Why sustainability programmes should start with obligations, not impacts

The instinctive way to start a sustainability assessment is to ask what impacts the organisation has on the world. The problem is that question has no edges. Every business activity creates some impact, so without a boundary the assessment becomes unwieldy, and worse, it starts reflecting what the sustainability team happens to think is important rather than what the organisation is actually accountable for.

Start with obligations instead: the laws, regulations, reporting frameworks and voluntary commitments the organisation has to answer to, in every jurisdiction it operates in materially, not just headquarters. That's the same logic ISO 37301 applies to compliance, before you can manage compliance you have to know what you're obliged to comply with. A voluntary commitment, once made, carries the same weight as a mandatory one: a company that's publicly committed to science-based targets has an obligation to pursue them, full stop.

The obligations register does more than bound the assessment. It determines which materiality lens applies, impact materiality under GRI, financial materiality under ISSB, double materiality under CSRD and ESRS, and most organisations of any size are actually subject to more than one at once. It also determines which stakeholders have to be engaged and why, since a CSRD obligation implicates different people than an investor-facing ISSB disclosure does.

The part that gets missed: a sustainability function that can point to its obligations register and say 'this is why we do what we do' has a fundamentally stronger position with the board than one that has to justify its programme by reference to values or reputation. Obligations create accountability, and accountability is what gets a sustainability programme taken seriously at the top of the business, not the other way around.