Call for Open Data Principles in EU Corporate Sustainability Reporting Directive Legislation

Policy Advice
Call for Open Data Principles in EU Corporate Sustainability Reporting Directive Legislation+Image

Dear EU Commission and Members of the European Parliament:

We, the undersigned, strongly call for the adoption and incorporation of open data principles in the proposed Corporate Sustainability Reporting Directive and the supporting reporting frameworks.

Open Data is "data that can be freely used, re-used and redistributed by anyone - subject only, at most, to the requirement to attribute and sharealike" (Open Data Handbook). To ensure data is open, it must meet the standards of legal openness and technical openness or the "F.A.I.R" principle:

F: Findable or easily discoverable on a website or within a database

A: Accessible or available in a machine readable, “convenient, modifiable form” and published as a whole, complete dataset (not cherry-picked)

I: Interoperable or able to be mixed with different data sets

R: Reusable or provided under an (open) license that permits re-use and redistribution, including the intermixing with other datasets.

Data shared as a linked PDF, buried in a lengthy corporate sustainability report, would not meet the standard of Open Data. 


The reporting frameworks and requirements of the Corporate Sustainability Reporting Directive must integrate Open Data principles to unlock the legislation’s full potential. First, Open Data principles are already European Union policy and recommended in the OECD Due Diligence for Responsible Supply Chains in the Garment and Footwear Sector. Second, these principles will ensure that one, the data produced as a result of the legislation is accessible to all stakeholders, rather than select groups, and two, that data collation can be automated, meaning accountability can be scaled to encompass all reporting entities across multiple sectors. Due Diligence data shared in both a legal and technical open manner will eliminate duplication of efforts, ensuring efficiencies across public and private initiatives and collaboration across stakeholder groups. 

For example, an open dataset of a company’s suppliers would allow stakeholders such as unions, manufacturers, companies and government to collaborate on remediation efforts within a supply chain, allow consumers to understand their product’s impact and provenance and allow academics to share research with relevant stakeholders on the supply chain’s environmental footprint. 

Clearly defining the disclosure format and data points required in the Corporate Sustainability Reporting Directive will also increase adoption of the reporting framework and ensure its scalability. As research in Germany showed, unclear or free-form standards for CSR reporting led to only 17-19% of companies completing their required reporting. Complete, open data sets must also be mandatory to realize their full potential to bring about real, long term lasting impact. Future innovations or academic research yet unknown will benefit enormously from whole data sets, rather than summary analysis or cherry picked stats. By having clearly defined, repeatable and predictable reporting forms and methods, and mandating this reporting meets open data standards, costs can be reduced and harmonization across member states will increase, something that benefits all stakeholders.

In closing, we strongly urge EU members of Parliament and the EU Commission to adopt and incorporate open data principles into the proposed Corporate Sustainability Reporting Directive to ensure stakeholder access, interoperability and collaboration. 



Clean Clothes Campaign 

Open Apparel Registry 



Business and Human Rights Resource Centre

Fashion Revolution


Open Data Institute

Open Knowledge Foundation 

International Corporate Accountability Roundtable (ICAR)

Icebreaker One


The Center for the Advancement of Garment Making


Je valide ça, service-conseil

TISC Report

Sourcing Playground

The Restart Project

Viet Labor Movement

Myanmar Centre for Responsible Business

J & M Fanwear

Cornell University New Conversations Project

Inno Community Development Organisation 

Young IL Co.,Ltd

Changing Markets Foundation

Custom Collaborative

Open Carbon

Lady Lawyer Foundation and Lady Lawyer Fashion Archive

Comitato Lady Lawyer Village




International Federation for Human Rights (FIDH)

Open Development Cambodia (ODC)

Kernow Waves Surf Clothing

Anti-Slavery International


Rights CoLab




Material Exchange

Open Contracting Partnership


Global Biodiversity Information Facility

The Climate Choice