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Sustainability legislation is developing fast worldwide, and the Sustainable Games Alliance supports its members in complying with all relevant legislation.
Keep in mind that your company might be affected earlier than displayed below, especially if you are part of the supply chain of a larger company.
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Corporate Sustainability Reporting Directive (CSRD)
Mandatory sustainability reporting begins for existing EU entities covered by the Non-Financial Reporting Directive.
Affects only Large companies, which have already been subject to the mandatory disclosures of the NFRD since 2013.
The first year of mandatory sustainability reporting for remaining Large companies and EU parent-owned group companies that have not previously been subject to NFRD.
First year of mandatory sustainability reporting for small and medium undertakings.
Small undertakings will have the option to “opt-out” from disclosures for up to 2 years.
First year of reporting for any company with a “significant presence” in the EU.
Helps game businesses of all sizes to understand, measure, and align sustainability reporting by CSRD deadlines.
Company size according to EU
Keep in mind that your company might be affected by disclosure requests earlier than indicated by company size if you are part of the value chain of a larger company that has to report before you. CSRD is designed to cover the entire value chain.
Micro undertakings do not exceed more than 2 out of 3 of the following:
€450k balance sheet, €900k revenue, and 10 employees
Small undertakings do not exceed more than 2 out of 3 of the following:
€5m balance sheet, €10m revenue, and 50 employees
Medium undertakings do not exceed more than 2 out of 3 of the following:
€25m balance sheet, €50m revenue, and 250 employees
Large undertakings exceed more than 2 out of 3 of the following:
€25m balance sheet, €50m revenue, and 250 employees
Climate Corporate Data Accountability Act & Climate Related Financial Risk Act (California SB253, SB261)
First year of reporting for companies that are formed in the United States and do business in California, and have $1bn+ revenue. Must disclose Scope 1 & 2 emissions initially.
Starting in 2026, same large companies have to expand reporting to include Scope 1, 2 and 3 (value chain) emissions.
SB261 introduces new mandatory climate risk disclosures for companies with revenue over $500M USD and that do business in California. Reports must be filed every two years.
By meeting the stringent ESRS standard, the SGA Standard provides guidance and a common platform for companies required to report under SB253 and SB261. This will also include guidance on climate related risk disclosures, applying best–practice from both the EUs “double materiality” approach and TCFD recommendations.
The Enhancement and Standardization of Climate-Related Disclosures for Investors (SEC Rules)
Large accelerated filers (LAFs) from FY 2025
Accelerated filers (AFs) FY 2026. Assurances and electronic tagging beginning from FY 2026 onwards.
Smaller reporting company (SRC), emerging growth company (EGC) and non-accelerated filer (NAF) FY 2027.
The SGA standard will meet or exceed the requirements of the US SEC climate-related disclosure rules. The SGA standard will also enable outputs compatible with electronic filing requirements.
Aotearoa New Zealand Climate Standards
Large NZ companies with the following: Market price of all equity securities >$60 million NZD, debt >$60 million.
Overseas incorporated organisations with New Zealand business above the same thresholds.
Involves implementing the IFRS S2 and TCFD recommendations for climate disclosures.
Covers entire value chain for climate-related risks and opportunities, specifies optional strategy and details on alignment with climate scenarios, plus metrics and target setting.
The NZ XRB notes “a high degree of interoperability between NZ CS and the TCFD recommendations and the ISSB standards.” EU CSRD has also published interoperability guidance between ESRS and ISSB S1/S2 which will facilitate the SGA Standard’s complementarity with NZ CS.
Australian mandatory climate reporting
Mandatory sustainability reporting starting 1 July 2024 for large entities passing at least 2 of 3 criteria: 500+ employees, $1bn+ AUD assets, $500m+ AUD revenue.
Mandatory sustainability reporting starting 1 July 2026 for medium size entities passing no more than 2 of 3 criteria: 250+ employees, $500m+ AUD assets, $250m+ AUD revenue.
Mandatory sustainability reporting starting 1 July 2027 for smaller entities passing no more than 2 of 3 criteria: 100+ employees, $25m+ assets, $50m+ revenue.
Also affects ‘controlling corporations’ – foreign companies owning or operating in Australia meeting same threshholds.
As above, the SGA Standard’s interoperability with IFRS S1 & 2 will be ensured, through meeting and exceeding the requirements of the ESRS.
