Who's actually reading your ESG report?

When a Canadian company publishes its ESG report, it opens with a familiar gesture — an all-inviting “to whom it may concern.” But unlike a financial report, which speaks primarily to capital providers, a sustainability report is meant to address everyone a business touches: investors, employees, customers, communities, regulators, Indigenous nations, suppliers and even the planet itself. So who, exactly, are TSX 60 companies talking to? And are they listening?

Researchers affiliated with the Climate Business Institute Impact Lab Climate Measures and Reporting at the John Molson School of Business set out to answer that question by examining how the 58 TSX 60 companies that publish ESG reports self-identify their stakeholders. Fifty disclose this information; eight do not. The picture that emerges is instructive for any Canadian business preparing to disclose, or to read, a sustainability report.

A crowded room

On average, TSX 60 firms name seven different key stakeholder groups, with some listing as few as three and others as many as thirteen. Longer lists may look inclusive, but they raise a concern: when a company claims to engage meaningfully with a dozen constituencies, how deep can any single conversation really go?

The usual suspects

Shareholders and investors top the list, with 63 mentions across the 50 reports — unsurprising given that financial materiality remains the dominant lens under several sets of sustainability reporting standards (SASB, TCFD, and IFRS S1/S2). Other stakeholders mentioned are: employees (43 mentions), communities (40), customers (36), and suppliers (33). Indigenous communities appear 16 times, a meaningful figure in the Canadian context, though arguably still low given the stakes. Debtholders, despite being primary providers of capital, are mentioned only once.

Grouped more broadly, financial, social, and employee stakeholders appear in nearly every report. Yet only 60% of the sample identifies regulators as key stakeholders, a striking omission in an era of Anti-greenwashing Bill C-59 and expanding global disclosure regimes.

Vague labels, variable depth

The more telling finding lies in how stakeholders are defined. Some firms offer granular classifications — persons with disabilities, academic institutions, dealers and brokers, franchisees — each tied to a specific business model. Others lean on sweeping categories such as “communities,” “customers,” “partners.” Broad labels are easy to write but difficult to act on. Specific labels, by contrast, signal a mature materiality assessment and clearer pathways for measuring outcomes.

This heterogeneity matters. A long tail of rarely mentioned stakeholder types points to a wider problem. Because there is no standard for how Canadian firms identify the audiences their sustainability disclosures are meant to serve, two companies in the same sector can produce reports that barely overlap in stated audience and, therefore, in what each considers material.

What this means for Canadian business

For management, investors and boards, the implications are practical.

First, stakeholder lists are an early tell of reporting quality. A report that names thirteen stakeholder groups without explaining how engagement with each informed the material topics is likely doing less analytical work than it appears to be. A report that names five, with precision, often does more.

Second, the absence of debtholders and the thin treatment of regulators suggest blind spots that will become more difficult to defend as anti-greenwashing rules and, potentially, mandatory climate disclosure take hold. Lenders and regulators are not silent audiences, rather they are rewriting the rules.

Third, the gap between generic and specific stakeholder identification is, in effect, a gap in governance. Boards reviewing their company’s ESG report should ask a simple question: could a reader tell, from this document, who we actually engaged with, what they told us, and how it changed our priorities?

As disclosure expectations continue to tighten in Canada, the firms that earn credibility will be those that move past the “to whom it may concern” formulation and write instead to specific, well-understood audiences they can actually name.

Read the full article in 2025 ESG Reporting Radar: Heydari, M., Bodur, O., Moldovan, R., & Wei, Y. (2025). To Whom It May Concern: Who Are the ESG Stakeholders?. In H. Al Maleh et al. (Eds.), 2025 ESG Reporting Radar: TSX 60 Spotlight (pp.25-28). Climate Business Institute, Concordia University, John Molson School of Business, Montreal, Canada.

About the John Molson Climate Business Institute 

The John Molson Climate Business Institute (CBI) focuses on rethinking how businesses operate to better align with environmental goals, social well-being and organizational principles. By conducting practical research, collaborating with stakeholders and offering educational programs, the institute drives meaningful change and helps businesses tackle the challenges of the modern world. 

About the Climate Measures and Reporting Impact Lab

The Climate Measures and Reporting Impact Lab drives business decarbonization and environmental progress through research, teaching and community engagement. It focuses on improving climate-related communication, guiding businesses in transitioning to sustainable models and enhancing methods for measuring and managing emissions. By aligning strategies with sustainability goals, the lab helps organizations meet stakeholder expectations, improve decision-making and build trust in their environmental performance.