This article offers criticism on the current approach to sustainability reporting by many governments. The article argues that lessons from earlier initiatives involving additional non-financial information (NFI) reporting seems to be ignored, when they should instead critically guide sustainable reporting efforts. In addition the author calls on the audit community to be aware of negative impacts they may have on the use of NFI for achieving sustainable goals.
The article represents the viewpoint of a practitioner with a background in both public sector reporting, auditing and academic research. It is based on relevant literature combined with practical insights from experience gained in over two decades of working in the field of public sector NFI reporting and utilisation of performance information.
The dynamics and impact of annual reporting in the public sector are fundamentally different from those in the private sector. This has important implications for the conceptualisation and utilisation of NFI in the budget cycle. Governments worldwide have gained extensive experience in managing strategic non-financial objectives using NFI from budgeting and annual reports. Academic research has identified a number of informational, organisational and cultural obstacles that inhibit the analytical use of NFI. Applying these insights can help make public sector sustainability reporting more proportional and impactful and help avoid unrealistic expectations. The audit community can contribute to easing or even eliminating informational obstacles but may aggravate some organisational and cultural ones at the same time.
As a practitioner’s dialogue contribution, this article provides a brief overview of existing academic evidence as well as practitioner’s observations and personal opinions rather than an empirical analysis of data to systematically answer a research question.
The article provides several practical implications for practitioners, auditors and academics.
This is the first article that combines perspectives from the audit community, academia and practitioners of public financial management with regard to sustainability reporting. More precisely it matches insights from academic research on public administration and budgeting reforms with current public sector sustainability accounting initiatives. In addition it focuses on the role that standard setting and audit can have in enhancing or obstructing NFI use.
Over the last decade or so, the availability of information about our health has significantly increased thanks to pedometers and advanced apps. Judging by the consistent percentage of people who do not get enough exercise or struggle with being overweight (e.g. in the Netherlands both persistently at around 50% of the population) this additional information, on average, does not seem to have led to healthier choices. The fact that more and better information alone does not automatically translate into wiser choices is something that most of us intuitively understand and has repeatedly been confirmed by scientific research. Yet policymakers and auditors appear to make little use of this knowledge in their work. This is illustrated by the high expectations many governments in the European Union and beyond have about sustainability reporting and its impact on more sustainable outcomes. To seriously assess the potential impact of the newly reported information on achieving sustainable goals, a broader view on enabling factors and obstacles to its use is helpful.
This article aims to offer a broader context for public sector sustainably reporting and offer some lessons from academic research on the use of non-financial information (NFI) in budgeting. In the first Section I introduce the current developments that made public sector sustainability reporting an increasingly relevant topic and argue that it may not be that new of a phenomenon. The next section addresses relevant differences between private and public sector reporting and argues that this has important implications for the potential take-up of NFI by public sector decision makers with regard to timing and purpose of use. The third section deals with the differences in scope between public and private sector sustainability reporting, requiring a more comprehensive yet more selective approach for the public sector. The fourth section of this paper looks at the different types of obstacles that stand in the way of using NFI for decision making and at ways governments have found to ease or mitigate these obstacles. The fifth part offers some suggestions for practitioners for impactful public sector sustainability reporting. Subsequently, I go into ways public sector audits can contribute to proportionate and impactful sustainability reporting in the sixth part. I provide my concluding remarks in the final section.
Sustainability reporting: current initiatives and the public sector
On December 14th, 2022, the European Union (EU) published its Corporate Sustainability Reporting Directive (CSRD – Directive, 2022/2464), aimed at supporting the implementation of the European Green Deal. The CSRD came into effect on January 5, 2023, for (parts of) the private sector and is intended to help investors, interest groups, consumers and other stakeholders assess the sustainability performance of companies. The regulations are detailed in 10 standards covering environmental, social, and governance (ESG) aspects that must be addressed in the annual reports. The EU suggests that the new ESG information can be used to gain insight into sustainability risks and impacts, monitor environmental and social trends and provide information to governments (CSRD – Directive, 2022/2464). The CSRD is supplemented by the corporate sustainability due diligence directive (CSDDD), which obliges companies to identify and where necessary, prevent or mitigate the negative impacts of their activities on human rights and the environment. For reasons of clarity and lack of a clear generally accepted definition, ESG and sustainability will be used interchangeably in this article.
Government initiatives to impose sustainability reporting requirements on the private sector have not been without criticism. Some claim that the new and complex European sustainability regulations present risks of a reporting and auditing explosion and argue that companies should primarily focus on creating shareholder value (Harper Ho, 2023). In the US, this perspective has led to widespread shareholder activism against sustainability reporting initiatives that resulted in anti-ESG bills in some US states (e.g. Malone et al., 2023; Naidu and Jessop, 2024). While California is looking at far-reaching reporting requirements not unlike those of the EU, other states such as Texas moved in another direction prohibiting government from contracting with banks that screen investments for ESG risks and opportunities. Even in Europe, where initial criticism of the EU’s Green Deal and CSRD requirements seemed modest, the original ambitions are beginning to be diluted due to pushback from voters and interest groups who claim that excessive administrative burdens unnecessarily harm businesses.
Another critique is that while governments enforce uniform sustainability reporting on the private sector, they are not themselves subject to mandated reporting on these issues. Understandably many feel that governments should not only practice what they preach but also lead the way in demonstrating useful and impactful sustainability reporting (Bryan, 2021; Dees and De Jong, 2024). So far, most governments that do disclose sustainability information do so on a voluntary basis and seem to be driven largely by pressure from peer institutions (Zhao and Patten, 2016; Goodman et al., 2023).
The main standards currently used for reporting and examining public sector sustainability disclosure are the Global Reporting Initiative (GRI) standards. In October 2016, the GRI introduced the GRI Standards, replacing GRI G4, which were later superseded by the GRI Universal Standards. This despite criticism related to an excessively generic approach to reporting and a lack of indicators addressing the specificities of different types of public sector organisations (Manes-Rossi et al., 2020). In 2024 the International Public Sector Accounting Standards Board (IPSASB) in cooperation with the World Bank issued draft Sustainability Reporting Standards (SRS) based on the International Sustainability Standards Board for the private sector.
Regardless of political preferences, it seems very likely that non-financial information (NFI) on sustainability will play a more dominant role in future government reporting. It is not yet clear how the new reporting requirements like CSRD and SRS will impact sustainability reporting in the public sector. However, convergence with private sector standards seems likely, if only because of close public-private cooperation for the realisation of government policies (e.g. government participations, contracting with private entities).
It should be stressed that reporting on sustainability objectives is not that new for most governments. Governments worldwide have been reporting on internationally standardised United Nations Sustainable Development Goals (SDGs) for several years. Additionally, many public organisations are engaged in their own sustainability reporting initiatives. An increasingly popular way to generate sustainability information in the budget cycle is tagging budget items based on their contribution to cross-cutting objectives such as climate or gender related expenses (Blanch et al., 2023).
An obvious shortcoming of budget tagging is that it focuses on inputs only. Tracking how much resources are being allocated to a particular topic may reveal preferences in political prioritisation, but perhaps no more than that. Therefore, a reduction in tagged budget expenditures can signal either political de-prioritisation of the issue at hand or a decreasing problem based on objective data justifying lower expenditures to solve it. More advanced examples of integrating sustainability information in budgeting include mechanisms to systematically assess sustainability impacts in budget proposals (e.g. South Korea) as well as the use of advanced methods to estimate the fiscal impact of climate change in countries such as Ireland, Denmark, Switzerland and Canada (OECD, 2024).
Why NFI reporting is different for the public sector
Many of the initiatives to bolster sustainability reporting take the annual budget cycle and, more specifically, the annual report as the dominant vehicles for disclosing information. The reported information about sustainability is expected to impact decision making that contributes to achieving sustainable objectives and goals. Using the annual budget cycle for sustainability reporting offers several advantages over stand alone reports, as it is a well-established process that already has the attention of stakeholders. Most importantly, it allows for the integration of different types of information. A possible drawback of integrating sustainability in annual reporting is that attention for sustainability issues may suffer from a focus on finance and, therefore, be debated at a more abstract and aggregated level (Niemann and Hoppe, 2018).
When it comes to the budget cycle, most of us realise that the government is “a different beast” from the business world in many respects. Indeed, the role of NFI in the budget cycle differs across the public and private sectors in several ways. Firstly, there is a disparity between public and private sectors regarding the timing of NFI use for decision-making. In the private sector, the annual report is a critical moment for resource allocation, as this is the moment when the annual profit is determined and shareholders are rewarded. In the absence of the profit motive and shareholders in the government context, discussions regarding resource (re)allocation primarily occur during budget preparation and budget implementation. Consequently, the use of NFI in decision-making in government is predominantly anticipated during these earlier phases of the budget cycle instead of the annual report. It is therefore not surprising that some of the more advanced examples of integrating sustainability with the reporting and budgeting cycle (see previous section) share a forward-looking perspective.
Much to the chagrin of many employed in accounting and control, the attention of politicians and civil servants pay to public sector annual reports, including the NFI that they report at the end of the budget cycle, is usually limited. Most public sector practitioners will easily confirm the observation that political attention to NFI about goals and ambitions greatly exceeds the attention for results reported afterwards (Hijal-Moghrabi, 2018; Raudla, 2022). So when looking for impact of NFI in general and of sustainability information in particular, the annual report is not the most likely budget phase to observe it. Instead NFI will more likely impact public sector decision making in the budget preparation and budget execution phases. This is why it is worth considering the entire public sector budget cycle when looking at the impact of NFI.
Secondly, the way accounting information is used in the public sector often differs from that in the private sector. Given the political context in which public budget debates occur, perspectives other than rational decision-making come into play such as credit claiming, blame avoidance and negativity bias (Curristine and Flynn, 2013; De Jong and Ho, 2019; Conlan et al., 2014; Nielsen and Baekgaard, 2015). Whether politicians use accounting information depends on their individual characteristics and contextual factors such as prioritisation and the degree of political controversy of policy fields (Van Helden et al., 2016). Insofar as NFI is used in the political debate, it is often merely referenced as the phenomenon of performance measurement itself, without attaching specific policy consequences to it (Moynihan, 2008).
Furthermore, NFI use is often aimed at legitimising one’s own positions or debunking those of opponents (Demaj, 2017, Saliterer et al., 2019). Politics, after all, is also about beliefs and interests in addition to facts. In this light, it is not surprising that opposition parties appear to use NFI more often than the parties in power (Grossi et al., 2016; Saliterer et al., 2019; Faber, 2022), although this finding is not confirmed by some studies (Raudla, 2022). The incremental nature of the budget process and the limited capacity to process large amounts of information are additional reasons why analytical use of reported NFI fails to meet reformers’ expectations in most governments (Simon, 1947; Wildavsky, 1961; Lindblom, 1959; Joyce, 2008; Shaw, 2016; Moynihan and Beazley, 2016; OECD, 2018; Raudla, 2022). So in summary, the use of NFI on sustainability in the public sector can be expected to largely follow political instead of technical rationality. The likeliness of analytical use of NFI increases if its message aligns with ideas and interests of political leaders.
The scope of public sector sustainability reporting exceeds one’s own operations
Despite differences in the dynamics and impacts of annual reporting across the private and public sectors, sustainability reporting in both sectors cannot be viewed as an aim in itself but rather as a step in a value creating process. For private sector organisations, sustainability reporting can supplement traditional reporting to help investors, interest groups, consumers and other stakeholders assess the sustainability performance of companies. The EU suggests that its new ESG information requirements can be used to gain insights into sustainability risks and impacts as well as monitor environmental and social trends (CSRD – Directive, 2022/2464). This application of sustainability reporting largely fits a private sector company’s traditional focus on creating value by maintaining a competitive advantage and safeguarding continuity. As such sustainability information supplements information on shorter term goals such as maximising profits and increasing shareholder value.
Given the broad definition of sustainability, the question what an organisation should and should not report on remains one of the most important challenges for both private and public sector entities. Existing sustainability reporting often uses a dual definition of impact. The CSRD, for example, uses the concept of double materiality, where both the impact of the external environment on an organisation and the organisation’s impact on the environment must be considered.
This brings me to the third important difference between private and public sector NFI reporting that bears relevance to sustainability reporting. Value creation processes of governmental entities, especially of national governments, are often intended to have impacts way beyond their internal operations. Although governments have internal production processes that are comparable to those of the private sector, it would be a mistake to ignore government’s unique role in developing and executing policies that focus on society as a whole. For many government organisations the most substantial ESG impact on their environment will more likely result from their external policies (e.g. environmental legislation) than from their internal operations (e.g. electrification of government vehicles). Likewise, the impact of the external environment on policy responses (e.g. natural disaster relief) will often be more substantial than the impact on its own operations (Dees and De Jong, 2024, see Figure 1).
The figure shows a representation of an administrative building with columns on the left, along with the label “Government Policies.” A set of interconnected gears, along with the label “Government Operations,” is present below it. A series of four arrows: A pair of rightward and leftward arrows is stacked vertically in the middle, and each pair extends between each label and the globe. A drawing of a globe is on the right. The top rightward arrow in the middle is labeled “Impact outwards” and has an example below it that reads, “for example, issuing G H G emission standards.” The second leftward arrow in the middle is labeled “Impact inwards” with the example that reads “for example, strengthening flood defences.” The third rightward arrow in the middle is labeled “Impact outwards” with the example that reads “for example, using E Vs by government agencies.” The bottom leftward arrow in the middle is labeled “Impact inwards” with the example “for example, climate control in offices.”The dual nature of sustainability impacts by government. Source: Author
The figure shows a representation of an administrative building with columns on the left, along with the label “Government Policies.” A set of interconnected gears, along with the label “Government Operations,” is present below it. A series of four arrows: A pair of rightward and leftward arrows is stacked vertically in the middle, and each pair extends between each label and the globe. A drawing of a globe is on the right. The top rightward arrow in the middle is labeled “Impact outwards” and has an example below it that reads, “for example, issuing G H G emission standards.” The second leftward arrow in the middle is labeled “Impact inwards” with the example that reads “for example, strengthening flood defences.” The third rightward arrow in the middle is labeled “Impact outwards” with the example that reads “for example, using E Vs by government agencies.” The bottom leftward arrow in the middle is labeled “Impact inwards” with the example “for example, climate control in offices.”The dual nature of sustainability impacts by government. Source: Author
Making this distinction between Sustainability with a capital “S” in the context of external policy versus sustainability with a small “s” for own operations is vital for public sector sustainability reporting. If ignored, governments risk sacrificing their scarce capacities to measure, analyse and audit on such things as scrutinising the vegan options in their cantina at the expense of analysing more impactful national sustainability policies. Fortunately, this important distinction is increasingly being recognised (e.g. in the draft ISPASB SRS guidelines). Applying a “dual double” materiality perspective can help government organisations attain proportionality and focus while considering the full scope for government impacts.
In short the differences between NFI reporting in the private and public sectors have important consequences for the uptake of sustainability information by decision makers. To keep sustainability reporting focused, manageable and useful for decision making, the materiality assessment should emphatically look beyond the own operations of a public sector organisation.
What can be learned from earlier reforms calling for extra NFI reporting?
Using annual reporting and budgeting to report on the impact of government policies, aligns with a long-standing tradition where governments use performance indicators and other policy-related information in the budgeting cycle to steer towards policy objectives and improved accountability. Most OECD countries have, over recent decades, gained experience in using their national budget cycles for strategic purposes. By incorporating NFI into the reporting and budgeting cycle, various forms of transformational budgeting – such as performance budgeting, gender budgeting and green budgeting – were expected to significantly influence decision making (Blanch et al., 2023). In reality however these reforms tended to emphasise the supply side of NFI while overlooking the demand side resulting in disappointment about the actual use of reported NFI. Based on this experience, it would be unreasonable to expect that just integrating extra NFI into budgeting and reporting cycles will automatically lead to its analytical use to achieve the desired outcomes (Melkers and Willoughby, 2004; Government Accountability Office, 2004; Moynihan, 2008; OECD, 2007; Sterck, 2007; Mihm, 2011; Moynihan and Lavertu, 2012; De Jong et al., 2013; De Jong, 2015).
Due to governments’ decades long experiences in managing strategic non-financial objectives through the reporting of policy impacts in annual reports, it could well be argued that the public sector should have a knowledge advantage over the private sector in this area. Given the different realities of private sector and public sector budgeting, it is hoped that the public sector learns from previous attempts to mimic the private sector. So, what are the lessons learned regarding the underutilisation of NFI reported in the public sector budget cycle and what is their relevance for sustainability reporting? Fortunately, there is a substantial base of academic evidence about the take-up of NFI by public sector decision makers and why NFI actually informs decisions or remains unused in public sector settings.
Public sector budgeting is historically characterised by an imbalance between the supply of information and its actual take-up. The overwhelming amount of data to assess was noted long ago by public administration scholars (Lindblom, 1959; Wildavsky, 1992). Looking at the information graveyards of unused NFI generated through the budget cycle, the previous attempts at transformational budgeting have aggravated this problem. Nonetheless, proponents of NFI related public sector reforms operate on the assumption that by integrating NFI into the budgetary cycle, this information will have a substantial influence on decision-making (“what gets measured, gets done”). The anticipation that sustainability will be employed this way is also evident in the goals of the European Commission’s new ESG reporting requirements (CSRD and CSDDD). Therefore, when using the budget cycle for reporting extra NFI on sustainability, it is worthwhile to look at why existing NFI remains underutilised.
Academic studies on sustainability reporting in the public sector are scarce and focus mainly on higher education institutions, local governments and state-owned enterprises (Manes-Rossi et al., 2020). Research among American municipalities shows that use mainly depends on the extent to which sustainability information is shared internally (Park, 2021). A study among Australian municipalities showed that they used sustainability performance measurement more for efficiency and output measures than for program learning and focused more on employee diversity and economic activity and less on ecological and social welfare (Adams et al., 2014).
The majority of academic studies on the use of NFI from budgeting in public sector settings concern implementation of performance budgeting (PB). PB also uses the budget cycle for strategic purposes by reporting NFI in annual reports and sometimes at other moments. Therefore, the experience gained with this widely adopted reform seems particularly instructive when looking for lessons on the use of sustainability related NFI in the budget cycle. Many studies have been conducted on the utilisation of NFI from budgeting and annual reporting in the public sector. These reveal several key factors that can help or obstruct the actual use of information. These factors are easily confirmed by practitioners working in management control and accountability within the public sector.
Generally, the experience with PB (as well as accrual accounting reforms) hints at an overly optimistic assessment of the capabilities of the users of this information, notably public sector managers and parliament. The disappointment with the success of PB lead to a substantial amount of academic research studying enabling factors for the use of performance information for decision making by public sector organisations. Inversely, the absence of such enabling factors can be viewed as obstacles for use. As performance information is usually broadly defined to include all kinds of NFI in these studies the findings can be expected to apply for NFI in annual reports. I summarised these factors in Table 1 as organisational, informational and cultural obstacles for NFI use.
Obstacles to NFI use by Public Sector Organisations
| Obstacles to NFI use by public sector organisations | |
|---|---|
| Organisational |
|
| Based on: Behn (2014), De Graaf and de Waard (2023), De Jong and Ho (2019), Grandia and Volker (2023), Ho and De Jong (2019), Laegreid et al. (2008), Langer et al. (2016), Metzenbaum (2015), Moynihan and Kroll (2016), Moynihan (2018), Moynihan and Beazley (2016), Moynihan and Kroll (2016), Moynihan and Landuyt (2009), Moynihan and Pandey (2010), OECD (2018), Posner et al. (2008), Raudla (2012), Schick (2003), Speklé and Verbeeten (2014), Taylor (2014) | |
| Informational |
|
| Based on: De Jong (2015), De Jong and Mills (2022), Ho and De Jong (2019), Moynihan and Beazley (2016), Park (2021), Taylor (2014) | |
| Cultural |
|
| Obstacles to NFI use by public sector organisations | |
|---|---|
| Organisational | Rigidity of Administrative Systems: Highly rigid administrative and budgetary systems limit managers’ flexibility, creativity, and involvement in achieving goals, making it difficult to use NFI effectively. Similarly low decision-making autonomy and strict procurement frameworks hinder innovation and exploratory use of NFI, which is crucial for addressing complex issues like climate policy Time Constraints in Budget Cycles: The budget cycle often imposes significant time pressure, leaving little room for thorough analysis or actionable use of NFI Underestimation of Workload and Costs: NFI integration reforms often overlook the additional workload and associated costs, leading to capacity issues. Larger organisations are better equipped to handle NFI requirements, while smaller entities often struggle Knowledge and Skills Gaps: Employees frequently lack the expertise to interpret or utilise NFI effectively, further limiting its impact |
| Based on: | |
| Informational | Lack of Common Standards and Inconsistent Terminology: The absence of shared definitions, indicators, and aligned goals across stakeholders complicates effective use, especially for cross-cutting issues like sustainability Fragmentation of Systems: Separate dashboards and monitors with varying standards, definitions and measurement intervals hinder harmonisation and comparability of NFI and its validity for management and benchmarking Low Perceived Credibility of NFI: Unreliable or controversial NFI can be exploited by political opponents, discouraging its use by policymakers and civil servants Gaming and Manipulation Risks and Lack of Independent Verification: Subtle manipulation of indicators (e.g. selective definitions or measurement points) undermines trust, particularly when linked to financial incentives or penalties |
| Based on: | |
| Cultural | Lack of participative and reflective openness: Effective NFI use is hindered when employees don’t feel encouraged to participate in discussions about results or to think critically about how to improve them. More specifically, fear of reporting bad news, defensive routines, or denial strategies can prevent employees from using NFI for discussing underperformance or proposing improvements Political Domination: Political interests may overshadow objective evaluation, discouraging candid discussions of NFI. Lack of Leadership’s commitment to NFI: Leaders who champion performance measurement significantly enhance NFI use. If leaders show no commitment to measured results, this will negatively affect the organisational support for using NFI. Prioritisation of Compliance over Results: Leadership that prioritises compliance over results signal to their organisation that avoiding mistakes is more important than achieving better results. This inhibits the explorative use of NFI for learning and decision-making |
Based on: | |
Organisational obstacles refer to several challenges in aligning managerial, procedural and capacity-related factors and many of them can be alleviated or even eliminated by adaptations of administrative processes and capacity building. The ability of management to flexibly reallocate resources in pursuit of outcome goals is often curtailed by regulation and inadequate mandates in public sector settings. This problem is aggravated if management and budgetary mandates are scattered for cross cutting goals like climate and sustainability. In response to budgetary rigidity, many countries have eased restrictions for virement, often as part of introducing a program budget format. This grants public sector managers autonomy to re-allocate resources and make necessary adjustments during budget execution to meet program goals. Establishing dedicated functions and units for collecting and analysing performance data has been a way to ensure safeguarding required capacity such as, for example, the Chief Performance Officer and Chief Data Officer in US federal agencies. To circumvent the time-constrained budget process, some governments introduced alternative learning routines such as periodical data driven reviews as a vehicle for analysis and learning (Behn, 2014; Moynihan and Landuyt, 2009; Moynihan and Kroll, 2016; OECD, 2018).
Informational obstacles refer to the challenges of achieving consistency, trustworthiness, and alignment, and can largely be addressed by the implementation of reporting standards combined with internal controls and audits. Some studies point to the availability of performance information as the most important significant condition for its use (e.g. Hammerschmid et al., 2013). Low credibility and low comparability of data can however reduce the usefulness of NFI for a performance dialogue. One notable problem for the type of cross-cutting goals that often characterise sustainability agendas has to do with data integrity and comparability of data. This is due to the presence of strong organisational and budgetary silos that are present in governments and are often rooted in legal provisions and sometimes centuries long traditions (Bryan, 2021). For example, if entities each use their own definitions and measurement intervals for measuring GHG emissions, it will be impossible to consolidate the total government’s emissions, as was found in an audit by the Dutch Court of Audit (Algemene Rekenkamer, 2024).
To avoid operational problems with consolidating data, strong horizontal coordination from the centre of government is required that, not unlike financial reporting, regulates and harmonises reporting efforts. Reporting standards can help standardise NFI across reporting entities and help ensure its quality. To prevent gaming and manipulation, powerful financial incentives and punitive use of NFI is better avoided and independent audit capacity should be in place (Moynihan and Beazley, 2016). Independent sourcing of measurement data or auditing by reputable organisations can help reduces uncertainty and enhance trust in NFI reliability.
Finally cultural obstacles refer to the challenges of fostering an open, supportive culture and committed leadership to effectively utilise NFI in public sector organisations. This is the most difficult category to address through reform measures as culture often involves deeply entrenched behavioural patterns and tends to correlate with other factors. In fact, some authors suggest that the right cultural conditions for NFI use require stars at different levels of organisational culture to align: leaders who share a deep belief in performance assessment, a common language on performance and organised routines to assess performance (Taylor, 2014). Ambitious policy agendas such as climate policy are often characterised by ambiguous goals and little knowledge about the best strategies to achieve the goals. With the help of stretched outcome goals, experimentation and pilot programs, exploratory NFI use can be effective way to motivate professional managers and foster innovation (Speklé and Verbeeten, 2014; Metzenbaum, 2015; De Jong and Ho, 2019).
Given this knowlegde, we ought to have realistic if not modest expectations of the potential impacts of the sustainability reporting in annual reports of public sector organisations. Because of the different role of the annual report in public sector decision making and the political context in which decision making largely takes place, we should look at the earlier stages of the budget process and to internal users for the impacts of reported NFI. The actual use of NFI by internal users in these budget phases is inhibited by a number of obstacles that commonly occur in public sector settings.
Towards actual sustainable impact
As stated earlier, sustainability reporting can never be an aim in itself and should be viewed as a step in a value creating process. Therefore the reported NFI is expected to impact decision making that contributes to achieving sustainable objectives and goals. In fact, for investments in sustainability information to pay off, the measuring, reporting and auditing of sustainability NFI should be followed by its utilisation for decisions to help create public value such as lower greenhouse gas emissions, energy saving innovations or more equitable resource allocation and policy outcomes.
Impacts of sustainability reporting are not easy to realise and may be even harder to sustain. A study of six pioneering European cities in sustainability reporting showed that its organisational impacts disappeared over time and that continued usefulness of sustainability reporting for management purposes and external communication was difficult to achieve. In response, several of the investigated local governments experienced “reporting fatigue,” leading to the discontinuation or radical altering of sustainability reporting practices (Niemann and Hoppe, 2018).
Using the available academic knowledge about factors obstructing and enabling the use of NFI should critically guide sustainability reporting initiatives in the public sector. Any investment in costly and labour-intensive reporting requirements for a public sector entity should be preceded by an assessment of the use of existing NFI and of the factors that may have contributed to underutilisation. Addressing these obstacles can help create a more enabling environment for NFI use that can actually help achieve sustainability objectives instead of creating another costly data graveyard.
In this article several challenges were discussed that prevent NFI on sustainability from being used analytically after it is reporting in public sector annual reports. The differences between public and private sector reporting and the lessons learned with the use of NFI from public sector budget cycles have several implications for practitioners seeking to increase the impact of sustainability NFI in public sector annual reports. Six important conclusions and their implications for practitioners are summarised in Table 2.
Conclusions and implications for use of sustainability NFI in the public
| Conclusion on public sector sustainability NFI | Implications for practitioners |
|---|---|
| 1. The information reported in annual reports is unlikely to result in observable impact through decision making in the final phase of the budget cycle | Sustainability information is more likely to impact public sector decision making if it meets information needs of decision makers within government during the earlier budget phases |
| 2. The reported information is often used selectively and follows a political rationality | Sustainability information is more likely to impact public sector decision making if its message is timed and framed to align with political debates. Often this means its use is disconnected from the budget and accountability cycle |
| 3. The materiality of information of public policies easily outweighs the importance and relevance of the own operations for most government organisations | For sustainability reporting to be proportionate, scarce capacity for measuring, reporting, and analysing NFI should focus on major impacts of policy programs and very selectively for government’s own processes |
| 4. Organisational obstacles can challenge an enabling environment for use of NFI in the public sector | Investments in sustainability information should be accompanied by an assessment of obstacles for managerial use of this info. Sustainability reporting initiatives should integrate strategies to ease obstacles such as budget rigidity, inadequate mandates and gaps in skills and knowledge |
| 5. Informational obstacles can challenge an enabling environment for use of NFI in the public sector | Low credibility and low comparability of data can be addressed by a combination of reporting standards, internal controls and audits as well as strong horizontal coordination across organisational and budgetary silos. Independent sourcing of data and audit can help prevent manipulation and gaming |
| 6. Cultural obstacles can challenge an enabling environment for use of NFI in the public sector | Allowing for experimentation and piloting programs can help create an enabling environment for exploratory NFI use that fosters innovation |
| Conclusion on public sector sustainability NFI | Implications for practitioners |
|---|---|
| 1. The information reported in annual reports is unlikely to result in observable impact through decision making in the final phase of the budget cycle | Sustainability information is more likely to impact public sector decision making if it meets information needs of decision makers within government during the earlier budget phases |
| 2. The reported information is often used selectively and follows a political rationality | Sustainability information is more likely to impact public sector decision making if its message is timed and framed to align with political debates. Often this means its use is disconnected from the budget and accountability cycle |
| 3. The materiality of information of public policies easily outweighs the importance and relevance of the own operations for most government organisations | For sustainability reporting to be proportionate, scarce capacity for measuring, reporting, and analysing NFI should focus on major impacts of policy programs and very selectively for government’s own processes |
| 4. Organisational obstacles can challenge an enabling environment for use of NFI in the public sector | Investments in sustainability information should be accompanied by an assessment of obstacles for managerial use of this info. Sustainability reporting initiatives should integrate strategies to ease obstacles such as budget rigidity, inadequate mandates and gaps in skills and knowledge |
| 5. Informational obstacles can challenge an enabling environment for use of NFI in the public sector | Low credibility and low comparability of data can be addressed by a combination of reporting standards, internal controls and audits as well as strong horizontal coordination across organisational and budgetary silos. Independent sourcing of data and audit can help prevent manipulation and gaming |
| 6. Cultural obstacles can challenge an enabling environment for use of NFI in the public sector | Allowing for experimentation and piloting programs can help create an enabling environment for exploratory NFI use that fosters innovation |
Some cultural obstacles towards NFI use will not be easily impacted by the characteristics of sustainability reporting itself (e.g. degree of political domination, leadership attitudes towards NFI). Even then it is useful to be aware of these obstacles to help set realistic expectations. At the very least implementers of sustainability reporting and auditors should be aware of their impact on NFI use within organisations.
So in summary while the annual report and its reporting requirements may present a suitable vehicle for measuring and reporting NFI on sustainability, the opportunities for using this information go far beyond annual reporting itself. Given the experience from prior comparable reforms, we ought to have realistic if not modest expectations of the potential impacts of the sustainability reporting in annual reports of public sector organisations. Because of the different role of the annual report in public sector decision making and the political context in which decision making largely takes place, we should look at the earlier stages of the budget process and to internal users for the impacts of reported NFI.
Public sector audit may both ease and aggravate obstacles for use of sustainability NFI
This article assumes that using sustainability related NFI for decision making is the ultimate goal of investing in better or extra sustainability reporting requirements by the public sector. In fact, this is the view taken by the US Government Accountability Organisation on evidence building and performance management activities in general. GAO identifies three cyclical activities: plan for results, assess and build evidence, and use evidence (GAO, 2023). Most audit recommendations typically address the first two of these phases such as calls for SMART goals and safeguarding information quality. However, the last phase of actually using this information to learn, apply lessons to decision-making and communicate with stakeholders is arguably the most important for creating public value.
When looking at the different obstacles to the use of NFI, better sustainability reporting and auditing can support the use of NFI by reducing informational obstacles. Firstly, audit can help tackle the obstacle of low perceived NFI credibility through better independent verification and audit. This will reduce the risks for both civil servants and political leaders to base decisions on the reported figures as it reduces opportunities for political opponents to seize doubts to discredit the policy involved. Therefore, systematically auditing NFI on sustainability according to widely accepted standards can be expected to be beneficial for using the information in decision making.
Secondly, since sustainability transcends budgetary and organisational boundaries within and between governments, shared standards and definitions are not self-evident. Adopting and auditing uniform reporting standards can stimulate convergence of the current fragmented landscape. Access to reliable and mutually comparable data can be expected to support a meaningful performance dialogue and therefore the use of sustainability NFI.
Finally, in addition to directly easing or eliminating informational obstacles to NFI use, it should be noted that improving external reporting on sustainability may also raise awareness within organisations and thus impact internal decision-making. Recent research on integrated and sustainability reporting by both private and public organisations in the Netherlands seems to support this claim to some extent (de Graaff, 2023).
Notwithstanding the potential benefits of stepping up audit efforts according to detailed new standards, there are also some risks involved that may negatively impact an enabling environment for using NFI for achieving sustainability goals. More specifically, too much emphasis on audit may aggravate some well-known organisational and cultural obstacles to NFI use.
Organisationally, extra or new reporting requirements usually result in more work to measure, report, and analyse new information but seldom lead to the reduction of existing requirements. The capacity to do so has to compete with other, often more high profile, staffing requirements within public organisations. Not surprisingly, a study among municipalities in the Netherlands showed that large ones had a higher success rate according to a sustainable reporting benchmark (De Graaf and De Waard, 2023). In the worst case, analytical use of NFI can even suffer from displaced analytical capacity towards compliance with extra reporting requirements (Posner and Fantone, 2008; Moynihan and Kroll, 2016; Moynihan, 2018).
From an informational point of view, it has to be acknowledged that the cross-cutting character of sustainability and climate related expenditures can obstruct accurate costing. For example, expenditures on a reforestation project may simultaneously serve biodiversity and GHG reduction goals. How much of the costs and results should be attributed to either program will always remain a somewhat arbitrary decision that can be easily criticised. The ways organisations currently cope with this difficult problem are often necessarily imperfect. Some governments and the European Commission use so called Rio Marks to classify expenditures as either 100%, 40% or 0% climate related. Although such crude measures can be easily questioned, auditors should realise that a call for more precision will not eliminate the inherent conceptual complexity and will likely result in additional arbitrary choices. So instead for calling for more precision, it should be accepted that sometimes being approximately right may be better than being precisely wrong.
Culturally, a focus on avoiding mistakes instead of improving performance can be an important obstacle to a results-orientation and learning behaviours in government organisations (Osborne and Plastrik, 1997; Schick, 2003). The need to comply with complex new reporting standards in the face of restricted capacity can trigger or strengthen a managerial focus on compliance instead of innovation and come at the expense of the exploratory use of NFI that many sustainability goals rely on. Indeed, less can be more in this respect.
By being aware of these risks, public sector audit can support impactful sustainability reporting without unwillingly impairing enabling factors for the use of NFI for decision making. Public sector auditors can actively support the use of NFI by moving beyond the traditional call for SMART goals and scrutiny of information quality and also focus attention on an organisation’s need to balance compliance and accuracy with its capacity to process and use information. This involves expanding audit activities towards the missing link between information and behaviour by auditing a broader set of enabling factors for actual use of NFI. An important aspect to focus on is the alignment of externally reported sustainability information and management control systems with the strategic priorities of public organisations. Capacity requirements of public sector sustainability reporting initiatives and the discretionary power of management to reallocate resources are also important enabling factors where audit could offer valuable assurance.
Conclusion
In conclusion, we should realise that reporting sustainability is never an end in itself and should ultimately support the use of the reported information for learning, steering and control and for rendering account. Therefore, the question is how to balance consistency, usefulness and reliability with issues like complexity, realism and workload implications to optimise the utilisation of NFI. Critically applying a dual double materiality concept can be a key tool to separate need-to-know from nice-to-know information requirements.
To increase the likeliness of actual use of sustainability NFI for realising sustainable goals in public sector settings, practitioners should be aware of the obstacles that have often inhibited such use in the past and draw lessons from this experience. Auditors can contribute by performing their traditional role, but also by looking beyond the annual report and by focusing more on the enabling factors for NFI use. Academia can offer more support to the sustainability agenda by more targeted research. Currently the use of sustainability NFI by governments is still understudied, especially the use by central national governments. In particular there is a lack of empirical studies that look into actual use by government managers and politicians. The academic insights from studying obstacles and enabling factors for NFI use could be further hypothesised to test their validity for government sustainability reporting.
Maarten de Jong, Ph.D., is employed as Strategic Advisor at the Netherlands Court of Audit and as Assistant Professor in Public Administration at Erasmus University Rotterdam (EUR). Internationally he has worked in over 20 countries on behalf of the WB, IMF, WHO, EC and OECD to support budget and governance reforms. The article does not express the view of any of the organisations mentioned.
This paper was written during a visiting scholarship at the Department of Political Science and Public Administration of the University of North Carolina at Charlotte that was made possible by the Netherlands Court of Audit and the Erasmus School of Social and Behavioural Sciences at Erasmus University Rotterdam. The author would like to thank two anonymous reviewers and Professor James W. Douglas of UNC Charlotte for their contributions.

