Alternative choices within regulatory constraints The limits of the de facto harmonisation under the CSRD

This paper aims to investigate the effects of the Corporate Sustainability Reporting Directive (CSRD) on the harmonisation of sustainability reporting practices at both national and cross-country levels. Manual and automated text analysis of 714 corporate sustainability reports from France, Italy, and Spain (2022–2024) was performed to assess de facto harmonisation in sustainability disclosure. Reporting standards and frameworks were identified to compute Herfindahl and Comparability indices, while dictionary-based content analysis and ANOVA were employed to assess thematic convergence across countries and sectors. The results reveal that the adoption of ESRS is a consequence of standardisation in Italy and France, and of de jure harmonisation in Spain. However, it does not translate into in-depth de facto harmonisation in the three EU members. The CSRD, therefore, did not exert a sufficiently intense institutional pressure to generate in-depth isomorphism, as pre-existing differences in national accounting traditions persist. To our best knowledge no prior research has compared de facto harmonisation levels during the NFRD with those after CSRD adoption. Additionally, this analysis assesses the level of de facto harmonisation not only through the computation of indices, but also through computational text analysis of an extensive cross-country database.