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Institutional investors and company directors will note that there are three new EU directives that apply to companies doing business in the European Union (EU). Under the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD), and the European Accessibility Act (EAA), disability is recognized as a sustainability matter for companies operating in the EU. All three of directives impact people with disabilities and their involvement in the economy in important ways. Companies that hire employees with disabilities, make products for consumers with disabilities, earn money and loyalty from buyers with disabilities, ask for input from users with disabilities, and mitigate discrimination against workers with disabilities must now analyze disability as a sustainability matter to determine whether to report on disability in their own workforce, value chain, and board of directors.

This issue of Inclusive Governance & Investing Quarterly is inspired by Disability:IN and White & Case recent legal analysis of the CSRD, CSDDD, and EAA (PDF).

The Facts

3,000+

U.S. businesses will be required to conduct a double materiality assessment and report on disability under the EU’s Corporate Sustainability Reporting Directive

2x

The number of companies publishing their disability representation has nearly doubled in the last three years

65%

of major U.S. companies are already reporting on disability in their annual reports

Research

Disability Inclusion in the EU: A Legal Analysis to Guide Corporate Responsibilities Under the New EU Disability Inclusive Legislation by White & Case and Disability:IN with the support from the Thomson Reuters Foundation outlines how the CSRD, CSDDD, and EAA create a robust framework to enhance the inclusion and protection of persons with disabilities in the EU. Companies are required to implement comprehensive policies, conduct diligent risk assessments, and ensure product and service accessibility. By adhering to these directives, companies can contribute to a more inclusive and equitable business environment. Compliance will not only mitigate legal risks but also enhance corporate reputation and foster a more inclusive society. 

Investors can assess companies’ readiness for reporting on disability by looking at Windō’s Disability Transparency Tiles 2024 (PDF), a report that provides insight into leading companies disclosure practices for corporate directors, senior leaders, overall workforce, public statements, and disability indexes. 

Deloitte, one of the world’s most disability transparent companies and Disability:IN’s corporate partner, released a report on Disability Inclusion @ Work 2024 (YouTube) that profiles the perspective of over 10,000 survey respondents.

Their analysis yielded 5 key recommendations:

1. Make disability inclusion a visible, board-level priority
2. Help managers understand and embrace disability inclusion 
3. Embed accessibility into business as usual, including meetings and events 
4. Encourage and recognize the importance of accommodations 
5. Provide a disability inclusive culture and address non-inclusive behavior

Policy & Government Affairs

Plain Language Summary with Comparison Chart – Disability Inclusion in the EU: A Legal Analysis to Guide Corporate Responsibilities Under New EU Disability Inclusive Legislation

Investors are IN

Invest Ahead: Investors for Board Diversity (formerly the Thirty Percent Coalition) is a group of institutional investors, asset managers, and private equity firms representing $8 trillion in AUM who work to increase diversity on corporate boards. Invest Ahead maintains an extensive peer-reviewed academic research database on the connection between board diversity and financial performance. The database is available here.

Boards are IN

The European Sustainability Reporting Standards ask companies to “disclose the composition of the administrative, management and supervisory bodies, their roles and responsibilities and access to expertise and skills with regard to sustainability matters” (Disability:IN and White & Case, p. 26). Companies that deem disability material to their operations or business strategy will begin to disclose disability status in their board diversity matrixes.

Click here to review Boards Are IN: Model Proxies and Disability Inclusive Board Diversity Disclosure Matrixes.

News & Events

• Watch Disability:IN’s webinar featuring the European Financial Reporting Advisory Group and White & Case (Zoom) to learn more technical information about reporting on disability under the European Sustainability Reporting Standards

• Palo Gaudiano’s award-winning new book, Measuring Inclusion, offers real-world case studies, sample data and step-by-step directions to help companies make meaningful and sustainable improvements. Discover an entirely new way of thinking about how inclusion is the key to organizations that enjoy higher performance and greater employee satisfaction. 

Contact Information | Research & Policy Team

Reid Jewett Smith, Ph.D.

Director of Research & Policy

Jacob Wilson

Research & Policy Analyst

Disability:IN Research & Policy Webpage

About Disability:IN

Disability:IN is a global organization driving disability inclusion and equality in business. More than 500 corporations trust Disability:IN to activate and achieve disability inclusion across their enterprise and in the broader corporate mainstream. Through the world’s most comprehensive disability inclusion benchmarking; best-in-class conferences and programs; and expert counsel and engagement, Disability:IN works with leading businesses to create long-term business and societal impact. Join us at disabilityin.org/AreYouIN #AreYouIN

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