CSR communication: publishing a genuine, useful report
CSR communication: how to publish a verifiable report, avoid greenwashing sanctioned since 2022, and turn transparency into a real asset.
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ESG & CSRD reporting in France | SME and mid-cap supportExpert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. Genuine CSR communication rests on a verifiable report: sourced indicators, an explicit method (GRI standards or ESRS), challenges owned up to and a costed action plan, ideally with third-party assurance. Conversely, an unsupported environmental claim exposes you to sanctions. The decree of 13 April 2022 has strictly framed carbon-neutrality claims since 1 January 2023.
CSR communication has become a double-edged exercise. Done well, it lends credibility to a real approach and supports the commercial relationship. Poorly calibrated, it exposes you to the accusation of greenwashing, now sanctioned. The stake is no longer to communicate a lot, but to publish accurately: a report you can hold up before a client, an investor or an inspector. This article describes what sets genuine CSR communication apart from decorative talk, and where the accountant secures the information chain.
Why CSR communication has become a risk topic#
For years, the sustainability report was mainly a matter of communication. Two shifts changed this. On one hand, regulation now frames environmental claims and sanctions misleading ones. On the other, stakeholders (client buyers, banks, investors) ask for proof, not intentions.
CSR communication is no longer judged on tone, but on traceability: every figure put forward must be reconstructable from reliable data. This is exactly an accountant's ground, used to tying a statement to supporting evidence.
The frameworks: GRI, ESRS and the role of assurance#
Several frameworks structure a credible report. The GRI (Global Reporting Initiative) standards are the most widespread voluntary international reference. In Europe, the ESRS standards, anchored to the CSRD directive (directive EU 2022/2464), set a harmonised format of sustainability information for the companies subject to it.
One point sets regulatory reporting apart from mere communication: assurance. The CSRD provides for verification of sustainability information by an independent third party (statutory auditor or independent third-party body). This assurance, first at a limited level, turns talk into enforceable information.
| Framework | Nature | Feature |
|---|---|---|
| GRI standards | Voluntary international reference | Very widespread, comparable across sectors |
| ESRS standards (CSRD) | European regulatory framework | Harmonised format, double materiality |
| Third-party assurance | Independent verification | Gives the report its enforceable value |
Note that the CSRD timetable has been adjusted: the so-called Omnibus directive, whose deferral strand was adopted in 2025, shifts the obligations of some company waves by about 2 years and narrows the scope of those subject. The principle of verified reporting, however, remains the reference towards which market expectations converge.
Greenwashing: what the law already bans#
Apart from the CSRD, environmental communication is regulated. The Climate and Resilience law (law no. 2021-1104 of 22 August 2021) reinforced the fight against greenwashing. Its implementing decree no. 2022-539 of 13 April 2022, in force since 1 January 2023, frames the use of carbon-neutrality claims (for example carbon neutral, zero carbon, fully offset).
A company claiming the carbon neutrality of a product or service must make accessible, via a link or a code, a life-cycle greenhouse-gas emissions assessment, a reduction trajectory and the offset arrangements. Failing this, it faces a fine of 20,000 euros for an individual and 100,000 euros for a legal entity, amounts that can be raised to the full cost of the communication operation.
In other words, an unsupported claim is not just an image risk: it is a quantifiable financial risk.
Our view#
We regularly see CSR reports polished in form, yet unable to produce the data behind the figure. This is the most frequent weak point. Our conviction: a short CSR report, where each indicator is sourced and reconstructable, is worth more than a long, illustrated document no one can audit.
Good practice means owning up to challenges and gaps against targets too. A report showing only successes arouses the suspicion of an informed reader. Showing a missed target, explaining why and presenting the action plan is paradoxically more credible, and more protective legally.
The underestimated risk#
The most overlooked risk is not the administrative sanction: it is internal inconsistency. When the CSR report states a figure that the accounts or the management system do not confirm, the contradiction eventually surfaces, during a client audit, a due diligence or an inspection. A published datum commits the company.
That is why CSR communication should never be disconnected from management figures. The same euro of spending, the same tonne of waste, the same energy use must tell the same story in the report and in the accounts.
In practice: where the accountant steps in#
The accountant does not write the company's CSR narrative, but secures its costed backbone:
- Indicator traceability: tying each published datum to a verifiable source, as one ties an entry to its evidence.
- Accounting consistency: checking that CSR figures and the accounts do not contradict each other.
- Preparing for assurance: organising the documentation for third-party verification, a topic close to the approach described in our article on preparing an EcoVadis evidence file.
- Regulatory linkage: placing the report against the green taxonomy and the ESRS, as in our analysis of calculating taxonomy-aligned turnover.
This is the aim of our support in CSR and CSRD sustainability reporting, often paired with outsourced CFO backing.
A common case#
An industrial SME publishes a brochure announcing a 30 % cut in its emissions over 2 years. A major client asks for the calculation method during a supplier audit. Reviewing the file, we find the scope was not stabilised from one year to the next, which artificially inflates the drop. The correction brings the real reduction down to a more modest but defensible level. Better to publish a figure of 18 % that is perfectly traceable than a figure of 30 % that collapses at the first check.
Points to watch in 2026#
- Quantified claims: any carbon-neutrality mention must comply with the 2022 decree, on pain of a fine.
- Stable scope: an indicator only means something if its calculation scope is constant from one period to the next.
- Assurance: anticipate third-party verification, which is becoming the norm for sustainability reporting.
- Consistency with the accounts: never publish a CSR figure the accounts could not confirm.
Frequently asked questions
What is genuine CSR communication?+
It is communication where each statement rests on verifiable data, with an explicit method, a stable scope and, ideally, third-party assurance. It also owns up to challenges and gaps, instead of showing only successes.
What is the difference between GRI and ESRS?+
The GRI standards form a voluntary international reference, widespread and comparable across sectors. The ESRS standards are the European regulatory framework anchored to the CSRD, with a harmonised format and double-materiality logic.
Is greenwashing sanctioned?+
Yes. Decree no. 2022-539 of 13 April 2022 has framed carbon-neutrality claims since 1 January 2023. Without accessible justification, the fine can reach 100,000 euros for a legal entity, raisable to the full cost of the operation.
Should a CSR report be verified?+
The CSRD provides for assurance of sustainability information by an independent third party for the companies subject to it. Beyond the obligation, having indicators verified lends credibility to the report and makes it enforceable before a client or an investor.
Should my report show the weak points?+
Yes, it is even recommended. A report showing only successes arouses suspicion. Showing a missed target, explaining it and presenting the action plan is more credible and more protective legally.
How does the accountant help with CSR communication?+
They secure the costed chain: indicator traceability, consistency with the accounts, preparation for assurance and linkage with the taxonomy and the ESRS. They do not write the narrative, but ensure the figures hold up.
Key takeaways#
- Genuine CSR communication is judged on figure traceability, not on the tone of the talk.
- GRI standards and ESRS structure a credible report; third-party assurance makes it enforceable.
- Decree no. 2022-539 of 13 April 2022 sanctions unsupported carbon-neutrality claims.
- Owning up to challenges and gaps is more credible and more protective than showing only successes.
- The accountant secures consistency between the CSR report and the accounts.
Hayot Expertise, registered with the Ordre des experts-comptables d'Île-de-France. This article is for information only; a decision specific to your situation requires reviewing your activity, your documents and the regulations in force.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
This topic is part of our service ESG & CSRD reporting in France | SME and mid-cap support
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