The Global Reporting Initiative (GRI) and the International Sustainability Standards Board (ISSB) have turned sustainability disclosure into a global governance infrastructure. Many companies now report accordingly. Their stated goals are transparency, comparability, and accountability.
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A new article by Kennedy Prince Modugu, published in Accounting Open, examines the ontological and epistemological assumptions of these initiatives from an accounting perspective. The study claims that Western, capital‑centric views root most of these initiatives. In other words, their foundations determine what to measure, what to audit, and what to link to enterprise values.
As a result, local subjective values are often marginalized or treated as secondary. These include local knowledge, relational ethics (such as Ubuntu or Buen Vivir), and justice‑oriented concerns.
Modugu’s argument is not against global standards as such. Instead, it is a call for epistemic pluralism: accepting that sustainability exists across cultures, ecologies, and economies.
Subsequently, the author proposes PASS (Plural Accountability for Sustainability in the South). PASS is a heuristic framework asking three principal questions: Who knows? What matters? To whom, with what effect? PASS is not a new reporting standard or regime. It is a diagnostic lens to discover who gets to define materiality, whose knowledge counts as evidence, and whether disclosure actually leads to transformative accountability.
You can find more about the paper through the tabs below.
Accounting for pluriversality: Decolonizing sustainability reporting in the Global South
Global sustainability reporting: enabling diffusion or epistemic colonialism?
The paper draws on critical accounting, dialogic accounting, postcolonial theory (Said, Spivak, Bhabha), and decolonial thought (Mignolo, Santos, Quijano). It treats sustainability reporting not as a neutral tool but as a discursive practice of power and knowledge – shaping what can be seen, said, and governed.
Key critiques
- Ontological hierarchy: ISSB treats socio‑ecological phenomena as relevant only when translated into financial risk. GRI’s impact ontology is broader but still privileges measurable, auditable evidence.
- Epistemic injustice: Local knowledge (e.g., indigenous ecological monitoring, oral histories, community‑based narratives) is often dismissed as non‑comparable or insufficiently verifiable.
- North‑South asymmetries: Standard‑setting processes dominated by Global North actors (large corporations, accounting firms, financial markets). Costs of compliance are higher for SMEs and local organisations in emerging economies.
- Mimicry and symbolic compliance: Postcolonial theory (Bhabha) reveals that adoption of global standards in the South can be ambivalent – simultaneously conforming and subverting – but without dialogic spaces, local reinterpretations remain invisible.
Institutional vs. critical perspectives
The paper does not dismiss institutional or legitimacy theories. On the contrary, it acknowledges that global standards can diffuse disclosure, professionalise practice, and attract capital. However, critical and decolonial lenses reveal a hidden problem. Even well‑intended frameworks carry coloniality of knowledge. They universalise Northern ways of knowing. At the same time, they treat alternative forms of knowledge as merely anecdotal.
Consider a mining company that displaces indigenous communities. Under GRI’s impact assessment, this displacement counts as a profound social harm. But under ISSB, it becomes reportable only if it triggers litigation or supply‑chain disruption. Therefore, the problem is not a complete lack of recognition. Rather, it is a hierarchical ordering of concerns.
Materiality as the operational hinge of epistemic closure
Materiality translates abstract philosophical commitments into concrete disclosure decisions. It is here that ontological and epistemological assumptions become visible – and where power is exercised.
- Concerns: cash flow, access to finance, cost of capital.
- Affected stakeholders included only indirectly (via financial effects).
- High comparability, low epistemic pluralism.
- Risk: social/environmental harms become reportable only when legally or financially consequential.
- Concerns: significant impacts on economy, environment, people.
- Stakeholder engagement encouraged, but still managerially controlled.
- Broader ontology, but assurance demands still privilege quantifiable data.
- Risk: local concerns may be translated into standardised indicators, losing their moral urgency.
Why materiality fails the Global South
- Access barriers: Marginalised communities often lack the institutional infrastructure to participate in formal materiality assessments.
- Translation losses: Concerns about land tenure, customary rights, or intergenerational equity become ‘material’ only after being reframed in investor‑centric language.
- Assurance bias: What cannot be audited tends to be relegated to narrative or omitted. Indigenous ecological knowledge rarely fits assurance templates.
PASS: Plural Accountability for Sustainability in the South
PASS is a diagnostic lens – a set of analytical questions – to interrogate sustainability reporting practices, not to replace the GRI or ISSB. It consists of three interlocking arcs (decolonial epistemology, contextual ontology, transformative accountability).
An African mining company formally adopts GRI indicators on community engagement, but its actual accountability practices are shaped by Ubuntu (“I am because we are”) – emphasising communal obligations that exceed the standard’s requirements. PASS would not replace the GRI, but would ask: does the reporting system make this ontological difference visible, or does it force Ubuntu to be translated into generic metrics that strip its meaning?
How PASS differs from existing frameworks
- Not a competitor to ISSB or GRI: It is a critical heuristic for researchers and reflective practitioners, not an operational standard.
- Diagnostic, not prescriptive: It reveals hidden assumptions and power dynamics, leaving space for contextual adaptation.
- Rooted in dialogic accounting: Emphasises contestation, refusal of closure, and the legitimacy of multiple, conflicting accounts.
- Attentive to mimicry and subversion: Recognises that Southern actors may strategically adopt global standards while inflecting them with local meanings – but asks whether such subversions are captured or erased by assurance processes.
Implications for practice, policy, and scholarship
The paper does not offer easy solutions, but outlines directions for more reflexive, plural, and just sustainability reporting in Global South contexts.
For practitioners and boards
- Treat materiality as a deliberative practice, not a one‑off filter. Explicitly ask: which perspectives shaped this list? whose concerns are marginalised?
- Experiment with dialogic engagement – e.g., shadow reporting, community‑based counter‑accounts – alongside formal assurance processes.
- Recognise that compliance with global standards does not automatically equal meaningful accountability. Disclose trade‑offs between enterprise value and local harms.
For policymakers and standard‑setters
- Acknowledge epistemic and ontological diversity in convergence efforts. Harmonisation should not come at the cost of erasing locally salient impacts.
- Build regulatory space for contextual adaptation, especially in emerging economies. Avoid “one‑size‑fits‑all” mandates.
- Learn from the European Union’s double materiality (CSRD/ESRS) but remain critical of its assurance‑driven implementation in low‑capacity settings.
For researchers: future research agenda
Key takeaway
Sustainability reporting is not a technical fix; it is a contested, world‑making practice. The paper’s most powerful contribution is to shift the conversation from “how to improve standards” to “what worlds do these standards make possible, and which do they leave unarticulated?”. PASS offers a structured vocabulary for asking those questions – without pretending that the answers are easy or universal.
References
Modugu, K. P. (2025). Accounting for pluriversality: Decolonizing sustainability reporting in the Global South. Accounting Open, 100009.
Key works cited: Adams & Abhayawansa (2022); Brown & Dillard (2014, 2015); Cho et al. (2015); Fricker (2007) – epistemic injustice; IFRS Foundation (2023); GRI (2021); Mignolo (2011); Santos (2014); Spivak (1988); and others.
Acknowledgements: The author used Grammarly for grammar editing. No external funding was received. The author declares no competing interests.
