A Comparative Study on Enforcement of the Corporate Sustainability Reporting Directive (CSRD): Sweden, Denmark, France and ESMA's Role in Harmonizing Supervision

This article compares the enforcement of the Corporate Sustainability Reporting Directive (CSRD) in Sweden, Denmark and France, and assesses whether ESMA's Guidelines on Enforcement of Sustainability Information (GLESI) can reduce national divergence. It argues that the CSRD should be understood as part of a broader EU turn toward regulating sustainability in global value chains through a multilayered governance model consisting of harmonized disclosure duties, national enforcement, assurance gatekeepers, private enforcement and EU-level supervisory coordination. Using Article 51 of the Accounting Directive as a benchmark, the article finds that all three national systems rely heavily on correction, but differ in deterrence, escalation and private enforcement. GLESI can harmonize review methods and market correction for listed issuers but cannot itself ensure dissuasive sanctions where national enforcers remain unwilling to implement them.