A pension fund deciding where to invest for the next twenty years wants to know how a company’s emissions profile will affect its value over that period. In most cases nobody can give it a reliable answer. Dame Alison Rose, who led NatWest Group from November 2019 to July 2023 and now serves as a senior partner at Charterhouse, has spent much of her recent career pointing at this specific gap: capital wants to move toward sustainable outcomes, but the data needed to direct it accurately barely exists in usable form.
The Allocation Problem in Plain Terms
Capital allocation depends on comparability. An investor choosing between two companies needs figures that mean the same thing in both cases, calculated the same way, verified to a similar standard. Financial statements have spent a century developing that kind of comparability through accounting standards and audit requirements. Sustainability data has had roughly a decade, and it shows. Two companies in the same industry can report emissions figures that differ by a wide margin not because their actual environmental impact differs but because they used different measurement boundaries and nobody caught the inconsistency.
Why This Is Not a Minor Technical Issue
When the underlying data is unreliable, capital does not stop moving. It moves anyway, based on whatever data exists, which means it sometimes moves in the wrong direction with total confidence. A fund can build an entire sustainable portfolio around numbers that turn out to be aspirational disclosures rather than measured outcomes. Rose has argued that this is not a rounding error in an otherwise functional system. It is a structural flaw that undermines the premise of sustainable investing itself, since the whole exercise depends on the data being roughly accurate.
Where GRESB Fits
Real assets, buildings, infrastructure, land, present a particularly hard version of this problem because their environmental performance is physical and site-specific rather than aggregated at the corporate level the way a manufacturer’s emissions might be. Benchmarking frameworks built specifically for real assets exist to close that gap, standardizing how a building’s energy use or a portfolio’s carbon intensity gets measured and reported so that one fund’s numbers can actually be compared to another’s. Dame Alison Rose’s involvement with this kind of benchmarking work reflects a conviction that standardization has to happen at the asset level, not just the corporate level, before capital allocation decisions in real estate and infrastructure can be trusted.
What Better Data Would Actually Change
Reliable sustainability data would not, on its own, make any company greener. What it would do is let capital find the companies that are already performing well and reward them with a lower cost of capital, while making it harder for weaker performers to raise money on the strength of a well-written disclosure. That reallocation effect, capital moving toward genuine performance rather than toward good storytelling, is the actual mechanism by which better data changes outcomes. It works through markets rather than mandates.
The Verification Gap
Financial statements get audited by firms with legal liability for getting it wrong. Most sustainability disclosures still do not carry that same level of external verification, which means a company has limited downside if its reported figures turn out to be optimistic. Dame Alison Rose has pointed to one of the more underfunded parts of the sustainability data infrastructure, since building better reporting standards accomplishes little if nobody is checking whether companies actually follow them.
A Slow Fix for an Urgent Problem
None of this closes quickly. Standards take years to develop, adoption takes years to spread, and verification infrastructure takes years to build out at scale. Rose has been candid that the timeline for fixing sustainability data does not match the urgency of the capital allocation decisions that depend on it, which leaves investors making high-stakes choices with imperfect information in the meantime. Her argument is not that this justifies waiting. It is that acknowledging the gap honestly is a precondition for closing it, since a market that pretends its data is already reliable has little incentive to invest in making it actually reliable.
Why the Work Continues Past Any Single Institution
Fixing a comparability problem across an entire asset class was never going to be a single bank’s project. It requires benchmarking bodies, auditors, regulators, and the institutions holding the capital to converge on shared standards, which is slower and less visible than any individual firm’s disclosure improvements. Dame Alison Rose’s continued involvement in this work after leaving her role as a bank chief executive, tracked on LinkedIn, suggests she sees the data problem as bigger than any one balance sheet, a piece of financial infrastructure that has to be built collectively before the capital allocation it is meant to guide can actually be trusted.
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