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Social and Environmental Responsibility & Corporate Social Responsibility

The differences between the French and American markets
July 6, 2026 by
Social and Environmental Responsibility & Corporate Social Responsibility
Isabelle Frey

Reading time: 8 minutes

Written by Isabelle Frey - Article published in January 2023, updated in July 2026

CSR, CSR, ESG: simple definitions


CSR / CSR: the approach

CSR is the common term in France and Europe (Corporate Social Responsibility). CSR (Corporate Social Responsibility) is the dominant term in the United States, popularized as early as 1953 by Howard Bowen (Social Responsibilities of the Businessman, University of Iowa Press, 1953).

It is the approach: what the company decides to do in terms of priorities, action plan, governance, and management of its impacts.

ESG: the measurement framework

ESG (Environment, Social, Governance) is the framework that allows for structuring issues, measuring indicators, reporting, and comparing performances.

Practical rule: CSR = the "what, why, how"; ESG = the "how we prove".

Why does CSR look different in Europe and the United States?

To understand CSR in the United States, we need to look at the relationship Americans have with businesses. Anglo-Saxon culture, and particularly Americans, have an admiration for self-made men. This fascination facilitates the trust Americans have in businesses. In contrast, in France, the French have a greater distrust of businesses.

This relationship with business partly explains why CSR is approached differently from one country to another. In the United States, CSR is not a societal issue, regulations are less significant and less binding. The mere act of creating wealth is seen as a contribution to the development of society. In this country, when a company engages in CSR efforts, it is therefore more a matter of individual will, particularly that of entrepreneurs who see added value in it.

One of the most emblematic American companies regarding its environmental commitments is the clothing brand Patagonia. Indeed, founder Yvon Chouinard made headlines in 2022 by giving 100% of the company's capital to organizations responsible for protecting the planet. This approach reflects the individual and personal desire of the founder to act and transform the impact of his company.

Stakeholders: who really matters?

In the United States, attention has long been focused on shareholders and consumers — through market pressure, reputation, and legal risk.

In France and Europe, the "stakeholder" approach is generally broader: employees, suppliers, territories, civil society.

Regulation: soft law vs hard law

Europe has a tradition of binding frameworks, common standards, and transparency obligations. The United States favors voluntary approaches, with regulatory requirements varying by state.

This contrast remains structural, even though both areas have experienced significant changes since 2024.

The lack of regulations is explained by the low interference of the State in the American economic system. The intervention of public authorities in the economy is very poorly perceived by Americans. It is therefore up to companies to decide on their social, environmental, and societal projects; they are free to use them as they see fit and have the freedom to implement CSR projects or not. It is thus considered that companies, just like individuals, are responsible for their actions and must or must not implement responsible actions. In general, CSR is primarily a voluntary initiative motivated by the desire of companies to improve their reputation and attract socially responsible consumers. The implementation of CSR approaches can also stem from pressures exerted by shareholders or consumers. A perfect example is BlackRock, one of the most influential American investors on the planet, which informed its clients in 2018 that they could no longer be content with just making profits but would also have to contribute to society if they wanted to continue to benefit from the group's support.

However, the fact that companies are not constrained by strict regulations like in France allows them to have greater leeway. They are free to choose their battlefield and often have their projects driven by employee volunteering, which can advance projects further than in France.

Companies act on their own, without structured and aligned collective efforts in the same direction, consequently reducing the societal impact of their projects. Without a determined framework, without pressure from consumers, or without recognition of the benefits brought by CSR initiatives, many American companies will not change their business model for the moment.

Europe: the rise of ESG… and the simplification phase (2025–2026)


CSRD and ESRS: sustainability reporting in reconfiguration

The CSRD (Corporate Sustainability Reporting Directive) regulates sustainability reporting in Europe, supported by the ESRS standards (European Sustainability Reporting Standards), adopted via delegated act (EUR-Lex, first set).

What has changed recently: the EU has initiated a so-called "stop-the-clock" mechanism and a package of simplification/competitiveness, with calendar delays and a tightening of the scope of certain obligations. (Source: Council of the European Union, 2025; Reuters, 2025)

The bottom line remains: the demand for ESG transparency is maintained. It is the pace and the scope that are evolving.

CS3D: the European duty of vigilance adopted in 2024

The European directive on the duty of vigilance — CS3D, Directive (EU) 2024/1760 — was adopted in May 2024. Its scope has been significantly reduced compared to the initial proposal of 2022.

It imposes on the large companies concerned a due diligence process to identify and prevent their impacts on human rights and the environment in their value chain. (Source: EUR-Lex, Directive 2024/1760)

In France, this framework is linked to the law on the duty of vigilance, adopted as early as 2017 (Légifrance, official text).

United States: a more contested ESG framework at the federal level, more active at the state level


SEC: the climate rule abandoned in 2025

The SEC had adopted in March 2024 a rule requiring publicly traded companies to disclose their climate data in their financial reports. Immediately challenged in court, this rule was suspended. On March 27, 2025, the SEC voted to end its legal defense — effectively abandoning the federal climate reporting requirement. (Source: SEC.gov, 2025)

Direct consequence: American companies cannot rely on a single federal framework for ESG reporting. They align with the requirements of their clients and investors, and with the obligations of the markets in which they operate — notably the EU.

California: major climate laws, a shifting timeline

California is an exception at the state level. The SB 253 and SB 261 laws impose climate reporting obligations on large companies operating in the state. These laws have experienced judicial twists in 2024–2025, but the competent authority (CARB) is making progress on the implementing texts. (Source: AP News; Deloitte Dart, 2025)

The "S" (Social): a visible contrast in labor law

Two concrete benchmarks:

  • In the United States, the principle of employment-at-will is the standard: the employment relationship can be terminated by either party "at any time", except for exceptions related to discrimination. Federal law (FLSA) does not require payment for unused vacation or holidays: it is largely contractual. (Sources: Legal Information Institute; Department of Labor)
  • In France, the general rule is 30 working days of paid leave per year (5 weeks) for a full year. (Source: Service-Public.fr)

Proving your approach: ISO 26000, labels, and ratings


ISO 26000: the international reference framework

ISO 26000 provides guidelines for integrating social responsibility into the organization's strategy and practices. It is not a certifiable standard: it is a structuring guide. (Source: ISO.org)

B Corp: what the reader should know

B Corp certification is based on a minimum score of 80 on the B Impact Assessment, a recertification every 3 years, and maintenance requirements published by B Lab. The framework evolves regularly. (Source: bcorporation.net)

Positive Company® Label: a graduated European approach

The Positive Company® label is a French CSR label structured around ISO 26000. It allows a company to have its CSR approach evaluated and recognized, with a framework graded according to the size and maturity of the organization.

How to choose your approach ?

If your main issue is external recognition : A label helps to frame, evaluate, and make your commitment clear: evidence, audit, external communication. 

→ The Positive Company® supports companies from the initial diagnosis to labeling.

 Discover the Positive Company® label  


If your main issue is risk management and the value chain: A supplier scoring allows you to evaluate, prioritize risks, build improvement plans, and manage responsible purchasing (ESG in the supply chain). 

→ Scoring by Positive evaluates the CSR maturity of your suppliers, without charging them for the process.

 Discover Scoring by Positive®  

❓ FAQ - CSR / RSE

It’s the same concept — the responsibility of the company towards society and the environment — with different cultures and regulatory frameworks. Europe tends towards a more harmonized and binding approach; the United States towards more fragmented and voluntary approaches.

It depends on the country, size, sector, and market. In Europe, obligations exist through the CSRD and the ESRS, with recent adjustments to the timeline and scope. In the United States, there is no longer a federal climate reporting rule since the SEC rule was abandoned on March 27, 2025. (Source: SEC.gov, 2025) 

The CSRD focuses on reporting: transparency, data, publication. The duty of vigilance — French law from 2017 and the CS3D directive (EU Directive 2024/1760) — focuses on processes: identifying and preventing impacts on human rights and the environment in the value chain.

Because the pressure also comes from their customers, investors, and international markets. Companies that sell or operate in Europe must comply with European obligations (CSRD, CS3D). International frameworks like the ISSB (International Sustainability Standards Board) also structure a gradual convergence of standards. (Source: SEC.gov; IFRS Foundation / ISSB)

How to choose your approach ?

Do you want to structure and have your CSR approach recognized? → The Positive Company® Label supports you from the first diagnosis to the labeling.

Discover the Positive Company® Label


Are you managing a supply chain and want to assess your suppliers? → Scoring by Positive evaluates the CSR maturity of your suppliers, without charging them for the process.

 Discover Scoring by Positive®  

🔗 Sources:


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