The Rise of ESG Controller Jobs

Back in January I flagged the rise of “ESG controller” jobs as one of the corporate compliance events to watch in 2023. Today I want to unpack that idea a bit more, to understand what these jobs entail, whether corporations really are trying to fill them, and what sort of person might be qualified to take one.

Conceptually the job of ESG controller is easy to understand. It’s the person responsible for assuring that any ESG-related disclosures a company makes are complete and accurate, just like a “traditional” corporate controller is responsible for assuring the accuracy of financial disclosures. 

Nor is talk about ESG controllers all that new; advisory firms have chatted up the idea for several years. But as ever more jurisdictions move toward mandatory disclosure of at least some ESG metrics, (such as the European Union’s new Corporate Sustainability Reporting Directive, and whatever climate disclosure rule the U.S. Securities and Exchange Commission will adopt later this year), the urgency to get those disclosures right has gone up. So has the chatter around ESG controller roles.

For example, back in December I attended a conference on SEC reporting issues, and those forthcoming ESG disclosure requirements were all over the agenda. One panel discussion featured a slate of ESG controllers from companies including Google and Bank of America. As one panelist said with decided understatement: “We know it’s going to be a lot of work.”

So how are companies trying to fill that need? What do these ESG controller jobs look like, and what are they trying to accomplish? I poked around on LinkedIn and Indeed.com looking for a few such roles to see what’s out there.

The Jobs Getting Listed

First, jobs with the actual title “ESG controller” are rare. Companies instead seem to be posting lower-level roles that are more about project management to get ESG disclosure efforts up and running. 

For example, Delta Airlines advertised a job several weeks ago for a project manager on the financial reporting team, focused on environmental sustainability. Duties include:

• Act as the subject matter expert on the latest SEC rules, in particular as it relates to climate-related disclosures and other Environmental, Social and Governance (ESG) matters. Monitor, assess and communicate to senior leaders implications of new standards for Delta’s financial statements and other external reports.
• Establish strong processes to prepare and review climate and other ESG-related disclosures and ensure information is accurate, complete and in compliance with SEC and FASB standards, as applicable.
• Act as a liaison between finance, sustainability and legal to establish proper controls around climate and other ESG-related disclosures. Help different functional areas to implement new business processes, data gathering, reporting and protocols.

Netflix listed a somewhat similar job, for a climate data and disclosure manager. The duties include:

• Oversee calculation of our annual carbon footprint, automation of emissions data collection and analysis, and third-party assurance against prevailing standards.
• Identify and evaluate carbon accounting best practices, updated methods, and the latest emission factors from accepted external sources.
•  Qualify M&A activities to be folded into footprint or may trigger rebaselining.

Citigroup recently did list an opening for an actual ESG controller. This role seems more senior than the two mentioned above, and one that addresses a wide range of ESG issues rather than only climate change. Duties include:

• Responsible for oversight and reporting of ESG related disclosures wherever they are disclosed (10-K report, ESG report, etc.).
• Subject matter expert on ESG disclosures, keeping current on evolving disclosure trends in the industry and advising and evaluating.
• Work with Global Public Affairs to create and implement a well-controlled process to collect and report on ESG type disclosures.

To answer a few questions right away: I picked these three examples at random simply because they were the first I found. Some others include a vice president of sustainability at Virgin Galactic; vice president of sustainability at Facebook; and a director of ESG reporting at Mastercard. You can find others through internet searches of your own.

Second, I have no idea whether any of these jobs are still open. I’m just using them to tease out common job requirements.

‘Sustainability’ vs. ‘ESG Controller’

One important question here is where these ESG controller jobs are “born.” That is, are they emerging from corporate ESG programs that suddenly decide they want enough assurance to satisfy external reporting obligations? Or are they arising from external reporting functions suddenly deciding that they should sweep the company’s ESG program into their purview? 

That might sound like hair-splitting, but whichever part of the company is sponsoring an ESG controller job will have more influence over the job description and which candidate gets the job. So this question matters. 

These days the pendulum seems to be swinging away from ESG programs, toward external reporting — largely because regulators are paying more attention to the ESG disclosures that public companies make. The plain truth is that a high-quality sustainability program is nice to have, but rock-solid external reporting is something corporations need to have. It will be easier for the external reporting functions to pick up ESG than it will be for ESG program managers to pick up external reporting, because the risks of getting external reporting wrong are far higher. 

So could we see ESG program managers boxed out of future job opportunities because they aren’t masters of external reporting? Yes. 

On the other hand, we also have external reporting types who won’t be good fits for these ESG controller roles either, because they don’t know how to collaborate with other parts of the business or how to think imaginatively to design processes that capture ESG data. 

For example, one bullet point I see repeatedly on ESG controller jobs is that the ideal candidate will be a subject matter expert on ESG disclosure requirements and related frameworks. How many of those people do you have on your SEC reporting team? Not many, I’m guessing. Heck, it’s still the wild west out there for professional certifications and associations for ESG controllers.

To be clear, I do know numerous compliance and audit executives who have done amazing work building ESG programs, including programs designed to withstand the SEC-level scrutiny that’s destined to come. But we still have a long way to go as the ESG controller job evolves into a standardized, recognized professional role within corporate reporting.

I’ll be fascinated to see how that happens.