Navigating The Sustainability Journey - The Impact of Mandatory Reporting On Travel & Tourism

NAVIGATING THE SUSTAINABILITY JOURNEY: THE IMPACT OF MANDATORY REPORTING ON TRAVEL & TOURISM
NAVIGATING THE
SUSTAINABILITY JOURNEY:
THE IMPACT OF MANDATORY REPORTING
ON TRAVEL & TOURISM
March 2024
World Travel & Tourism Council 1
CONTENTS
FOREWORD 3
EXECUTIVE SUMMARY 4
MOVING FROM VOLUNTARY TO MANDATORY 5
STAKEHOLDER DEMANDS ON SUSTAINABILITY 5
UPCOMING MANDATORY REGULATIONS 7
SUSTAINABILITY AS A COMPETITIVE ADVANTAGE 9
SUSTAINABILITY OPPORTUNITIES AT THE SECTOR LEVEL 9
SUSTAINABILITY OPPORTUNITIES AT THE COMPANY LEVEL 10
COMMON CHALLENGES FACING TRAVEL & TOURISM 11
SECTOR-SPECIFIC CONSIDERATIONS 13
SUSTAINABILITY READINESS ROADMAP 15
SUSTAINABILITY REGULATION APPLICABILITY SELF-ASSESSMENT 16
SUSTAINABILITY MATURITY SELF-ASSESSMENT 18
RECOMMENDATIONS BY THEME 20
ACKNOWLEDGEMENTS 25
ABBREVIATIONS 26
APPENDIX 1: COMPANY ARCHETYPES AND ILLUSTRATIVE RECOMMENDATIONS 27
APPENDIX 2. REGIONAL ADOPTION OF CLIMATE-RELATED DISCLOSURE STANDARDS 28
REFERENCES 31

FOREWORD
Every major corporate governance shift in history has followed a simple pattern: first
crisis, then action. The last change came in 2008. The financial crash was a crisis of
corporate governance, in which power was concentrated in all the wrong places. What
followed was an overhaul of financial regulation that transcended countries and sectors,
on a scale scarcely seen since.
This time, the crisis is planetary. Global temperatures are rising and ecosystems are at
risk. In response, governments and institutions are making changes to the way companies
disclose their sustainability information. Tourism is no exception, and travel providers
will soon face mandatory requirements for which many are unprepared.
Working across borders poses a unique challenge. The global footprint of tourism
means travel providers are subject to a huge array of governance and reporting rules,
sometimes spanning a dozen countries and destinations, each with wildly different
regulatory requirements. Even companies working in a single jurisdiction may find
themselves facing mixed compliance demands based on their subsidiaries and partners
in the supply chain. With limited time and resources, companies find themselves
consumed by a thick fog of conflicting legal, financial, and strategic advice.
Standardised reporting will transform how the sector works. In the meantime, businesses
need the best advice they can get. At the WTTC, we’ve collated expertise from leaders
in sustainability and corporate governance around the world to create a single source
of guidance for Travel & Tourism. This report, in partnership with Oliver Wyman, has a
single goal: to demystify the plethora of sustainability reporting requirements for the
Travel & Tourism sector. It covers three regulatory bodies: the European Commission, the
US Securities & Exchange Commission, and the International Sustainability Standards
Board.
New sustainability requirements are a once-in-a-generation shift in Travel & Tourism.

It is a change commensurate with both the scale of the climate problem, and the role
the private sector must play. We have all seen the crisis. Now, we need the action.
Companies must assess their obligations, urgently prepare, and demonstrate their
efforts not only to investors and policymakers but increasingly to customers too. At
risk are the priceless experiences and destinations our industry and customers hold
dear. Otherwise, history warns us, the next crisis will not be far off.
Julia Simpson Virginia Messina Scot Hornick Mike Matheis

President & CEO, SVP,Advocacy & Partner, Partner,
World Travel & Communications, Oliver Wyman Oliver Wyman
Tourism Council World Travel &
Tourism Council

EXECUTIVE SUMMARY
The climate crisis is urgent. Around the world, natural disasters are becoming more
extreme and species are being wiped out. In response, governments and financial
institutions are making changes to the way companies disclose information about
their sustainability practices. Tourism is no exception, and in the coming years travel
providers will face a growing number of environmental laws and regulations. Voluntary
frameworks have established a foundation for the industry to build upon and move
beyond, as regulatory bodies are shifting to mandatory data collection and disclosure.
Many of these efforts are a step in the right direction. But Travel & Tourism companies
face a distinct challenge: because our sector is defined by its ability to work across
borders, companies typically operate under many local and national jurisdictions at
once. They have broad supply chains that might include dozens of small operators,
and the sector has faced a consistent lack of guidance about the variations between
different laws and reporting requirements. This can make compliance tricky. To help,
this report analyses the three major sustainability disclosure frameworks that have
emerged:
• Europe’s Corporate Social Responsibility Directive (CSRD);
• The International Financial Reporting Standards (IFRS), affecting jurisdictions

including Australia, Brazil, Canada, Hong Kong, Nigeria, Singapore, and the UK;
• And the Securities and Exchange Commission (SEC) Climate-Related

Disclosures in the US.
For those unsure where to begin, this report also features a Sustainability Readiness
Roadmap. It includes a diagnostic tool to help companies to assess which sustainability
framework(s) apply to them, as well as their sustainability maturity level.
Change is never simple. Some companies are more prepared than others. Many have
limited resources – particularly smaller businesses – while leaders may be hesitant or
unsure how to navigate complex legislation.
But change also brings opportunity. Travellers, particularly the younger generation, want
greener products and services. Employees want to work for companies they believe in.
Investors are eager for transparency, and sustainability is increasingly part of the criteria
for choosing businesses to affiliate with. Those who take the lead will outperform in
the long run. And we hope that, by using this methodology, WTTC Members will be
able to better understand how and when they need to prepare, and become part of a
sector that is a model for others.

MOVING FROM VOLUNTARY

TO MANDATORY
There is increasing demand for sustainability information from different stakeholders, but little
consensus over what data best informs decision-making. Even so, companies are working to
meet this need. As of 2022, 98% of S&P 500 companies published sustainability reports, up from
86% in 2018.1
There are already several popular voluntary sustainability disclosure frameworks being followed
by companies around the world, including the Global Reporting Initiative Standards (GRI) —
the most widely used voluntary sustainability reporting guidelines — and the United Nations’
Principles of Responsible Investment (PRI). Perhaps most importantly, given its role as the
foundation for the three major standards evaluated in this report, the Task Force on Climate-
Related Financial Disclosures (TCFD) had been supported by over 5,000 companies before
transferring its monitoring responsibilities to IFRS in 2024.2
While 42% of Travel & Tourism companies analysed in 2021 by the WTTC had defined a climate
target, a much smaller number had adopted a voluntary sustainability reporting standard.3,4 This
gap highlights the significant task ahead for Travel & Tourism to comply with the detailed scope
of reporting that will be required for new mandatory disclosure. It is urgent that companies
across the sector gain a better understanding of these new requirements and begin to prepare
for them.
Stakeholder demands on sustainability  

As sustainable business practices gain traction around the world, companies must increasingly
consider the concerns of Travel & Tourism stakeholders. These concerns are wide-ranging,
including investors demanding transparency and comparability, travellers seeking eco-friendly
destinations, workers desiring employer action that aligns with their values, and communities
concerned about their future. This section explores the viewpoints of different Travel & Tourism
stakeholders on sustainability.
Investors  
According to a study by Harvard Law School, more than a quarter of global institutional investors
say sustainability is central to their investment approach, with client demand pivotal to that
perspective. Indeed, more than three-quarters (78%) of investors say that managing regulatory
risks is an important factor driving the inclusion of sustainability in their investing decisions,
second only to client demands (82%).5 Global investment in the energy transition continues to
rise, hitting a new record of $1.8 trillion in 2023, a 17% increase on the prior year.6
There are a wide range of ESG scores available to investors in the market today, each with their
own strengths and weaknesses. Applying a broad scorecard approach may not be effective, and
many ESG funds suffered a roughly three to four percentage point underperformance compared

with broad equity markets in 2022. Concurrently, Morgan Stanley Capital International (MSCI)
downgraded 95% of the AAA ESG ratings it had given ESG exchange-traded funds (EFTs) in 2023
after reassessing funds against new regulations.7
Investors are now using more bottom-up data to shed light on specific investment issues,
reducing the use of ESG ratings as a primary tool, according to a 2023 HSBC survey.8 Alternative
approaches include MSCI’s Climate Action Indexes, launched in late 2022, to invest in those
companies best prepared for the energy transition, and impact funds focused on tracking
real-world outcomes.
These trends are increasing the pressure on corporations to offer transparent and accurate data
on their climate impact and carbon footprint, even before international reporting and disclosure
requirements are finalised. It is important to remember that many financial institutions have set
their own net-zero commitments, requiring decarbonisation of the companies they invest in.
Consumers
Consumers are increasingly aware of the environmental impact of various products and
services and the sustainability practices of companies they purchase from. Sixty percent of
middle-and high-income households proactively seek out sustainable brands, and 85% are
willing to pay a premium for sustainable goods.
Generation Z consumers tend to have less disposable income, but still want to make a positive
impact on climate change through their purchasing decisions, according to a 2022 study by
Oliver Wyman Forum. A whopping 95% of Gen Z consumers say they are willing to pay more for
sustainable products, compared with about a third of the overall population, the same study
showed. One in five are ready to switch brands if a company’s values no longer mirror their own
— a willingness that outpaces attitudes in older generations.9
These trends certainly apply to Travel & Tourism-related purchases, which are on the rise.
According to a recent survey from Hilton, Gen Z and millennial travellers will spend more on
travel in 2024 compared to previous years, while 64% of global travellers say they will cut back
spending in other areas to prioritise travel in 2024. Within this group of frequent travellers, a
leading 40% will travel to learn about different cultures and/or destinations, with 24% planning
getaways for one-of-a-kind experiences such as concerts or sporting events.10
While the sector remains sensitive to consumer sustainability concerns at a high level,
two-thirds of travellers admit that the subject of environmental change can be overwhelming
as they consider vacation plans, with Gen Z and millennials more likely than older generations to
change their vacation travel habits due to climate change concerns. 11,12
Other stakeholders
Though investors and consumers typically have an outsized impact on corporate behaviour
compared to other stakeholder groups, activities unique to the Travel & Tourism sector have
far-reaching consequences. Travel & Tourism operations are often both global and hyperlocal,
impacting many distinct destinations, ecosystems, and communities around the world.
Companies must address the impact of their operations on nearby populations, recognising that
their success can be a force for good (providing jobs and economic prosperity) or a hinderance
(leading to overcrowding and the depletion of natural resources).
At both the local and corporate level, companies must ensure they provide a compelling
employee value proposition that both attracts and retains talent. With Gen Z in particular,
workers are increasingly looking for employers whose values reflect their own. According to an
Oliver Wyman Forum survey, Gen Zers – who will make up 31% of the workforce in 2031 (up from
15% in 2022) – are 80% more likely to be less engaged at work in day-to-day activities and 75%

more likely to consider other jobs that better align with their values if their employers are not
engaged in social issues.13
Finally, the breadth of the Travel & Tourism sector necessitates substantial cooperation with
value chain partners, many of whom are SMEs. Today, that includes addressing supply chain
challenges, such as material shortages, geopolitical conflicts, and extreme weather events.
This certainly extends to sustainability efforts, where partners may have different (potentially
misaligned) priorities, interests, and regulations. As reporting requirements increase at different
paces around the world, particularly in terms of Scope 3 emissions and supply chain due diligence,
real-time visibility and coordination will be critical for staying ahead of potential issues.
Falling short on voluntary rules  

Companies have struggled for years to make clear progress in complying with voluntary
sustainability standards, and now they must learn how to cope with mandatory ones. To date,
voluntary disclosures have provided a valuable foundation, though uptake has been insufficient
to fully promote consistent and comparable sustainability performance information, as well as
high standards in governing and controlling information.
These limitations can make it hard to distinguish between companies that genuinely embrace
sustainability and those that may be greenwashing their numbers — a risk that mandatory
regulations look to mitigate by enforcing a level playing field for companies and their data.
Voluntary disclosures, by their very nature as being voluntary, cannot alone provide the
comprehensive, consistent, and global comparability that stakeholders seek. That said, the
voluntary frameworks have provided an important, industry-informed foundation for global
standard setters to build upon. There is growing momentum towards global convergence on the
need for sustainability requirements, with more regulation shifting from voluntary to mandatory,
though significant uncertainty remains.
Many sustainability-related initiatives have either been proposed or adopted around the world,
involving a variety of approaches to the climate problem, including tactics such as carbon price
mechanisms. These initiatives will reduce differences in the interpretation of sustainability
reporting and data, while standardising the way companies disclose their sustainability
performance.
Upcoming mandatory regulations

There are ongoing efforts in the EU, internationally, and in the US to solidify mandatory disclosure
requirements that promote transparency and accountability to ensure companies are operating
on a level playing field. The EU and the International Sustainability Standards Board (ISSB) are
developing their standards with an eye towards highly interoperable non-financial reporting
standards, though uncertainty remains regarding the SEC framework and jurisdiction-specific
rules.  
As such, all draw heavily from the framework introduced by the TCFD, as well as the GRI and
other voluntary frameworks with widespread adoption. Each also requires disclosure of Scope 1
and 2 emissions, though Scope 3 reporting requirements will differ. The frameworks also differ
in terms of third-party assurances required.

European Union
In Europe, the Corporate Sustainability Reporting Directive (CSRD) was created in 2021 and
has been in force since January 2023. Companies currently subject to Non-Financial Reporting
Directive (NFRD) requirements (which the CSRD replaced) and some large issuers must start
reporting in 2025, based on 2024 data, with other companies to follow
The CSRD’s unique attributes include double materiality – reporting on both the impact of
sustainability issues on company financials (financial materiality) as well as the company’s own
impacts on the environment (impact materiality). It also requires information from both upstream
and downstream value chains and incorporates the concept of sustainability due diligence. In
addition, a forthcoming European Sustainability Reporting Standards (ESRS) publication will
outline sector-specific standards (including hospitality and transportation) and standards for
SMEs.14,15
International
Globally, the International Financial Reporting Standards Foundation (IFRS) launched the ISSB in
2021 at the UN climate summit, COP26. In 2023, the ISSB issued its first two IFRS Sustainability
Disclosure Standards, the General Requirements for Disclosure of Sustainability-Related Financial
Information (IFRS S1, core content requirements) and Climate-Related Disclosures (IFRS S2,
information about exposure to climate-related risks and opportunities). The ISSB framework
includes specific sector-based standards for hotels and lodging, airlines, cruise lines, and leisure
facilities, among other categories.16,17,18,19
Unlike the other two sets of standards, third-party assurance is not required (though it will
be determined on a jurisdiction-by-jurisdiction basis). It is also ultimately at the discretion of
national jurisdictions whether, and in what form, to mandate the use and assurance of the ISSB
Standards. The ISSB is working closely with individual jurisdictions to support their adoption
(Appendix 2).
United States
In 2022, the SEC proposed a new rule to standardise and expand climate-related disclosures.
The proposal applies to all SEC registrants, with limited requirements for smaller reporting
companies.20 Under the proposal, registrants will be required to provide disclosures about Scope
1 and Scope 2 emissions on both a disaggregated and aggregated basis. Unlike the EU and global
standards, there is considerable uncertainty as to whether the disclosure of Scope 3 emissions
will be required 21 This is also the only of the three frameworks that does not mandate the
disclosure of climate scenario analysis (unless already being used for other purposes).
The proposed SEC rules have yet to be finalised; they were expected to be effective in 2024,
but have been delayed. While the SEC continues to debate, California has signed into effect
the Climate Corporate Data Accountability Act and the Climate-Related Financial Risk Acts
(Senate Bills 253 and 261) in 2023. The regulation will require around 5,400 companies, both
public and private, to disclose their emissions, including Scope 3 emissions, starting in 2027.22

SUSTAINABILITY AS A
COMPETITIVE ADVANTAGE
Companies should look beyond sustainability compliance and seize the opportunities that the
increasing importance of sustainability presents. This is particularly relevant for the Travel & Tourism
sector, which is influenced by a uniquely broad and geographically diverse set of stakeholders,
including governments, customers, and investors among others. Impacts will be pervasive across the
sector, in terms of cross-border jurisdictional complexities, traveller expectations, and downstream
consequences of complicated value chains. Although the transition to mandatory sustainability
reporting can be challenging, the Travel & Tourism companies who succeed in sustainability will be
the ones who anticipate both challenges and opportunities and develop a proactive strategy that
plays to their strengths while mitigating their weaknesses. The following section will explore the
opportunities that sustainability presents at both the industry and company level.
Sustainability opportunities at the sector level

Protecting the sector’s ultimate product. Sustainability should be embedded within the strategic
priorities of Travel & Tourism. Indeed, the sustainability of destinations is key, as they are the sector’s
ultimate product. With the increase in extreme weather events due to climate change, as well as
growing concerns about overcrowding and depletion of natural resources, the sector is increasingly
focused on the sustainability of its operations and services. For instance, Iceland has imposed a
tourism tax to try to better manage the impacts of tourists in sensitive landscapes, while climate
change is melting the glaciers and ice caves.
Establishing evidence of industry commitment. Over the past decade, Travel & Tourism has
embraced sustainability as a strategic pillar. The WTTC report “Net Zero Roadmap for Travel &
Tourism” shows that 42% of leading Travel & Tourism companies have set a climate target – either
interim, long-term, or both.23 But mandatory sustainability requirements will require everyone in
the sector to make an effort to create harmonised global reporting that is more reliable, consistent,
structured, and comparable – as well as fully transparent to a wide range stakeholders. This is an
opportunity for companies with ambitious targets who are able to show progress over the coming
years.
Increasing collaboration. The prevalence of common value chain partners and relative lack of
subsector-specific guidance for Travel & Tourism companies presents opportunities for the sector
to collaborate, reducing regulatory costs. This is particularly important in a fragmented sector,
ensuring larger companies and SMEs alike can move forward as one on sustainability reporting and
its related challenges, particularly data collection.
For example, the hotel industry has joined forces to create a new methodology to guide how to set
a net zero pathway.24 The Net Zero Methodology for Hotels was authored in partnership between
Greenview, Tourism Declares a Climate Emergency, Pacific Asia Travel Association, Sustainable
Hospitality Alliance, and the WTTC and was developed through a collaborative process with
industry experts, including an Advisory Group of over 20 hotel companies, and wide stakeholder
consultation. Another example is Travalyst, a coalition that works collaboratively with travel brands
to unify sustainability reporting across the industry.25
Sustainability opportunities at the company level

Embedding sustainability in corporate strategy. Most industries will accelerate sustainability
actions over the next five years, prompted by new mandates and mounting evidence of the
disturbing impacts of climate change. Companies that take a leadership position in this field
will be best able to garner goodwill and improve brand resilience while avoiding bad publicity as
climate crises unfold.26 One example is Iberostar, whose Decarbonisation Pathway sets some of
the most ambitious targets in the industry, informing decision-making across its operations and
value chain, and even providing recommendations for peers embarking on a similar journey.27
Improving business resilience. Supply chain disruption during the pandemic raised concerns
about how prepared companies are to deal with global turbulence. Those concerns are equally
true of environmental disasters caused by climate change. Assessing companies’ exposure to
climate-related risks, modelling climate scenarios, and investing in environmental sustainability
are crucial approaches to ensuring the resilience of companies and an industry uniquely exposed
to international disruptions. Improved management of energy, water, and other resource
consumption, as well as emission and waste reduction, can also help to improve profitability by
reducing costs.
Attracting and retaining talent. As the industry struggles with labour shortages, appealing
workplace policies in terms of environmental protection, equity and diversity, health and
safety, and worker compensation and development are important to attract and retain skilled
employees. This is particularly true for younger personnel, such as Gen Zers, who prefer working
for companies with values and social commitments that align with their own. In particular,
Gen Zers are engaged on issues such as healthcare, criminal justice laws, diversity, gun rights,
and climate change – and are more likely than other generations to look for a new job if their
employer doesn’t align with their views, according to Oliver Wyman Forum’s Gen Z survey.28
Securing more and cheaper capital. Increased transparency through mandatory reporting
frameworks will help companies share trusted information with investors and rating agencies in
the same way they are able to share financial information. According to the Glasgow Financial
Alliance for Net Zero, companies with credible sustainability targets and transition plans will
have access to better financial terms and products, while those that do not may face higher
costs and potential constraints.29
Developing brand loyalty, a positive image, and new products and services. Mandated disclosure
provides companies that do care about the environment and corporate social responsibility with
verification and transparency of their commitment. This can help create a more loyal customer
base, mitigate potentially damaging media coverage, and improve investor relations.
It also has the potential to drive revenue, given that customers are increasingly mindful of the
sustainability of their purchasing decisions. Not only do they request more sustainable practices
from the companies they purchase from, they also increasingly look for sustainable trips, “green”
destinations, and eco-conscious tours. New consumer priorities can also help with controlling
overcrowding in destinations, with a third of travellers (33%) saying they choose to travel outside
of peak season and 27% opting for less popular destinations to avoid overcrowding.30

COMMON CHALLENGES
FACING TRAVEL & TOURISM
Mandatory sustainability reporting and disclosure will be a headache for most Travel & Tourism
companies. But for those that span multiple geographies and sectors and may be subject to
more than one framework, compliance will be even more complicated. Unfortunately, in Travel
& Tourism, that represents a lot of enterprises.
WTTC and Oliver Wyman interviewed WTTC Members across subsectors and geographies to
identify what they perceived to be the biggest challenges facing them, their value chains, and
the sector as a whole due to mandatory sustainability reporting. The findings are summarised
in this section.
Reporting
Discrepancies among regulations. WTTC Members noted the difficulty of gathering and
reporting sustainability information in different ways based on the multiple regulations and
standards from different jurisdictions. Despite the ambition to harmonise requirements,
there are key differences between the overarching frameworks (e.g., double materiality,
Scope 3 requirements) and there is still uncertainty around interoperability – particularly
regarding still-in-development SEC rules and jurisdiction-specific implementation of the
IFRS framework.
Lack of industry-specific guidance. Travel & Tourism combines various products and services,
as the industry is composed of different types of companies with complex and interconnected
value chains. Each subsector is different and requires appropriate guidance to interpret the
implications of the upcoming requirements. This is particularly true for Scope 3 reporting
requirements, which can be complex and significant. According to Oliver Wyman’s 3D Carbon
Accounting group, Scope 3 emissions can make up as much as 90% of a company’s output in
some sectors, is particularly complicated for those companies with suppliers outside of Europe.31
Recent regulations do not yet clearly address just how far down a supply chain a company must
go to collect relevant data.
Strategy and organisation

Balancing growth with sustainability concerns. While the uptick in travel demand post-pandemic
is generally seen as good for business, it also presents a challenge because of the significantly
higher greenhouse gas emissions that accompany it. Companies want to reduce emissions, but
higher demand is making it more difficult. This is particularly true for companies that have fixed
absolute emissions targets and will likely see overall emissions increase due to growth in travel.
Lack of resources. The Travel & Tourism industry was hit hard financially by the pandemic. As travel
rebounds, the industry is recovering, but still has limited resources to manage much more robust
demand and new pressures to collect sustainability data. As a result, many – perversely – have
to choose between meeting sustainability reporting requirements and actually implementing
sustainability initiatives.

Difficulty building organisational buy-in. Some WTTC Members face challenges when trying to
integrate sustainability into the company’s key decision-making processes. Sustainability teams
at times struggle to raise awareness across the company on the importance of sustainability
and the implications of upcoming regulations. The new reporting requirements necessitate a
coordinated approach across business units, as well as an organisation-wide shift in mindset.  
Shift in customer demand. WTTC Members find themselves playing catch-up to meet a shift
in customer demand for more sustainable products and services. As such, companies are
working hard to incorporate new sustainability elements into their offerings, such as providing
information on a trip’s carbon footprint and providing more sustainable destination travel.
Data
Inadequate data. Across the board, WTTC Members report significant problems with the broad
range and granularity of data needed to satisfy the new frameworks. For instance, the CSRD
demands a level of detail and specificity that goes beyond current reporting practices of even
some of the most advanced companies.
Lack of expertise. Members raised concerns that their companies may not possess the level of
internal expertise necessary — a level that might even be hard to hire. The new reporting will
require educating many departments across organisations on the intricacies of sustainability,
especially finance, which will need to begin including climate-related considerations in financial
statements.
Data collection inefficiencies. Members worried that many in the industry may not have
data collection platforms sophisticated enough to gather data efficiently. While some have
benefitted from automated data collection processes that improve data gathering efficiency
and traceability, many still use manual processes. Some Members will be faced with engaging
not only primary suppliers, but also secondary suppliers and beyond down the supply chain. This
presents a challenge in digitising information, due to the difficulty in overhauling manual data
systems further removed from purchasing decisions. There is an urgent need to upgrade current
processes and invest in more efficient data collection systems to ensure that companies can
meet imminent reporting requirements while providing high quality and reliable sustainability
data.  
Value Chain
Extensive and complex supply chains. Travel & Tourism companies rely on complicated supply
chains, making measurement of sustainability impacts — and in particular Scope 3 emissions —
more challenging. A tour operator, for example, may depend on 3rd parties for flights, ground
transport, booking engines, hotels, and local restaurants, among others.  
Difficulty engaging smaller suppliers. WTTC Members find it challenging to engage their entire
value chain, which is composed of many SMEs. Smaller suppliers prioritised their solvency during
the pandemic, and few have the resources to engage on issues surrounding sustainability and
sustainability reporting.34 Still, larger operators would often prefer to support diverse smaller
local companies rather than switch to larger suppliers, even if the latter might have better data
collection systems in place.  
Lack of industry alignment on supplier data requests. WTTC Members highlighted that diverse
interpretations of sustainability frameworks led to equally diverse and numerous requests for
data. Suppliers, particularly SMEs, might not have the resources to address so many data requests
and could suffer from reporting fatigue.  
Geographical differences. Some WTTC Members report varying levels of willingness to comply
among suppliers and value chain partners in different geographical regions. For example, Members
encountered more resistance to implementing new sustainability practices and activities in

North America than in Europe. WTTC Members also faced challenges around language barriers
when sharing new guidelines with certain suppliers, due to the lack of translated versions of
these requirements.
Sector-specific considerations
Subsectors within Travel & Tourism face very different sustainability challenges due to
differences in business models, as well as the products and services they provide, making it far
more complicated for some companies to collect data and make necessary changes than for
others. Here are some of the challenges:
Accommodation
Emissions for most providers of accommodation are concentrated under Scope 2 and Scope 3.
As a result, many providers have moved to standardised measurement systems like Energy Star
and LEED certification, as well as other initiatives such as the WTTC’s Hotel Sustainability Basics
and GRI disclosures to demonstrate their sustainability commitments.33,34 While most of the
larger hotel chains have committed to net-zero carbon goals by 2050, a commitment from the
full sector will be difficult to achieve given the fragmentation within this space.35,36
One complicating factor for hotel chains is the industry’s range of business models and ownership
structures. Many operate under franchise agreements with multiple levels of control, from brand
owners to property managers and owners. Implementing a data collection system across the
franchise and performing data assurance when dealing with multiple different stakeholders and
a more complex governance process can be arduous. This is also true when sharing guidelines
and sustainability principles with general managers and other value chain partners handling
the operations, who must go through proper training and ensure their property complies with
sustainability policies of the group. This adds to the complexity of defining and reporting Scope
3 emissions.  
In addition, accommodation providers often rely on local infrastructure and third-party services,
such as waste management services and facilities, laundries, and on-site renewable energy
sources. This requires additional coordination and may limit the company’s ability (and range of
options) to reduce their environmental impact.
Aviation
Air travel accounts for over 2% of global carbon emissions, and that number could grow as
international demand recovers following the pandemic.37 Indeed, the International Civil Aviation
Organisation (ICAO) reports emissions from international aviation could be four times higher in
2050 than they were in 2015.38
Because the industry is so global and the bulk of aviation’s emissions are Scope 1 — the easiest
emissions to quantify and control because they involve a company’s direct operations — airlines
are under more pressure to disclose their carbon footprints. As a result, there are multiple
ongoing initiatives pushing the sector to decarbonise, such as ICAO’s Carbon Offsetting and
Reductions Scheme for International Aviation, and airlines are likely more advanced within the
Travel & Tourism sector in terms of sustainability reporting.  
Meanwhile, airlines struggle with limited decarbonisation solutions that would help them reach
their environmental performance goals. Indeed, the primary short-term solution relies on
the switch to sustainable aviation fuel (SAF), with less carbon-intensive technologies such as
hydrogen-powered or electric aircraft not yet commercially viable. While more expensive than
conventional jet fuel, SAF eliminates between 50% to 80% of lifecycle emissions.

Cruises
The International Maritime Organisation aims to regulate the impact of cruise ships on the
environment by adopting a framework to reduce the carbon intensity of international shipping
by 40% by 2030.39 There are several ongoing initiatives to shrink the subsector’s carbon footprint,
including one led by the Cruise Lines International Association (CLIA). CLIA has committed to
net-zero carbon emissions by 2050 and focuses its efforts on alternative greener energy sources,
as well as partnerships with cities and ports for sustainable destination management.40Most
cruise lines do not report their Scope 3 emissions today because of the difficulties in
defining and reporting them. There is a lack of standardised guidance about which Scope 3
emissions cruise companies are responsible for, such as passenger transfers and fuel transport.
Like the airline industry, cruise lines also struggle with the lack of market-ready and scalable
low-carbon energy sources to power ships, such as renewable diesel, liquefied natural gas, green
hydrogen, or electric batteries. The sector will also have to face competing demand from other
sectors, such as road transportation and aviation, to source these more sustainable fuels.
Tour Operators
Emissions from tour operators vary across the sector. Asset-light tour operators (such as
technology platforms that act as intermediaries) have emissions concentrated primarily
under Scope 3, while asset-heavy tour operators (which own and operate a large portion
of the value chain) mostly report Scope 1 emissions. There are many sector-specific and
business model-specific nuances across Tour Operators, particularly in terms of how to
calculate emissions. Indeed, the upcoming standards do not provide guidance for tour
operators, meaning outcomes will not be comparable without industry collaboration.
Some tour operators also expressed concerns about limitations they encountered regarding
infrastructure at destinations. Indeed, some tour operators are actively investing in sustainability
initiatives, but the current infrastructure and technology in place at some destinations are not
developed enough for those investments to yield results in the short term. For example, some
tour operators want to invest in electric buses, but current EV coach battery life is inadequate
for longer tours, and there are limited, or often non-existent, charging points in less urban
destinations where they operate. While charging infrastructure could be constructed, the other
potential problem may be insufficient grid capacity to accommodate the additional demand
from EVs.
Travel Agencies (TAs) and Online Travel Agencies (OTAs)

Travel agents — both brick-and-mortar and online — play a central role in the industry, acting
as intermediaries between travellers and Travel & Tourism service providers. They interact with a
wide variety of industry players, from suppliers to destinations, and strongly influence consumer
choices. They are well-placed to help the Travel & Tourism industry achieve its sustainability goals,
though these efforts are complicated by the new reporting frameworks, as well as new rules such
as the Green Claims Directive in the EU, which regulates how companies can label their products
and services as sustainable.
Defining which activities and emissions fall under Scope 3 reporting responsibilities for agencies
is still unclear. Collecting Scope 3 emissions data is challenging for OTAs and TAs, because it
necessitates dealing with a large number of small local value chain partners, such as property rental
managers and local tour operators.
Furthermore, OTAs and travel tech companies more broadly are not easily classified, as they often
fall in the software sector rather than Travel & Tourism. As such, they also lack specific guidance on
how to tackle sustainability issues relating to their travel operations. They will likely have to consult
sector-based guides, such as for car rental and leasing, hotel and lodging, and airlines.    

SUSTAINABILITY
READINESS ROADMAP
Many Travel & Tourism companies are not fully ready for the coming sustainability compliance
standards, making it imperative that they move quickly. To help determine where to focus their
efforts, WTTC and Oliver Wyman have created the Sustainability Readiness Roadmap.
Companies can use the Roadmap to prepare for initial reporting requirements and understand
the direction upcoming sustainability reporting regulations will take in the coming years. For
some members, this may mean small adjustments to existing programmes and reports, while
others may need to implement transformative organisational change to collect and report
sustainability data. This is likely the first step in a long and complex journey for Travel & Tourism
to increase transparency and address sustainability demands.
In the first step of the Sustainability Readiness Roadmap, WTTC Members answer two key
questions:  
• What compliance standards will apply to your company and when?
• What is the current maturity of your sustainability platform and data?
The Roadmap proposes a diagnostic tool that allows companies to understand which
sustainability regulation(s) will apply to them and to assess their sustainability maturity level. It
is broken down into two assessments:  
The Sustainability Regulation Applicability Self-Assessment is a decision tree diagram

that can be used to understand which upcoming sustainability regulations will likely apply,
as well as the corresponding timeframe for compliance.  
The Sustainability Maturity Self-Assessment is a point-based system to determine

a company’s sustainability maturity level in four main areas: reporting, strategy and
organisation, data, and value chain.
By applying this Roadmap methodology, WTTC Members will be able to determine when
and how upcoming sustainability regulations will apply and where their company stands on
sustainability maturity across key themes. They will also be able to focus their attention on
addressing the themes where the biggest gaps exist and take urgent action to prepare.

Sustainability regulation applicability self-assessment

The decision tree diagrams in Figure 1 and Figure 2 help determine whether the CSRD and/or SEC
regulations will likely apply, as well as when compliance will be expected. The ISSB framework
is excluded from this assessment, as specific applicability and timing will vary based on how
each jurisdiction decides to implement, though the latest updates from countries adopting
climate-related disclosure standards are included in Appendix 2. Note that for portions of
these regulations that are not yet finalised, expected effective dates may change and continued
monitoring of regulatory developments is advised.
Figure 1. Standards applicability assessment: CSRD
Are you a non-EU parent company governed by the

law of a third country with a net turnover of ≥€150M in
Does your company have NO the EU at its group level, AND at least one subsidiary5,6 NO
operations in the EU AND is an
undertaking established in the EU which:
EU undertaking
• Is a public interest entity AND
• Is not a micro undertaking? Are you a non-EU parent company governed by the law of a third
YES country with a net turnover of ≥€150M in the EU at its group level,
Does your company AND at least one branch7 located in the EU which is either not part NO
have more than 750 NO YES of a group or held by an undertaking that is formed in accordance
employees with the law of a third country; and which:
Is your company an EU public • has a net turnover of ≥€40M at the branch level?
YES interest entity3 with more NO
than 500 employees? (i.e.,
already subject to NFRD YES
requirements}
Is your company a large EU
YES
undertaking OR an EU parent
undertaking of a large group,
that exceeds at least 2 of the 3 NO
following criteria (at group
level)?
• €40M net turnover4 Is your company an EU public
• €20M balance sheet total interest entity (i.e., listed)AND not a
• 250 employees micro undertaking, i.e., does it NO
exceed at least 2 of the 3 following
YES thresholds?
• €700k net turnover
• €350k balance sheet total
• 10 employees
YES
CSRD applies in FY 2024, CSRD applies in FY 2024, CSRD applies in FY 2025, CSRD applies in FY 2026, CSRD applies in FY 2028+, CSRD currently might
including Scope 31,2 Scope 3 in FY 20251,2 Scope 3 in FY 20261,2 Scope 3 in FY 20271,2 Scope 3 in FY 2029+1,2 not apply
1. “FY 2024” – report published in 2025 using FY 2024 data

2. Includes Scope 1 and 2 disclosures. Can omit to disclose the “financial effects from material physical and transition
risks and potential climate-related opportunities” prescribed by ESRS E1-9 for the first year of compliance. Can report
qualitative disclosures on that topic for the first three years if it is impracticable to prepare quantitative disclosures.
3. A public-interest entity is an undertaking which is either 1) governed by the law of an EU member state and whose
transferable securities are admitted to trading on a regulated market in the EU; 2) a credit institution; 3) an insurance
undertaking; 4) designated by EU member state as public-interest entities.
4. Net turnover means the amounts derived from the sale of products and the provision of services after deducting sales
rebates and value added tax and other taxes directly linked to turnover (Article 2(5) Directive 2013/24/EU).
5. A subsidiary is a separate legal entity from its third-country parent company, operating wholly in the local host country
market and subject to its laws.
6. Companies can choose to report at the subsidiary level or at the parent level. Directive 2013/34/EU exempt all subsidiary
undertakings from the obligation to report non-financial information where such undertakings and their subsidiary
undertakings are included in the consolidated management report of their parent undertaking, provided that report
includes non-financial information reported pursuant to that Directive and the subsidiary undertakings include in their
management report the name and registered office of the parent undertaking that is reporting sustainability information
at group level.
7. A branch is not a separate legal entity from its third-country parent company and is predominantly subject to the laws
governing the parent company.
Sources: European Parliament and European Council, Directive 2022/2464, December 12, 2022; European Parliament and
European Council, Directive 2013/34/EU, June 26, 2013
Note: Language is based directly on regulatory text and shortened for brevity where necessary   

1.1
SUSTAINABILITY REGULATION APPLICABILITY ASSESSMENT: SEC [UPDATED 03/13/24]
Fig.2 Sustainability regulation applicability assessment
No
Is your company an SEC registrant?
Yes
Is your company a No
Large Accelerated Filer (LAF) –
public float of over $700 million?
Is your company an Accelerated

Yes Filer (AF) but not a Smaller Reporting
Company (SRC) 1 or No
Emerging Growth Company (EGC) 2 –
public float between $250 million and
$700 million and greater than
$100 million revenue? Is your company an SRC 1, EGC 2, or
other Non-Accelerated Filer (NAF)?
Yes
Yes
FYB 2025: Initial disclosures3 FYB 2026: Initial disclosures3 and

electronic tagging6
FYB 2026: Remaining disclosures4, GHG FYB 2027: Initial disclosures3 and
emissions5, and electronic tagging6 FYB 2027: Remaining disclosures4 electronic tagging6 SEC climate-related disclosures
do not apply
FYB 2029: Limited assurance FYB 2028: GHG emissions5 FYB 2028: Remaining disclosures4
FYB 2033: Reasonable assurance FYB 2031: Limited assurance
1. Public float between $75 and 250 million and revenues greater than $100M, or public float between $75 and 700M and revenues less than $100M, or public float less than $75M.
2. Total annual gross revenues of less than $1.235 billion during its most recently completed fiscal year and, as of December 8, 2011, had not sold common equity securities under a registration statement; valid for the first five fiscal years after it completes an IPO, unless gross revenues exceed $1.235
billion, it issues over $1 billion in non-convertible debt in the past three years, or it becomes an LAF.
3. All Reg. S-K and S-X disclosures, other than noted below.
4.
5.
1. Public float between $75 and 250 million and revenues greater than $100M, or public float between $75 and 700M and
Item 1502(d)(2), Item 1502(e)(2), and Item 1504(c)(2).
Item 1505 (Scopes 1 and 2 GHG emissions).
6. Item 1508 – Inline XBRL tagging for subpart 1500; financial statement disclosures under Article 14 will be required to be tagged in accordance with existing rules pertaining to the tagging of financial statements; see Rule 405(b)(1)(i) of Regulation S-T.
revenues less than $100M, or public float less than $75M.
Sources: SEC, The Enhancement and Standardization of Climate-Related Disclosures: Final Rules, March 6, 2024; SEC, ‘Accelerated Filer and Large Accelerated Filer Definitions’, April 23, 2020; SEC, Smaller Reporting Companies and Emerging Growth Companies, February 21, 2024.
2. WymanTotal annual gross revenues of less than $1.235 billion during its most recently completed fiscal year and, as of December
© Oliver 1
8, 2011, had not sold common equity securities under a registration statement; valid for the first five fiscal years after it
completes an IPO, unless gross revenues exceed $1.235 billion, it issues over $1 billion in non-convertible debt in the past
three years, or it becomes an LAF.
3. All Reg. S-K and S-X disclosures, other than noted below.
4. Item 1502(d)(2), Item 1502(e)(2), and Item 1504(c)(2).
5. Item 1505 (Scopes 1 and 2 GHG emissions).
6. Item 1508 – Inline XBRL tagging for subpart 1500; financial statement disclosures under Article 14 will be required to
be tagged in accordance with existing rules pertaining to the tagging of financial statements; see Rule 405(b)(1)(i) of
Regulation S-T.
Sources: SEC, The Enhancement and Standardization of Climate-Related Disclosures: Final Rules, March 6, 2024; SEC,
‘Accelerated Filer and Large Accelerated Filer Definitions’, April 23, 2020; SEC, Smaller Reporting Companies and Emerging
Growth Companies, February 21, 2024.

Sustainability maturity self-assessment

Once WTTC Members have learned which regulations might apply and when, they should
assess their current sustainability maturity level across four main themes: reporting, strategy and
organisation, data, and value chain. Based on the total number of points accumulated using the
scoring rubric in Figure 3, companies can define their overall sustainability maturity level using
the following score ranges:
• 0 to 5 points: low maturity
• 6 to 11 points: medium maturity
• 12 to 17 points: high maturity
Companies should particularly focus on assessment outcomes by theme, which will help them
prioritise areas that are the most in need of improvement, with the urgency defined through the
applicability assessment. Though each company’s situation is unique and this assessment is not
a replacement for a more formal initiative to prepare for mandatory reporting requirements, it
should give companies a better understanding of their current situation and where they should
focus their resources.
See Fig.3 Sustainability Maturity Self-Assessment Scoring Rubric, on the next page

Figure 3. Sustainability Maturity Self-Assessment Scoring Rubric
Theme Question 0 point 0.5 point 1 point

How is your public reporting on Integrated within financial
Limited Separate from financial reporting
sustainability? reporting, where appropriate
Have you set sustainability targets
No Some Multiple with transition plans
(e.g., SBTi for emissions)?
Reporting Do you follow the TCFD
(max 4 A few to none More than half The majority or all of them
recommendations?
points) Have you started to compare the
Have not started preparing nor
information you are currently Have started preparing but
implementing based on newly Actively following new regulations
reporting against the information behind-schedule for new and
developed and upcoming and preparing reports accordingly
required in the new sustainability upcoming regulations
regulations
requirements (e.g., KPIs)?
Sustainability factors are always
Sustainability factors are
Sustainability factors are not considered as part of the
How is sustainability taken into sometimes considered as part of
considered as part of the com- company’s decision-making
consideration in your decision-making the company’s decision-making
pany’s decision-making process strategy where appropriate, with
process and strategy? strategy, but without a clear
and strategy a clear framework and materiality
decisioning framework
assessment
Collaboration between Sustainability roles and
Do you have sustainability governance Absence of a sustainability
sustainability and internal teams responsibilities are integrated
roles and responsibilities? team and/or responsibilities
on sustainability initiatives across the company
Limited leadership engagement
Strong leadership advocacy in
No leadership engagement in terms of resources and project
Is leadership engaged on sustainability terms of resources and project
on sustainability topics and prioritisation, with responsibility
topics? prioritisation, with sustainability
strategy of sustainability below C-suite
responsibility at the C-suite level
Strategy & level
organisation Board is informed regularly
(max 6 Board is infrequently informed
Is the Board informed on sustain- Sustainability is not a topic about sustainability issues, and
points) about sustainability issues, and
ability topics and monitors progress discussed at the Board level, have processes in place to assess
have limited processes, KPI’s
against sustainability metrics and with absence of sustainability and monitor progress against
and targets in place to monitor
targets? KPI’s and targets sustainability targets using specific
sustainability progress
KPI’s
Does the complexity of your com-
Yes, complexity of business No, complexity of business model
pany’s organisational structure / Partially; complexity of business
model often makes does not impact coordination
business model hinder your ability model sometimes impacts
coordination across company across the company; any potential
to implement your sustainability coordination across the company
challenging issues have been mitigated
strategy?
Have you conducted a materiality
Yes (considered and identified all
assessment on sustainability- Partially (just starting, incomplete
No potential material sustainability
related risks that might impact your assessment)
risks)
company?
Collect sustainability data on an Centrally collect and document
Do you collect sustainability data? No data collected
ad hoc basis sustainability data
Collect data on Scope 1, Scope 2,
Do you collect data on Scope 1, Collect data on Scope 1 and
No data collected and material Scope 3 following the
Scope 2, and 3 emissions? Scope 2 but not Scope 3
GHG Protocol
Data
(max 4 When emissions data is not available, Emissions estimated using lesser- Emissions estimated using
points) what is the quality of the data and No estimate known methodologies, unclear recognised methodologies, results
estimation methodology? explanation clearly explained
What is the level of your tracking

Lack of data tracking capabili- Partial data tracking capabilities Full data tracking capabilities across
capabilities to collect emissions data
ties across the value chain across the value chain the value chain
across your value chain?
Do you have visibility of your entire Comprehensive visibility (e.g., larger
Minimal visibility Partial visibility
value chain? spend categories)
Do you collaborate with suppliers on
No collaboration Occasional collaboration Regular collaboration
Value chain sustainability initiatives?
(max 3
points) Provide incentives to suppliers to
Do you select or encourage suppliers Do not select nor encourage Provide light encouragement adopt sustainability practices and
regarding their sustainability suppliers regarding their sus- to existing suppliers to adopt selectively choose new suppliers
practices? tainability practices sustainability practices based on their sustainability
practices

RECOMMENDATIONS
BY THEME
The following section provides recommendations based on each theme of the sustainability
maturity assessment. While every company’s situation is unique, WTTC Members who have
assessed their company’s sustainability maturity level across the four themes can look at the
relevant recommendations based on their results.
Reporting
Use voluntary sustainability frameworks to transition to the mandatory standards. All
three upcoming sustainability disclosure standards draw heavily on the disclosure framework
introduced by the TCFD, which are now fully incorporated into the ISSB’s Standards, as well as
the GRI and other voluntary frameworks with widespread adoption. As such, companies already
reporting according to those voluntary frameworks should seek available guidance and mapping
to transition from the voluntary to mandatory reporting standards. Meanwhile, those not yet
fully following voluntary reporting frameworks should implement as soon as they can.
Conduct an in-depth assessment of materiality, risks, and gaps. Evaluate upcoming sustainability
reporting requirements and prioritise areas that are deemed material, that carry the highest level
of risk, and that will require the most effort to achieve compared to current practice. Assess not
just requirements, but the capabilities necessary to meet them and show progress against them,
including scenario analysis, transition planning, and customer engagement. Explore developing a
global corporate reporting system to provide all stakeholders with a clear and accurate picture
of the entire organisation’s ability to create sustainable value over time.
Set sustainability targets, develop a transition plan, and report progress. Consider setting
targets for the main sustainability indicators you want to track, which should be in line with
your company’s sustainability commitments and the upcoming requirements. Develop a
transition plan with milestones that will ensure the company achieves those commitments, and
communicate it to across the organisation to encourage engagement.
Strategy and organisation

Promote leadership engagement on sustainability issues. Make sustainability a permanent
agenda item for leadership and Board meetings to ensure visibility of its impact on the business.
Integrate sustainability in business processes, including strategy development and resource
allocation. Senior leaders should also create a unified approach to sustainability analytics,
ensuring alignment across the company on key performance indicators (KPIs), which should be
monitored regularly.  A robust sustainability analytics platform and related governance enable
the internal transparency and accountability necessary to help organisations progress against
their transition plan and achieve their commitments.
Integrate sustainability in the company’s top-level strategy. For sustainability to have the
greatest impact, it should be part of the company’s main decision-making process, rather than
an afterthought. A broad range of considerations should be assessed, from sustainability-related
commercial opportunities to operational efficiencies that improve both profitability and
sustainability. Start by evaluating its materiality on the business and assessing which opportunities
and risks have the highest potential impact, ensuring that they are considered in the company’s
strategy. Based on the applicability and maturity assessments, prioritise the actions your
company should tackle first to meet the requirements that are most urgent. Also consider other
aspects of sustainability, such as human rights and biodiversity, which will continue to grow in
importance in the future.
Ensure sustainability governance, including roles and responsibilities, is in place across the
organisation. Build governance structures that provide oversight, incentivise, and support the
implementation of the organisation’s transition plan. Identifying senior employees for oversight
roles and linking outcomes to performance is key to ensuring accountability and driving progress
towards commitments. If not in place, assess which areas of responsibility should be prioritised
based on the maturity assessment, such as legal, reporting, and data analysis. Gather the relevant
expertise, potentially through training or recruiting. If a sustainability team exists today, push
for more cross-functional engagement and integration of sustainability responsibilities across
business functions. Whether you choose to have one central team or multiple smaller teams
within each function dedicated to sustainability, ensure that sustainability initiatives are
coordinated, and that the overall strategy is consistent. Best practice is to consider sustainability
an organisation-wide effort, though a central team is critical to drive efforts forward and ensure
proper coordination.
Apply scenario analysis to understand strategic risks. Even beyond regulatory compliance,
companies are encouraged to apply scenario analysis to assess the robustness of their strategic
plans under a range of potential future state risk scenarios. For companies at the start of their
sustainability journey, this may be a qualitative approach at first, with the ambition to become
more rigorous and quantitative over time. Depending on needs, resources, and capabilities,
companies can look to existing external scenarios and modelling solutions or develop
in-house modeling capabilities. Scenario analysis can provide the foundation for more effective
engagement with stakeholders on a company’s strategic resiliency and is key towards driving
real-world sustainability outcomes.
Data
Understand your current data collection capabilities. Start by mapping your sustainability data
sources. To do so, you must understand what data is currently tracked by your company and
what data gaps exist in terms of Understand your current data collection capabilities. Start by
mapping your sustainability data sources. To do so, you must understand what data is currently
tracked by your company and what data gaps exist in terms of your sustainability.
Determine your data needs and prioritise. To understand your company’s sustainability data needs,
you should identify the sustainability risks with the highest potential impact on your company
based on a materiality assessment. Based on those identified risks, you should choose relevant KPIs
and metrics that your company should track to assess and monitor these risks. By focusing on the
most relevant data, you can address your most material risks while setting up your sustainability
data collection structure, which you can expand later to address further data requirements.
Establish data ownership and governance. Determine who is responsible for data collection in
your company and value chain. This responsibility could initially fall to your sustainability team,
who should have a good understanding of sustainability and a clear view of where to obtain each
data point, although data collection will likely require extensive cross-functional coordination.
Develop a sustainability data collection strategy. Once you know what data you should collect,
where you can obtain it, and from whom, you should define how to get it. Determine the format
for collecting your data through means such as databases, spreadsheets, PDFs, and IT systems.
Establish clear processes and controls for collecting and storing the data, such as data quality
checks and audit processes.
Align on data requests from suppliers. Having a common methodology at the sector level is
crucial for collecting comparable and reliable data. Travel & Tourism companies within each
sector should align on a set of metrics and KPIs they need for their sustainability reporting
and convey these harmonised data requests to their value chain partners. This would facilitate
data collection for suppliers, which are often shared by multiple different Travel & Tourism
companies and may not have the proper resources nor capabilities to face completely different
data requests.  
Value chain
Assess your value chain. To collect the relevant data and meet your sustainability targets,
your company should have good visibility across your entire value chain. As many Travel &
Tourism companies have complex value chains, you should consider doing a supplier materiality
assessment, which will help your company prioritise suppliers with the highest material impact
and understand what data you should collect and from whom.
Engage your value chain partners. It is crucial to communicate your sustainability strategy
and data needs to your value chain partners, presenting it as an effort that will benefit both
companies, as it is an opportunity to gain a competitive advantage and is in their best interest
for shared long-term growth and stability. Determine the main point of contact responsible
for data collection at each of your value chain partners, and clearly explain the purpose
and importance of your sustainability strategy, the required timelines, and any necessary
confidentiality assurance. Collaboratively develop training to help upskill their organisation,
as well as sustainability scorecards to assess performance on a regular basis – holding them
accountable to commitments, highlighting successes, and identifying further opportunities to
improve.
Provide support and incentives to improve partner sustainability. Value chain partners,
particularly SMEs, might not have sufficient resources or understanding to meet supplier
sustainability targets. As such, ensure that you share resources and support to better their
chances of success, particularly around sustainability data collection and reporting. Look
for knowledge-sharing opportunities, financial incentives, and other resources to support
these partners in their sustainability journey and encourage them to improve in the key areas
that matter to your company. One strategy to encourage collaboration with suppliers on
sustainability is dynamic discounting and supply chain finance, which offers a reduced rate for
capital, incentivising suppliers to adopt sustainability practices.41 This is also an opportunity
to collaborate with peers who have similar value chains – reducing the burden on common
partners by aligning requests, standardizing data collection templates, and sharing best
practices.
Looking Ahead
his report highlights the urgent need for the Travel & Tourism industry to prepare for the
impending mandatory sustainability requirements and the divergence in levels of sustainability
maturity within the sector. Through this report, WTTC Members will come to understand which
upcoming regulations might apply to them, the timeframe of applicability, and their company’s
overall sustainability maturity level. They will also have an idea of some recommendations they
can implement immediately to begin preparing for the transition to mandatory reporting. level.
They will also have an idea of some recommendations they can implement immediately to
begin preparing for the transition to mandatory reporting

Call To Action
In parallel, the industry has expressed a desire for greater support from national and local
governments, as well as regulators, to encourage and facilitate a more seamless transition to
mandatory sustainability reporting. This includes, among others, undertaking measures to:
• Provide robust guidance and prioritize interoperability. Countries should consider

the adoption of roadmaps and pathways toward mandatory application of global
sustainability frameworks (such as ISSB, especially in non-European countries). This will
allow global consistency across all regions and will ensure a high level of interoperability
with other voluntary and mandatory frameworks.
• Phase-in requirements to help companies adapt to the new landscape.
• Provide industry-specific guidance to comply with the new requirements, including the
subsectors of the T&T industry, especially related to climate-related disclosures and
Scope 3.
• Provide resources for companies to understand and manage the transition to

mandatory standards, including both financial support and training (particularly for
SMEs) for both sustainability initiatives and reporting.
The actions recommended in this report are just the first steps in a long and complex journey
to increase the transparency of sustainability performance and to support companies making
progress towards global sustainability goals. The regulatory environment will continue to evolve
over the coming years, but here are some common expectations to keep in mind as you build
out your sustainability reporting strategies:
1. The time for compliance is here. For some requirements, large companies are expected to
collect data this year and file next year. This includes Scope 3 emissions, which will impact
their value chain partners around the world. There is an urgent need to prepare for these
requirements, and companies who don’t have the internal capabilities today must begin to
build them now.
2. More companies will need to disclose their Scope 3 emissions. The CSRD and ISSB proposals
directly call for disclosure of Scope 3 emissions, while the SEC proposes disclosure “where
considered material” or when the company has already issued a Scope 3 reduction target.
Companies should begin to evaluate their Scope 3 emissions to determine whether they are
material and, if so, prepare to report them.
3. Third-party assurance will become more common. Companies should prepare for limited
assurance requirements soon, with a longer-term transition to reasonable assurance likely
under both the SEC and CSRD disclosure regimes. Although the ISSB proposal provides
guidance on reporting standards, deciding whether disclosures are subject to assurance will
be left to adopting jurisdictions and regulatory agencies.  
4. Compliance across jurisdictions. It is still not fully clear to what extent certain jurisdictions
will recognise disclosures made pursuant to other jurisdictions’ rules. There is an effort
underway to align ESRS with the ISSB standards, leading to a high degree of alignment
between the two, though some key differences remain, such as double materiality, and it
is up to the individual jurisdictions implementing ISSB standards to ultimately determine

whether that interoperability is fully maintained. Meanwhile, the SEC proposal does not
yet include a provision for alternative or substituted compliance with another jurisdiction’s
reporting requirements.
5. Potential future expansion. The ISSB’s proposal focuses primarily on climate and other
environmental disclosure items, though its scope is likely to expand with future standards,
which are expected to eventually cover the entire ESG landscape. The CSRD is designed as
an all-encompassing sustainability disclosure rule, with standards related to biodiversity and
resource use, as well as social and governance topics. While the SEC’s disclosure proposal is
limited to climate data, the SEC’s regulatory agenda hints at potential future topics such as
board diversity and human capital. As such, companies should monitor the development in
the mandatory reporting standards and be prepared to face a future increase in scope.
WTTC Members should use this guidance as a starting point and seek additional help if required.
As the trusted voice in Travel & Tourism, the WTTC will support the industry as a platform
for companies to collaborate and share best practices and insights to meet the upcoming
sustainability requirements. By completing the Sustainability Readiness Roadmap, companies
can ensure that they’re heading in the right direction — a critical first step of a challenging
journey ahead.
A CRITICAL
STEP OF A
CHALLENGING
JOURNEY

ACKNOWLEDGEMENTS
AUTHORS
Christopher Imbsen
Director of Sustainability
World Travel & Tourism Council
Elena Ruiz
Sustainability Expert
World Travel & Tourism Council
The Voice of Travel & Tourism.
Dan Darcy
WTTC promotes sustainable growth for the Travel
Principal | Transportation & Services,
& Tourism sector, working with governments and
Climate & Sustainability
international institutions. Council Members are
Oliver Wyman
the Chairs, Presidents and Chief Executives of the
Nolwenn Cousineau world’s leading private sector Travel & Tourism
Senior Consultant businesses.
Oliver Wyman
For more information, visit: www.WTTC.org

DESIGN
Zoe Robinson
PHOTOS Oliver Wyman is a global leader in management

consulting. With offices in more than 70 cities
Cover: Shutterstock, S.R.Lee Photo Traveller|| across 30 countries, Oliver Wyman combines deep
Page 2: Shutterstock, Galyna Andrushko|| industry knowledge with specialized expertise
Page 3: Unsplash, Simon Ray|| Page 4: Unsplash, in strategy, operations, risk management, and
David Bruyndock|| Page 5 Unsplash, Loli Mass|| organization transformation. The firm has 7,000
Page 9: Unsplash, Kazuo Ota|| Page 11: Unsplash, professionals around the world who work with
Artem Zhukov|| Page 15 Unsplash, Patricia Jekki|| clients to optimize their business, improve their
Page 18: Unsplash, Danist Soh Page|| 20: Unsplash, operations and risk profile, and accelerate their
James Wheeleri || Page 24: Shutterstock, organizational performance to seize the most
Elena Larina attractive opportunities. Oliver Wyman is a
business of Marsh McLennan [NYSE: MMC].
For more information, visit www.oliverwyman.
com. Follow Oliver Wyman on LinkedIn and X.
SPECIAL THANKS
This report would not have been possible without the following individuals and organisations, among
others, who have provided valuable input and support throughout its development through interviews
and expert insight:
Aditi Mohapatra and Tomas Monti (Expedia Group); Jean Garris and James Alder (Hilton); Megan
Morikawa (Iberostar); Sara King (Intrepid); Charlotte Wweibe (TUI Group); Linden Coppell (MSC Cruises);
Shannon Guihan (The Travel Corporation), Lucas Bobes (Amadeus), Denise Naguib (Marriot), Sven
Wiltink (Radisson); Rochelle Turner and Jim Sutcliffe (Travelopia), Amy Stuart, Hannah Kopec and Jen
Zhao (Certares), David Carlin (United Nations Environment Programme Finance Initiative), John Colas,
Ilya Khaykin, Geoff Ng, and Julia Yang (Oliver Wyman)

ABBREVIATIONS
CDSB Climate Disclosure Standards Board

CLIA Cruise Lines International Association
CSRD Corporate Sustainability Reporting Directive
EFRAG The European Financial Reporting Advisory Group
EFT Exchange-traded funds
ESG Environmental, Social and Governance
ESRS European Sustainability Reporting Standards
GHG Greenhouse Gas Emissions
GRI Global Reporting Initiative
ICAO International Civil Aviation Organisation
IFRS International Financial Reporting Standard
ISSB International Sustainability Standards Board - IFRS Foundation
KPI Key Performance Indicator
MSCI Morgan Stanley Capital International
NFRD Non-Financial Reporting Directive
OTA Online Travel Agency
PATA Pacific Asia Travel Association
PRI Principles of Responsible Investment
SAF Sustainable aviation fuel
SASB Sustainability Accounting Standards Board
SBTi Science-Based Targets Initiative
SME Small and midsize enterprise
TA Travel Agency
SEC Securities and Exchange Commission
TCFD Task Force on Climate-Related Financial Disclosures
WTTC World Travel and Tourism Council

APPENDIX 1: Company archetypes and illustrative

recommendations
1. Company A: large multinational group, US-based with EU subsidiary
a. Description: Company A is a North American cruise group with global operations

and a few subsidiaries, one of which is based in the EU. The group is listed in
the US with a total market capitalisation of $20B, and a net turnover in the EU
of €300M. The EU-based subsidiary is deemed to be a large company by EU
standards. The group has a sustainability team which handles ESG-related topics.
However, the team mostly focuses on the E (or environment) aspect of ESG. ESG
roles and responsibilities are unevenly distributed across the organisation, and
sustainability is not taken into account by other functions within the organisation.
There is also a lack of resources dedicated to ESG challenges as well as leadership
engagement.
b. Applicability: Due its size and market capitalisation, Company A will be expected
to comply with SEC regulations starting in FY 2023 and disclose Scope 3 emissions
disclosure for FY 2024. In the eventuality that the SEC decides to modify or even
remove the Scope 3 disclosure requirement, Company A’s EU-based subsidiary
will still have to comply with the CSRD as early as FY 2027, and as such will have
to report its Scope 3 emissions.
c. Recommendations: Company A should aim to understand the particularities of

both the CSRD and SEC upcoming regulations and increase sustainability visibility
and importance within the organisation.
i. Company A should aim to meet the SEC’s requirements first due to the
applicability timeframe, while also ensuring that this is done in a strategic
way. This ensures it does not undermine its future efforts to meet the
CSRD requirements for its subsidiary’s operations.
ii. If not done already, Company A should map out its value chain and start
collecting data to estimate the required sustainability indicators such as
its Scope 3 emissions.
iii. Company A should encourage company-wide understanding and

collaboration on sustainability issues and their impact on the business.
Engaging leadership on this topic could provide incentives to invest in
more resources to tackle sustainability challenges and ensure that there
are proper sustainability roles and responsibilities in place to face the
repercussions of the upcoming regulations.
iv. Company A should also seek to understand the implications of the S and
G aspects of ESG, which are partially encompassed in the CSRD.

2. Company B: micro-company, supplying EU-based clients
a. Description: Company B is a micro-company with small-scale local operations in

the EU. The company provides external laundry services to a few hotels, one of
which is part of a large corporation with more than 500 employees and based
in the EU. Company C does not have a sustainability strategy, nor does it have a
sustainability team, and does not gather sustainability data such as the emissions
linked to its activities.  
b. Applicability: Due to its micro-company characteristics, the CSRD might not

apply to Company B. However, Company B’s clients, particularly the large hotel
chain, might require Company B to gather and share data on the emissions
generated by its activities. Company B’s emissions would fall under the hotel
chain’s Scope 3 emissions, which the company will have to report in FY 2024
according to the CSRD.
c. Recommendations: Company B should pre-emptively try to understand the

upcoming regulations and anticipate the demands from its clients, such as
sustainability data requests.
i. In the eventuality that Company B cannot provide the required data or

work on reducing its emissions, its clients could terminate their business
contract and seek other suppliers that have the adequate capabilities
and have sustainability embedded within their organisation’s strategy.
Company B should therefore start tracking relevant sustainability data
and indicators.
ii. Company B should coordinate with its clients and leverage existing
resources such as data management systems or data collection
processes. Investing in a centralised data management platform could
save both Company B, and its clients, time, and effort, while enabling
better traceability and transparency of data. Company B should aim to
understand its clients’ sustainability policies and practices, ensuring they
are aligned with Company B’s own policies. Company B should also inquire
about the resources and incentives at its disposal in case the company
needs support from its clients to meet its sustainability goals.
iii. Company B should continue monitoring sustainability regulations

developments and start to prepare accordingly. Indeed, regulations’
applicability criteria might evolve, and those criteria might apply to
Company B in the future as the company grows.

APPENDIX 2. Regional adoption of climate-related disclosure

standards
Regional adoption of climate-related disclosure standards (effective or under development)
Latest update: January 2024
Regional adoption of climate-related disclosure standards (effective or under development)
Country ISSB status

The CNV aims to incorporate minimum criteria for ESG disclosures, using IFRS S1 and IFRS S2
Argentina as the basis. The Ministry of Economy is considering the creation of a taxonomy to create
transparency and certainty around sustainable finance.
Following the release of the ISSB standards, the Australian ASB will develop Australian
Australia climate disclosure standards, in line with the ISSB’s IFRS S2 Climate-related Disclosures
standard, with modifications as necessary.
The Brazilian Ministry of Finance and the Comissão de Valores Mobiliários announced that
Brazil the ISSB’s IFRS SDS will be incorporated into the Brazilian regulatory framework, setting out a
roadmap to move from voluntary use starting in 2024 to mandatory use on 1 January 2026.
The Canadian Sustainability Standards Board (CSSB) was created to support the uptake of
Canada
ISSB standards in Canada and facilitate cooperation with the ISSB.
Authorities appear to support the ISSB, providing feedback on the draft. The MoF has
regular engagement with the ISSB via the Jurisdictional Working Group and is on the
China Sustainability Standards Advisory Forum. The IFRS Foundation opened the ISSB’s Beijing
office in June 2023 which serves as a hub for stakeholder engagement and capacity building
in Asia, along with Tokyo office.
The Colombian Environmental Superintendence requires issuers to disclose information
Colombia consistent with the TCFD recommendations for climate change and the SASB Standards for
other sustainability issues
In 2021, the FRA issued resolutions mandating companies listed on the Egyptian Stock
Egypt Exchange and companies operating in non-bank financial activities to submit TCFD-aligned
reporting.

The SCF and HKMA are considering mandatory TCFD and ISSB-aligned reporting which
Hong Kong
would be effective in FY2025 for companies on the HKEX
The SSBJ plan to issue final disclosure standards by end of Q1 2025 and plan to incorporate
Japan
ISSB Standards into these requirements. A first draft is expected by March 2024.
The Securities Commission Malaysia has set up the Advisory Committee on Sustainability
Malaysia
Reporting (ACSR) in May 2023 to support the implementation of the ISSB standards.
The XRB published the Aotearoa New Zealand Climate Standards in December 2022, which
New Zealand are closely aligned with the TCFD framework and ISSB exposure drafts and is considering
implementing the latest update to the standards.
The FRC and NGX Reg Co co-launched the final ISSB Standards in June 2023 and showcase
Nigeria
Nigeria’s commitment to adopt the standards.
ACRA and the SGX RegCo proposed recommendations requiring listed issuers to report
Singapore ISSB-aligned CRDs from FY 2025. Large non-listed companies with annual revenue of
+USD1BN revenue will follow suit in FY27.
The JSE published the Sustainability Disclosure Guidance and The Climate Change Disclosure
Guidance, for use on a voluntary basis intended primarily to assist JSE-listed companies.
South Africa The South African Institute of Chartered Accountants, in collaboration with the
Johannesburg Stock Exchange, hosted the South African leg of the global launch of the ISSB’s
(International Sustainability Standards Board) first two Sustainability Disclosure Standards in
June 2023.
Switzerland’s Financial Market Supervisory Authority amended disclosure rules for banks and
Switzerland
insurers to include climate-related financial risks, based on TCFD
In June 2023, the Public Oversight, Accounting and Auditing Standards Authority of
Turkey (KGK) decided to adopt the ISSB Standards. The KGK is currently in the process of
Turkey developing the Turkish Sustainability Reporting Standards (TSRS), which are planned to
be published by the end of 2023. The TSRS will be applied for annual reporting periods
beginning on or after 1 January 2024.
The Sustainable Finance Working Group has been studying potential implementation of a
set of ESG regulations since 2021. In a 2022 update the Workstream One on Sustainability
Disclosure mentioned it intends to consider the option of aligning with these standards in
UAE
due course, once the final standards are adopted by the ISSB and endorsed by international
standards-setters. However, the Abu Dhabi Global Market introduced ESG disclosure
requirements in July 2023, which did not mention ISSB.
The UK is developing Sustainability Disclosure Requirements (SDR) based on the ISSB
United Standards. It will require full TCFD-aligned reporting, including net zero transition plans as
Kingdom well as additional sustainability disclosure. Endorsement decisions on the first two standards
are due by July 2024 and will apply to all UK listed companies.
Latest update: January 2024

REFERENCES
1. 2022 Sustainability Reporting In Focus (ga-institute.com)
2. TCFD home page
3. Environmental, Social, & Governance Reporting in Travel & Tourism: Reporting Guidance For Travel & Tourism
Businesses. WTTC, 2017
4. A Net Zero Roadmap for Travel & Tourism. WTTC, 2021
5. ESG Global Study 2022. Harvard Law School Forum on Corporate Governance, 2022
6. Energy Transition Investment Trends 2024, BloombergNEF, 2023
7. The next phase of climate-aware investing. Oliver Wyman, 2023
8. Rising ‘anti-ESG’ sentiment in US is impacting funds, HSBC says. Bloomberg, 2023
9. How to help Gen Z turn climate anxiety into action. Oliver Wyman Forum, 2022
10. 2024 Trends Report. Hilton, 2023
11. 2024 Trends Report. Hilton, 2023
12. Climate Journal Vol. 2, p.50. Oliver Wyman, 2022
13. [16]
A-Gen-Z Report, Oliver Wyman, 2023
14. Update on Set 2 content and planning of sector standards, EFRAG
15. [Draft] ESRS SEC 1 Sector Classification. EFRAG, 2023
16. IFRS, “IFRS S2 Climate-related Disclosures, Appendix B Industry-based disclosure requirements – Volume B52 –
Hotels & Lodging”, March 20224
Airlines”, March 2022
Cruise Lines”, March 2022
19. IFRS, “IFRS S2 Climate-related Disclosures, Appendix B Industry-based disclosure requirements – Volume B53
–Leisure Facilities”, March 2022
20. US SEC, 2022. Fact Sheet: Enhancement and Standardization of Climate-Related Disclosures. Online posting.
US Securities and Exchange Commission. Accessed 2 June 2022
21. New climate reporting requirements to take effect in California. Dentons, 2023.
22. Hotel Sustainability Basics, WTTC
23. A net zero roadmap for travel & tourism. WTTC, 2021
24. Net Zero Methodology for Hotels. First Edition v1.0
25. Travalyst - Sustainable Tourism
26. Why marketing matters when it comes to climate. Lippincott, 2023
27. Iberostar’s Decarbonization Roadmap - Wave of Change
28. A-Gen-Z Report, Oliver Wyman, 2023
29. Transition planning | Glasgow Financial Alliance for Net Zero (gfanzero.com)
30. Sustainable Travel Report. Booking.com, 2022
31. What you need to know about carbon accounting in Europe. Oliver Wyman, 2023.
32. SMEs’ Sustainable Development Challenges Post-COVID-19: The Tourism Sector. World Journal of Entrepre-
neurship Management and Sustainable Development, June 2021.
33. The Hotel Sustainability Basics, WTTC
34. A Check-in on the Hotel Sector’s ESG Initiatives. CBRE, 2022
35. Hotels with Net-Zero Ambitions. New York Times, 2022.
36. Net-zero hotels realistic, but industry ‘too fragmented’ for global pledge: Sustainable tourism council chief.
Eco-Business, 2023.
37. Tracking Aviation, International Energy Agency, July 2023
38. Environmental Trends in Aviation to 2050, ICAO, 2019
39. 2023 IMO Strategy on Reduction of GHG Emissions from Ships
40. Environmental commitment, Innovation, and Results of the Cruise Industry. CLIA, 2021
41. Incorporating ESG into Supply Chain Finance. J.P. Morgan, 2021

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NAVIGATING THE SUSTAINABILITY JOURNEY: THE IMPACT OF MANDATORY REPORTING ON TRAVEL & TOURISM

World Travel & Tourism Council 2

New sustainability requirements are a once-in-a-generation shift in Travel & Tourism.

Julia Simpson Virginia Messina​​​​ Scot Hornick Mike Matheis

World Travel & Tourism Council 3

• Europe’s Corporate Social Responsibility Directive (CSRD);

• The International Financial Reporting Standards (IFRS), affecting jurisdictions

• And the Securities and Exchange Commission (SEC) Climate-Related

World Travel & Tourism Council 4

MOVING FROM VOLUNTARY

Stakeholder demands on sustainability

World Travel & Tourism Council 5

World Travel & Tourism Council 6

Falling short on voluntary rules

Upcoming mandatory regulations

World Travel & Tourism Council 7

World Travel & Tourism Council 8

Sustainability opportunities at the sector level

Sustainability opportunities at the company level

World Travel & Tourism Council 10

Strategy and organisation

World Travel & Tourism Council 11

encountered more resistance to implementing new sustainability practices and activities in

World Travel & Tourism Council 13

Travel Agencies (TAs) and Online Travel Agencies (OTAs)

World Travel & Tourism Council 14

• What compliance standards will apply to your company and when?

• What is the current maturity of your sustainability platform and data?

The Sustainability Regulation Applicability Self-Assessment is a decision tree diagram

The Sustainability Maturity Self-Assessment is a point-based system to determine

World Travel & Tourism Council 15

Sustainability regulation applicability self-assessment

Figure 1. Standards applicability assessment: CSRD

Are you a non-EU parent company governed by the

1. “FY 2024” – report published in 2025 using FY 2024 data

World Travel & Tourism Council 16

Is your company an Accelerated

FYB 2025: Initial disclosures3 FYB 2026: Initial disclosures3 and

World Travel & Tourism Council 17

Sustainability maturity self-assessment

• 0 to 5 points: low maturity

• 6 to 11 points: medium maturity

• 12 to 17 points: high maturity

World Travel & Tourism Council 18

Figure 3. Sustainability Maturity Self-Assessment Scoring Rubric

Theme Question 0 point 0.5 point 1 point

What is the level of your tracking

World Travel & Tourism Council 19

Strategy and organisation

World Travel & Tourism Council 22

• Provide robust guidance and prioritize interoperability. Countries should consider

• Phase-in requirements to help companies adapt to the new landscape.

• Provide resources for companies to understand and manage the transition to

World Travel & Tourism Council 23

World Travel & Tourism Council 24

For more information, visit: www.WTTC.org

PHOTOS Oliver Wyman is a global leader in management

World Travel & Tourism Council 25

Julia Simpson Virginia Messina Scot Hornick Mike Matheis

Stakeholder demands on sustainability  

Falling short on voluntary rules  