is, well, I have a lot of EU subsidiaries that are in scope, or maybe I have a EU holding company, but it makes up a big portion of my business. So maybe I should just do consolidated reporting. And perhaps one other overall consolidated reporting, and I think just one other level setting point to make here is that...

that requirement that Emily spoke about earlier in terms of the required consolidated reporting that's a few years down the road, the requirement is to report in accordance with a set of non-EU dedicated standards. So again, those are not intended to be as comprehensive as the ESRSs, although we don't know what those look like yet. So anyway, that's sort of just like another factor to keep in mind. But

And I will just add that in addition to just being included in a parent's report or doing this artificial consolidation in accordance with the SRS, there are some other criteria that have to be met too in order to take these exemptions, which I won't go into detail on all of those, but do just want to highlight that there are some other criteria as well that we won't cover in detail.

Okay, I think that's very important. So now for the audience, and again, in my mind, I can picture an org chart with a lot of entities that sort of have checks next to them because they are in scope for reporting and then maybe some holding companies that exist in this entity and then my parent company and just trying to think through what may make sense. Do I report for all those individual entities? Do I just go straight

straight to the parent and do global consolidated? Or is there something in between, whether that's artificial consolidation, that's picking one of these holding companies, or maybe I have a holding company that has to report. And so that may make the evaluation a little easier. So with all of these sort of moving parts, Emily, how do we sort of think about how to make this decision? Because definitely not something you want to jump into. I'll use the word rashly.

Yeah, so getting a really good understanding of which of the entities in your org structure are in scope and are required to report and what the available exemptions are is what we would recommend as step one.

And I will say there are certain situations where companies might not be able to take those exemptions. So, for example, if you have an entity that's both large and listed, then reporting would generally be still required on a standalone basis for that entity, standalone or group, just depending on the facts and circumstances. The other...

reason why a company might not be able to take these exemptions is that the CSRD is going through this transposition process where each of the EU member states is going to

implement it into their own national law. And so they have the ability to add additional requirements as part of that process. And so there certainly is the possibility that they could decide, well, we want information for a particular entity in our country or in this jurisdiction. And so as a result, monitoring that process is going to be important because there might be

disaggregated information required regardless in a particular country. Once you understand what exemptions either are or not available, then looking at company-specific factors, and we'll talk a little bit more about what some of those, I would say, most common ones are that we're seeing be considered or that we think are relevant to think about.

And then third, really thinking kind of more holistically and thinking a little bit past this as just being a compliance obligation. You know, how does this reporting fit into a company's broader corporate strategy around reporting objectives, you know, and thinking about those considerations as well?

And then lastly, kind of once you have an understanding of all these different pieces and facts and circumstances, you've gotten input from different stakeholders within your organization, really making sure that you understand what the trade-offs are of these different approaches is going to be key before making a decision.

All right, I think that's super helpful. And then Emily, maybe the other point before we get into the decision is that I know often when we are having these conversations with companies, there's one person driving the decision making, whether that is the chief sustainability officer, or maybe it's someone in the CFO's organization because they've been tasked with this responsibility.

And given the factors we're about to get into, probably one of the biggest points we can make here is that this is not something that should be made in a vacuum by one or even a few individuals, but there really should be a lot of different people involved. So can you just give a sense of what we're seeing in terms of who all the stakeholders within a company in this decision may be? So we're definitely seeing this.

decision-making process being a very cross-functional exercise. So utilizing whatever ESG-SIRCO might already be formed or putting one together for purposes of getting input on this assessment is definitely key. And so we've been seeing those, as you mentioned, from the sustainability team, finance and accounting, IT, investor relations, legal, others as well. I'd say in particular, those that are

going to ultimately be responsible for this reporting definitely should have a say as well because ultimately they're the ones that are going to be

signing off and responsible for this report. All right, definitely important. So then with all of that background and context, maybe we can jump into some of these factors. And for our listeners benefit, I'll say this again at the end, but Emily and I did recently publish a publication that actually runs through all of this in more detail. And so if you are making this decision, I highly recommend you check that out. But we'll also try to provide some context here that maybe you couldn't

get by just reading a publication in the background. So Emily, I think we talked through cases where you wouldn't be able to take advantage of exemptions. So let's see that now I've involved the right people. I figured out what companies are in scope. I understand what exemptions I have and I understand when I can't take the exemptions. Now what?

So I would categorize this first bucket of factors as those that relate to the availability of data and factors that are relevant to consider based on the company's organizational structure.

So maybe starting with data availability, because this is definitely a big one. You know, a lot of the information that will be reported is very data intensive. And so first, you know, understanding the availability of non-financial data available at a subsidiary level versus at a global consolidated level.

Because sustainability reporting today might already be done on a global basis or might be aggregated based on country or even at a site level, just depending on what the metric is that we're talking about. But that doesn't necessarily mean that it would be at the same level of accuracy.

entity or reporting that would be required for purposes of CSRD. So really just understanding how data is gathered today and how that translates then into how it will need to be prepared under these different reporting options will definitely shed some light into what might be kind of the most efficient way to prepare data.

The other type of data availability is availability of financial information. And we see this being particularly challenging for EU subgroups that are in scope. So like an EU holding company that historically hasn't prepared consolidated financial information because they've gotten exemptions for financial reporting purposes.

And so, you know, a lot of the metrics do require some type of financial information, such as intensity metrics. There's also the EU taxonomy reporting, which we won't go into detail today on because we could have multiple episodes just on that, which I think we will in the future.

But that is all very reliant on financial information. And so if that doesn't exist and if there's not an easy mechanism to get that information, that can create some challenges with reporting at that level. So, Emily, before you go on, let me pause you there because I do think a question that I know works.

we keep seeing come up is this idea of, okay, but I have this holdco. It's exempt from existing financial reporting requirements.

how could I have to be doing sustainability reporting if I'm not having to do financial reporting? So can you kind of close that disconnect? Yeah. So the exemptions for consolidated sustainability reporting are separate from those exemptions that exist for consolidated financial reporting. And so in concept, they're very similar in the sense that

you can be exempt from preparing this consolidated information if you're included within a parent company's reporting prepared using, you know, for financial reporting, local GAAP, IFRS, or something equivalent, which U.S. GAAP is typically considered equivalent. And so as a result, they don't need to do this subgroup consolidated reporting.

Because in your example, they're providing global consolidated reporting. Exactly. Exactly. Yeah. They'll just submit, you know, the ultimate parents consolidated financial statements and say, okay, this relieves us of our obligation to prepare sub-consolidated financial information. Right.

So in principle, that same concept, as we talked about, exists for consolidated sustainability reporting. But the challenge is that then in order for these EU subgroups to be exempt, they'd have to be included within a parent's consolidated sustainability information prepared using ESRS or something equivalent. And so because we don't know what those equivalent standards are yet, because that hasn't been determined yet,

That essentially means that the ultimate parent would, or some parent would need to prepare consolidated ESRS reporting in order to relieve these EU holding companies, which is an approach that is one of the reporting approaches, but again, would tend to bring in a lot more within the organization. Right. And we'll get more into that because that's sort of the point of this conversation. But I think that kind of gets lost in the shuffle a little because it's just,

I think for a lot of companies, they just sort of presume that they'll be able to take advantage of that. And to the point you just made, there's a lot more you need to think about. And I think we'll get more into those. So sticking though with this data availability question, and I like that you started with this because I feel like

This is sort of a level setting. If you can't overcome these hurdles, it kind of takes away some of your other options. So go ahead then with some of the other ones we think about here.

Yeah, so organization of IT systems and controls is definitely a big one as well. You know, if those are really decentralized today, it might make reporting at a global consolidated level more challenging. So that's certainly a factor that we're seeing be considered because you need to have a way to be able to gather this information and know that you can rely on the data that you're collecting.

The number of reports required is definitely a big one, too. I mean, for a lot of very large multinational companies, they might have dozens of subsidiaries in the EU that could all have their own individual reporting requirements. And so the ability to do artificial consolidation and combine those into one or report at a parent level and, again,

Have fewer reports that you need to prepare is certainly something that we're seeing companies consider just given the time and effort that would be needed to prepare multiple reports. I will say, though, just one thing to note, maybe a smaller point, but still something relevant, is that as part of this transposition process...

the EU member states might require that the reports are translated into a language that's acceptable locally. So even if you do just prepare one report, there's the possibility that it might need to be translated. So just wanted to mention that as well. Yeah. And I guess a related point that actually I thought you were going to make is that the option for artificial consolidation does go away in 2030. And so that is something for companies to think about. But

I know we'll make this point again at the end. It's worth reiterating here. This we often view as sort of that you can view this as like an on-ramp. So what you decide to do in your first year reporting doesn't mean it's what you're going to do in 2030 because you may decide, okay, well, in the first few years, I don't want to take on full responsibility.

global consolidated reporting, but maybe by 2028 when I have reporting requirements anyway, or 2030 when artificial consolidation is gone, I might want to do something different. So I just think that's an important point to make as well. This is not like a set it and forget it to use some accounting terminology type of decision. So Emily, I know there's a few more on data and organizational structure, but I think those are kind of the key ones.

So maybe we can move on to the next category, which is actually I sort of started talking about timing. So timing is a really important factor as well.

Yes. So the first time application deadlines do vary based on why companies and scope. So it's definitely possible that you could have certain entities within the organization that have to report in that first wave and others that have to report in the second wave. And so taking that into account, because perhaps if you only have one subsidiary that needs to report in that first year, you just go with that, you know, reporting at that subsidiary level and then move to something else the next year. Um,

So that's certainly a factor to consider. I think the other thing to keep in mind is that, you know, what ultimately needs to be reported will vary depending on the entities that are in scope of this reporting. And so there are certain phase-in reliefs that were given in the European sustainability reporting standards for companies that have 750 or fewer employees.

We generally expect that that employee threshold would be based on the reporting entity that's reporting, so the company that's reporting. And so in theory, the higher up in the organization you go, the more employees that get pulled in. So some of those exemptions might not be as applicable anymore if you decide to report at a global consolidated level. So something to consider.

Also, in terms of required filing deadlines, I mean, each member state and each entity might have slightly different timelines for when the statutory reporting needs to be filed. And so taking that into account as well is really important because if a territory has a three or four month deadline,

filing deadline, would you really be able to get global consolidated sustainability reporting done in that timeline? You might, but you might not. So taking that into consideration as well is important. And I think on that last point too, Emily, we've heard questions around scenarios where maybe a subsidiary has a different year end and so they may have an earlier reporting requirement. And does that mean you want to bring everyone, you know, want to have to report for everyone on that

that quicker timeline, or maybe if individual countries and their transposition give different deadlines, which I think is what you were alluding to with that sort of that three or four month timeline. Yeah. And I think some of that in terms of the timing for how that would work then, like for example, if you have an EU sub that has a shorter timeline,

filing deadline than its EU parent company. How does that exemption work? I think there's probably more to come on that. Unfortunately, I don't have an answer to that question today, but more to come. And that is certainly a very relevant question. So then, Emily, maybe moving on to sort of, I'll call it another bucket of factors to think about. One of the questions that

I've been hearing a lot as well. I'm already doing voluntary reporting at a consolidated level. And so does that just give me presumption I should keep doing that? And I know there's other considerations similar to that. So how do you think about this category? What are some of the factors? Yes, I mean, the status of existing voluntary reporting is definitely...

very relevant. You know, if you're already preparing consolidate global consolidated metrics that include every single subsidiary that you have, then it might be more efficient to just continue down that path. Um,

But I do think that there are a number of organizations where there are certain territories or parts of the organization that are more difficult to get information from today from a voluntary perspective. So there could still be some additional work or data gathering needed, even if you

you are doing some voluntary reporting today at a global level. And Emily, maybe I'll pause you there because I think that's such a critical point because there's two potential disconnects. One is that your voluntary reporting is unlikely to be currently including all of the metrics that are going to be required, obviously depending on your own scoping for ESRS.

But there's a big difference between voluntary reporting where you just make disclosures that, oh, well, this sub's omitted because we couldn't get the information or otherwise. And then these ESRS reports, which there is assurance requirements over. And so you're not going to really have necessarily the flexibility to say, I left out this whole part of my business and assert that that's in compliance with the ESRS. So

really thinking that through before you just jump to that conclusion, I think is important. Yeah. Yeah. The other factor that we're seeing companies think about is that, um,

ultimate non-EU parent reporting that we talked about that will be required in 2029 on fiscal year 2028. I think there's a general thought sometimes that, okay, well, I'm going to have to do this eventually anyway, so maybe I should just do global consolidated reporting now. But as you mentioned before, that reporting can be done using these dedicated non-EU standards that haven't been developed yet,

they're still expected to, I would say to be pretty detailed, but we do know that there are certain aspects of it that won't need to be certain aspects of ESRS that won't need to be included in those. Um,

So, you know, jumping right to that might be bringing a lot more of your organization in sooner than would otherwise be required. So that's definitely something to think about as well. All right, that's really, really helpful. And then I know there's some other reporting, bigger picture that you might be thinking about from a global point of view that could also factor in. So do you want to run through that? Yeah, I mean, there's certainly a lot of...

mandatory sustainability requirements coming and that are already coming. In the US now we have the California climate bills, still the SEC proposal on climate, probably soon a proposal for human capital as well. And so taking those into consideration as well and thinking about what other

mandatory sustainability reporting requirements might I have either at a global group level or at different subsidiary levels is an approach that a lot of companies are taking and trying to think holistically about how do I do this reporting in an efficient way and

even if the reporting levels don't necessarily align, at least thinking about where are there overlaps or commonalities in the data that I need to gather and ultimately report to be able to gather data once to satisfy multiple different reporting requirements. All right, that's helpful. So then, Emily, you alluded to this before, which is that in addition to, I'll call it these, in some cases, limiting factors or just...

company specific factors that you need to take into account to really understand what your options are. You also have a strategy that you want to think about. So companies have their actual sustainability strategy, what they're doing to get to net zero, how they're dealing with human capital issues and otherwise. But then often companies will have a strategy for how they want to communicate that message into the market. And I do think the bookends here would be that

CSRDs, purely a compliance exercise. Let's do the minimum to get our test reports done and our reports filed. And then someone else who's really viewing this as a strategic opportunity to share its message in a very holistic and fulsome way. So sort of with those bookends, how do you overlay the strategy question in this overall evaluation?

Yeah, so I think, as you said, there's definitely those different schools of thought. And I'm sure there are many companies that fall somewhere in the middle as well. But thinking about questions like, how is sustainability incorporated in the strategy? You know, do you want to

holistically for the whole organization, communicate the risks and opportunities that you have for your business. How are your peers reporting? Are they taking a certain approach because stakeholders or investors might want to understand how you're doing compared to your peers? And so there could be a general expectation that you're going to be reporting in the same way.

The other area is what are your stakeholders asking for, which I think is really key. And as we've talked about, because at the end of the day, if certain stakeholders want certain information, you're likely going to have to find a way to provide it to them. So some might want information for your entire organization. They might question why you're only providing really detailed sustainability information for a subset of your business and not all of it.

On the other hand, certain types of information, certain stakeholders might want locally. So, you know, for example, employee information, like employees in a particular country might want to understand, you know,

sustainability matters impact them locally. So balancing that is definitely something to consider. Well, and I think Emily, that is such an interesting point to me because when we went into this, I think the almost presumption is, Oh, well, global consolidated is quote better.

because it gives more, it's more comprehensive than otherwise. And it has been interesting to have these conversations where actually some of this local information in some cases may be more meaningful, or in some cases, looking at a region is more meaningful. So there is a lot to consider. And for each company, the answer is likely different or could be different. So something to think about. So is there sort of a broad brush way you can kind of

way efficiency versus strategy here? I mean, I would say that really thinking about who the intended audience and the stakeholders are, what are management's objectives, and just making sure that everyone is aligned who needs to have input into it, I think is really key. All right, that's helpful. So then maybe another point, and probably it would pull it all together, is I feel like as we've gone through this, at least if I was listening, I'd be like,

well, we've gone through sort of this, but that, or here's a pro, but here's a pretty big con. And so it really is kind of hard to see that there's a clear answer one way or another. So how do you think about these trade-offs that companies are making?

Yeah, I mean, I'm always a big fan of the pro-con list and bulleting it out and really thinking about seeing it on paper. So regardless of the path that companies go down, having some clear documentation around the thought process and how you got to where you ultimately landed is going to be important, especially as you think about the evolution of this reporting, right? And you could have entities come in and out of scope over time, potentially. So

having that documentation is going to be really important. I think there are pros and cons and you do have to look at them side by side and think about it because, you know,

for better or for worse, each of these factors has a pro and it probably has a con too. So, you know, for example, if a company has five individual EU subsidiaries in scope and two EU subgroups that are in scope that include some operations outside the EU, maybe it is more efficient to either prepare one report at a global consolidated level or do artificial consolidation, combine them into one. But on the other hand, if there are still a lot of, uh,

or other aspects of the business and operations that sit outside of those EU subgroups, you'd be including a lot more information than would otherwise be required. So I think that's really where...

management's objectives for this reporting is really key because that'll also drive and influence how heavily you weight certain factors over others. Yeah, and I think also for me, that's where this idea potentially of an on-ramp comes into place because even if ultimately from a strategy perspective, you conclude that it is going to be most meaningful to do global consolidated reporting

reporting perhaps with some information on individual subsidiaries and we didn't even talk about the fact in some cases that may be required to give risk or other information for some subsidiaries but even if that's your ultimate aim do you really want to do that the first year or do you start

I'll say smaller and build up to that? Or do you start smaller and realize that that's working for you and that you don't ultimately want to do this full scope of reporting? There's just a lot to think about. And I'm not sure there's going to be one answer that we can universally say really applies to all companies.

So as you think then sort of from a closing perspective, because now I am thinking that we've given people lots of pros and cons and not a lot of answers. How would you tie this all together?

So I would just highlight first that this decision, even with imperfect information now, because we are still waiting to see how the EU member states transpose the CSRD into law, I think making some assumptions and at least getting this process started is going to be really important because it does influence a lot of how the next steps are executed. Because at the end of the day...

the sustainability information that needs to be reported are those impacts, risks, and opportunities that are material for the entity that's reporting. And so how that double materiality analysis is done and what activities are considered in there is really dependent on the reporting approach that's taken because it's driven by the reporting entity.

I also think that making this decision, at least tentatively, sooner rather than later, will give companies more time to design and determine the systems and processes and controls that need to be put in place.

for reporting because that's not going to be a small, small process, a small undertaking to do. And as you mentioned, I think the last point that's really important to highlight is that this, whatever decision is made now, like while it might set some expectation for what would be disclosed in the future, it doesn't have to stay that way. So there is some flexibility then going forward as well because stakeholder needs might change or, you know,

Information might become more readily available to make different levels of reporting easier and more difficult. So I would just encourage companies to still take the appropriate time to think about this, involve the right stakeholders, and document their considerations before getting started on the next steps for reporting.

All right. Well, I think that's a great reminder to end with. And maybe the last point I would just make is not to jump too quickly into this. Make it soon, but don't make it, you know, in an hour without at least considering these factors. And as I mentioned earlier in the podcast, we do have a publication out there that goes deeper into each of these and I think provides some additional context.

And then in addition, if you look in that publication, there are definitely points of contact, including Emily and I, and you can always feel free to reach out because this is something that I think warrants at least one conversation. So anyway, appreciate you joining me today. Emily is always appreciate having opportunity to hear all your insights. So thank you. Thanks for having me. That's our show for today.

Tune in next week for more fresh episodes. So that you never miss any of our audio content, follow the PwC Accounting Podcast wherever you listen to your podcasts. And to stay up to date on all our latest accounting and reporting news, sign up for our newsletter at viewpoint.pwc.com. From Thought Leadership at PwC, I'm Heather Horn. Thanks for tuning in. ♪

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