Uncommitted Deliberation? Discussing Regulatory Gaps by Comparing GRI 3.1 to GRI 4.0 in a Political CSR Perspective

In this paper, we compare the two Global Reporting Initiative (GRI) reporting standards, G3.1, and the most current version G4.0. We do this through the lens of political corporate social responsibility (CSR) theory, which describes the broadened understanding of corporate responsibility in a globalized world building on Habermas' notion of deliberative democracy and ethical discourse. As the regulatory power of nation states is fading, regulatory gaps occur as side effects of transnational business. As a result, corporations are also understood to play a "political role" to fill regulatory gaps and contribute to a global governance system by voluntarily engaging in self-regulation. Such corporate political action, however, is not always legitimate as it suffers from a democratic deficit (corporations/managers are not democratically elected or controlled). Consistent with scholars in the field of political CSR, this paper argues that only by means of communication and discourse can this drawback be avoided. That is why CSR reporting and guidelines for standardizing the disclosed CSR information is key for political CSR. By comparing the GRI standards from a political CSR perspective, one can see whether these often-used reporting guidelines fulfill the communicative requirements and whether they are adequate tools to face the challenges of the twenty-first century. We present results from a theoryderived and criteria-driven comparison of the two guidelines. Indication of the effectiveness of voluntary self-regulation is, for example, important considering the 2014 directive of the European Union to make CSR reporting mandatory. We offer a guideline-based view on current CSR theory as well as CSR reporting practice. We discuss implications for CSR theory, particularly the appropriateness of (idealized) deliberation in the Habermasian sense, which is the basis of political CSR theory. We do so by introducing the notion of "uncommitted deliberation" with regard to the refined concept of materiality in GRI 4.0, which induces subjectivity and reduces data-driven comparability. Finally, we address the limitations of this research as well as research questions for future studies.