Mandatory corporate sustainability reporting has become a central instrument of environmental governance, yet whether disclosure mandates improve environmental performance or merely generate compliance documents remains contested. This study compares three staggered mandates: the Business Responsibility and Sustainability Reporting (BRSR) framework in India, the Corporate Sustainability Reporting Directive (CSRD) in the European Union, and the climate disclosure rules of the United States Securities and Exchange Commission (SEC). A convergent mixed-methods design combines a quasi-experimental difference-in-differences strategy with a comparative reading of the governing legal instruments as regulatory literature, interpreted through a political-economy framework that integrates political cost theory, political corporate social responsibility, and regulatory capture. Aggregate evidence for India shows that reporting completeness reached 96 percent of sampled firms and energy intensity fell by 13 percent between financial years 2022 and 2023, but much of that reduction tracks a pre-existing efficiency trend, so the disclosure-attributable effect is indicative rather than definitive. The European framework is the most demanding in scope and assurance, although the Omnibus simplification narrows its reach before outcomes can be measured. In the United States, the federal rule was adopted in 2024 and dismantled during 2025, when the Commission ended its defence, federal civil environmental complaints fell to 16, and the country moved to leave the Paris Agreement, evidencing a negative political effect on disclosure. A regulatory effectiveness index ranks the European framework above India and the United States. Disclosure is necessary but insufficient; assurance, enforcement, and binding performance standards separate transparency from transformation.
Dhar et al. (Wed,) studied this question.