Disclosure Spillovers Through ESG Ratings

ABSTRACT

I examine how mandatory ESG disclosure regulations transmit to unregulated firms through ESG rating agencies’ peer benchmarking. Using the United Kingdom’s 2017 gender pay gap (GPG) disclosure mandate with its expected positive rating consequences for regulated U.K. firms, I show that unregulated firms with similar Refinitiv ESG ratings are significantly more likely to voluntarily disclose GPG information after the mandate. The effect is more pronounced when peers are defined by ESG rating similarity rather than market capitalization and is not driven by industry affiliation alone. Consistent with ESG ratings creating competitive pressures, spillovers are strongest when U.K. peers were initially lower ranked and when unregulated firms can report relatively better GPG performance. Further analyses show that these spillovers extend to other social disclosures and generalize to the European Union’s Non-Financial Reporting Directive. Overall, the paper highlights how ESG rating structures extend the reach of disclosure regulations beyond their formal scope.

Data Availability: Data are available from the public sources cited in the text.

JEL Classifications: M14; M48; D70.