This study aims to investigate whether the gender of feedback providers influences the quantitative characteristics and narrative content of submissions to the European Commission’s public consultation on the draft European Sustainability Reporting Standards (ESRS). The objective is to assess if gender shapes linguistic patterns or disclosure tendencies. It also examines whether gender affects substantive positions within a highly technical and institutionalised regulatory environment.
The analysis is based on 276 ESRS feedback documents submitted between June 2023 and July 2024. This study excluded files lacking sufficient information to infer respondent gender. Using a mixed-methods approach, this study combines frequency statistics, chi-square tests, logistic regression and lexical analysis with WordSmith Tools 9.0. This approach enables examination of structural linguistic features, co-occurrence networks and thematic patterns. Robustness tests address potential confounding factors such as country, organisation type and document length.
Results show no statistically significant gender differences in any quantitative or qualitative dimension of the submissions. Men and women use similar vocabulary, sentence structures, collocations and thematic clusters. This reflects the strong discursive constraints of ESRS technical consultation. Concordance and clustering analyses reveal four stable semantic domains: regulatory/procedural, materiality-related, technical/environmental and organisational/social. The structure of these domains remains consistent across genders. This absence of divergence demonstrates a high level of institutional linguistic homogenisation among contributors.
This study provides the first large-scale evidence on gender-related linguistic behaviour in EU sustainability reporting consultations. It shows that gender does not influence the nature or framing of ESRS feedback. This supports the interpretative neutrality and procedural coherence of public consultation processes. The findings also contribute to research on institutional discourse. They show that highly standardised regulatory contexts can neutralise individual linguistic variation.
