Around 150 football clubs across Europe will be required to disclose sustainability data through the Corporate Sustainability Reporting Directive (CSRD), according to the European Club Association (ECA).

In its newly-published sustainability strategy, and through a briefing call with members of the press last week, ECA outlined its plans to help the clubs navigate emerging legislation through practical support and knowledge-sharing opportunities.

Football clubs that are listed on the stock market will be obligated to publish data around certain environmental, social and governance areas for the 2024/25 season, while non-listed clubs across the continent will face different levels of disclosure and timescales depending on their size and structure.

Clubs that have two or more of the following – €40m annual turnover, €20m balance sheet, 250-plus employees – will be required to publish a sustainability report by the 2025/26 season, while clubs more akin to SMEs in size and structure will have to start disclosing the following season with less rigid requirements, said Gaia Pretner, ECA head of sustainability.

She said that UEFA, as well as leagues across Europe, were starting to set the groundwork for disclosure by including sustainability metrics in licensing criteria. The German Bundesliga, for example, has 117 criteria, with several included under the banner ‘environment and resources’, while La Liga’s sustainability requirements have “increased” in recent years.

“This is going to be a big change maker,” Pretner added. “Leagues are receiving a lot of requests from the clubs about how to support them in being compliant with the regulation – it’s the role of leagues, federations and ECA to support clubs in meeting these obligations and matching them with our specific topics.”

Larger football groups owning multiple clubs also meet the threshold if one or more of those properties is in the EU. For example, City Football Group and Clearlake Capital, which own English Premier League clubs Manchester City and Chelsea FC respectively, will be required to disclose because of their controlling interests in Girona FC, Palermo FC (City Football Group) and RC Strasbourg (Clearlake).

As part of its work to support clubs, ECA has established a CSRD Task Force within its broader Sustainability Working Group, which is chaired by Malmö FF chief executive Niclas Carlnén. One of its short-term KPIs is to create guidelines and training courses for clubs around protocols related to CSRD and the European Financial Reporting Advisory Group (EFRAG), the European Commission’s technical advisor for developing the directive.

In the medium-term, by the end of 2027, ECA has set the target of supporting its members in becoming compliant with CSRD. However, the groundwork it conducted ahead of producing its sustainability strategy demonstrated some of the challenges European football faces amid the new regulatory landscape.

As outlined in its materiality matrix, which took into account the sustainability priorities of ECA members, clubs appear to have a greater degree of focus on social issues like anti-racism, equality and safeguarding children, with environmental issues like climate action and addressing unsustainable consumption further down the list.

Pretner explained that this was broadly down to two factors: firstly, clubs, generally, have more experience with tackling social issues and therefore are more likely to emphasise their importance, and, secondly, some environmental issues, like infrastructure sustainability, do not impact every club at the same level.

“In the survey we basically asked clubs: ‘Where do you feel stronger and where do you need more help?’ And it was so evident that the environmental area is where they feel they need help and support,” she added. 

From his own perspective, as the leader of a club, Carlnén agreed with Pretner’s assessment of the situation.

“Since we were founded at the beginning of the 1910s social impact has always been there,” he said. “In Sweden, we only have two clubs in the top league that own their stadium, so the only thing we can impact is travel and perhaps influence our spectators to travel in a more sustainable way.”

As part of the CSRD requirements, organisations are only obliged to report on sustainability issues that are relevant – or material – to their organisation. This should be done through a double materiality process, in which disclosing organisations take into account not just their impact on the wider world, but how environmental and societal issues are impacting their core business.

While football clubs, traditionally central to their communities, have prominently addressed social issues, every European club is now impacted by climate change to varying degrees based on their location.

Using UEFA’s Strength Through Unity sustainability strategy as a template, ECA has outlined four environmental pillars (circular economy, climate and advocacy, event sustainability and infrastructure sustainability) as well as seven social priorities.

Climate and advocacy KPIs overlap with many ESRS indicators required for CSRD compliance (see below). For example, ECA’s short-term target is to measure its carbon footprint and establish a reduction strategy by 2025, with all ECA member clubs adhering to the reporting requirements by 2027.

However, through CSRD requirements, clubs will also have to explore how they can not only mitigate their climate impact through a reduction of their own emissions and investments in carbon removal projects, but also how they are adapting their business model and operations to the changing climate.

Pretner hopes that through the ECA CSRD Task Force, a group of pioneering clubs will step up and help to clear the path for their counterparts across the continent.

“They are the pioneers and their experience will prove to be very important to understand how we can support the others and many more that will come next year,” she said. 

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