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The Failure of Transparency as Self-Regulation

Vigneau, Laurence; Adams, Carol

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Laurence Vigneau


Purpose: This article examines the existence of a transparency gap between voluntary external sustainability reporting and internal sustainability performance of an organisation arising from the operationalisation of transparency as an instrumental tool. Method: We combined an analysis of a firm’s sustainability report (secondary data) with a qualitative case study data (primary data comprising interviews, meetings and internal documents) to understand how the Global Reporting Initiative (GRI) sustainability reporting guidelines are applied in practice. Findings: By comparing what is reported with a range of primary case study data, we find evidence of transparency gaps, particularly in terms of the quality of measurement of sustainability performance, the materiality of issues covered, and the completeness of the report. We posit that voluntary disclosures following the GRI guidelines (transparency technique) shape the external expression of acceptable corporate behaviour (transparency norm) that is nevertheless at odds with actual behaviour or performance. Practical implications: Our findings indicate the importance of mandatory sustainability reporting requirements that facilitate accountability to all key stakeholders and that are externally assured and enforced. Such requirements might take the form of Standards that put boundaries on judgement and address material sustainable development impacts and that are accompanied by implementation guidance. Non-financial assurance practices must be developed to cover adherence to reporting principles and processes. Social implications: Transparency gaps that result from voluntary disclosure guidelines or standards being used to imply a transparency norm may undermine accountability for the impacts of the organisation and hinder alignment of business models and corporate strategies with sustainable development. Originality/value: The paper contributes to a theoretical understanding of transparency as a form of self-regulation and has implications for the further development of sustainability reporting standards.


Vigneau, L., & Adams, C. (2023). The Failure of Transparency as Self-Regulation. Sustainability Accounting, Management and Policy Journal, 14(4), 852-876.

Journal Article Type Article
Acceptance Date Nov 9, 2022
Online Publication Date Feb 20, 2023
Publication Date Jul 18, 2023
Deposit Date Nov 9, 2022
Publicly Available Date Nov 9, 2022
Journal Sustainability Accounting, Management and Policy Journal
Publisher Emerald
Peer Reviewed Peer Reviewed
Volume 14
Issue 4
Pages 852-876
Public URL


Accepted Journal Article (514 Kb)

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Copyright Statement
This author accepted manuscript is deposited under a Creative Commons Attribution Non-commercial 4.0 International (CC BY-NC) licence. This means that anyone may distribute, adapt, and build upon the work for non-commercial purposes, subject to full attribution. If you wish to use this manuscript for commercial purposes, please contact

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