From voluntary CSR to binding ESG frameworks: a legal perspective on sustainability disclosure standards

Abstract This article examines the evolving legal landscape of environmental, social, and governance (ESG) regulation and standardization from a global perspective, highlighting the fragmentation, ambiguities, and power dynamics that shape current ESG governance. It contrasts ESG with the historically rooted framework of corporate social responsibility (CSR), tracing the shift from voluntary, ethics-based initiatives to binding legal obligations. A transatlantic comparison reveals divergent disc