Beyond reporting: sustainability as a cognitive construct of the company

Data, policy and positioning: how companies help define the concept of sustainability between the CSRD, Corporate Political Responsibility and public authority.

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In the current European regulatory context, Directive (EU) 2022/2464 (CSRD) marks a paradigm shift: from the simple reporting of environmental and social impacts to a more comprehensive form of transparency that also covers lobbying activities, political influence and corporate public narrative. In other words, it is no longer just a matter of declaring what a company does, but also why, with which actors and with what impact on the public space.

The study by Clara Heinrich, published in Business and Politics (2025), introduces a key concept for understanding this scenario: epistemic business power, i.e. the ability of companies to actively contribute to the construction of public meanings and priorities. This article offers a reflection that brings together the regulatory dimension (the CSRD and Delegated Regulation 2023/2772), the conceptual evolution towards Corporate Political Responsibility (CPR), and corporate strategies for positioning in the public debate.

Beyond CSR: the epistemic power of companies

According to Heinrich, corporate power is not confined to the traditional channels of lobbying or advocacy, but extends to a deeper and less visible level: the cultural and cognitive one. Through studies, data, media relations and narrative activities, companies take part in shaping how society interprets and addresses the great collective challenges.

This role takes concrete form in the ability to offer interpretative keys and solutions, helping to steer the frames of meaning (framing) that precede every political and regulatory decision. Companies thus become producers of reliable and accessible knowledge, strengthening a more aware public debate, better informed and geared towards finding sustainable solutions.

CPR + CSRD: a new standard of strategic transparency

We have already described the evolution from CSR to Corporate Political Responsibility (CPR), which is now fully integrated into the principles of the CSRD. The four operational areas (Bohnen, 2020) – responsible lobbying, strategic positioning, political co-participation, provision of public goods – now fall within the scope of mandatory reporting.

Delegated Regulation (EU) 2023/2772 and Article 29b of the CSRD require companies to:

  • describe their commitments relating to institutional representation and public activity;
  • clarify the company’s issues and public positioning;
  • explain the link between these activities and material ESG impacts;
  • provide quantitative data on political contributions and public registrations.

This is not merely a formal requirement, but a genuine cultural shift: the public role of companies, once confined to grey areas or deemed marginal, now becomes a strategic factor to be governed, communicated and reported on responsibly.

Recognising and leveraging cognitive power: tools for mapping epistemic authority

As Heinrich points out, the cognitive influence of companies does not manifest itself through interest representation, but through the construction of shared meanings and the setting of priorities in public discourse. Although this presence is less tangible than traditional indicators, it can nonetheless be analysed and leveraged with more advanced tools.

The integrated use of semantic AI, political data analysis and narrative monitoring now makes it possible to track the spread of the concepts and themes promoted by a company across the media and institutional documents, to assess the consistency between ESG communication and public positioning, and to build a solid, credible corporate narrative capable of strengthening reputation.

In this context, political data management is emerging as a strategic lever for the governance of transparency, fostering a balance between internal accountability and external authority that is fully aligned with the principles underpinning the CSRD.

Governing public positioning: from data to strategic direction

Leveraging companies’ epistemic authority, however, requires a change of approach. Communicating responsibly is no longer enough: companies need to equip themselves with conscious governance that integrates ESG reporting, institutional communication and narrative oversight.

In this sense, political data management serves as a tool for strategic direction. It is not only about monitoring public presence: it makes it possible to steer, methodically, the construction of corporate reputation on the issues that matter.

Companies that want to lead the sustainable transition will therefore need to act with clarity towards their stakeholders, actively engage in the public debate, and ensure consistency between stated objectives, shared data and the vision they communicate.

Next steps for companies (2024–2026)

In the coming months, Public Affairs, Sustainability, Communications and Legal teams will be called upon to act in a coordinated manner to address the changes introduced by the CSRD.

Companies will therefore need to:

  • Verify whether the obligation applies: the first companies subject to the CSRD start reporting as early as 2025 (on 2024 data).
  • Map existing political influence activities: contributions, memberships, institutional relations, advocacy.
  • Define consistent narrative and metric standards: align ESG communication and public positioning.
  • Activate traceability tools: digital platforms, blockchain, knowledge management (e.g. KMIND).
  • Integrate cross-functional teams: CSR, Public Affairs and Communications working together on the governance of public reputation.
  • Invest in political data analysis tools to monitor narrative presence, anticipate crises and build epistemic authority.
Conclusion: reporting on power in order to exercise it legitimately

Epistemic power is no longer a theoretical concept: it is a concrete dimension of corporate sustainability and reputation. With the CSRD, companies are called upon not only to make their cognitive and political impact visible, but to demonstrate how they contribute, with transparency and method, to building a shared horizon.

For those working in Public Affairs, Sustainability or Communications, the task is no longer just compliance: it is narrative and institutional leadership. A challenge and, at the same time, an opportunity to be an active part of change.