Sustainability reporting has rapidly expanded as a regulatory tool in global capital markets, yet jurisdictions differ markedly in how international disclosure standards are adopted, designed, and implemented. While international initiatives increasingly promote convergence through global sustainability reporting standards, policymakers and regulators face a persistent challenge: formal alignment with global frameworks has not translated into uniform reporting regimes or comparable disclosure practices.

The thesis develops and empirically examines an integrated pathway model that conceptualises sustainability reporting as a multi-level institutional configuration linking global structural exposure, jurisdictional adoption stance, regulatory design choices, and corporate disclosure outputs. Rather than treating convergence as a linear or technical process, the model provides a structured explanation of how global standards are translated and reshaped through domestic institutions before producing observable reporting outputs.

Empirically, the study proceeds in three stages. First, a cross-jurisdictional analysis of 205 jurisdictions demonstrates that adoption of international sustainability reporting standards is driven primarily by structural exposure to global capital and trade networks, rather than by income level, legal origin, or generic governance capacity. This suggests that adoption is best understood as a response to international economic interdependence rather than as a uniform policy choice. Second, a comparative institutional analysis of the European Union, the United States, and China demonstrates that the adoption does not determine how sustainability reporting functions in practice. Instead, domestic institutional logics translate global standards into distinct and internally coherent regulatory designs. Materiality emerges as the key institutional hinge through which these translations occur, while stabilising regulatory-state (EU), market-legal (US), and state-led hybrid (China) reporting regimes in different configurations of state authority, market coordination, and legal accountability. Third, firm-level analysis using a structured Disclosure Completeness Index capturing 60 firms disclosure practice across ten jurisdictions shows that these design differences are behaviourally relevant. Regulatory regimes characterised by broader materiality scopes, higher legalisation, and clearer regulatory expectations are associated with systematically more complete and forward-looking climate disclosures, particularly in scenario analysis, transition planning, Scope 3 emissions, and assurance mechnisms.

The study contributes to sustainability governance scholarship by demonstrating that sustainability reporting convergence is constrained less by technical standard-setting challenges than by enduring institutional and political-economic differences. The analysis shows that global sustainability reporting frameworks can facilitate coordination and shared vocabularies, but their effects are mediated by domestic accountability structures, legal architectures, and policy objectives. From a policy perspective, this implies that global sustainability reporting “baselines” are most effective when understood as coordinated device and interoperable reference points, rather than as uniform regulatory endpoints. The thesis concludes that future progress in sustainability reporting governance is more likely to d