This article analyzes the Brazilian ESG reporting model from a comparative perspective with the European regime established by the Corporate Sustainability Reporting Directive (CSRD), seeking to identify its main limitations, challenges, and prospects for evolution. The research starts from the observation that the growing relevance of environmental, social, and governance factors has driven the construction of normative structures focused on corporate transparency and the management of socio-environmental risks. While the European Union is advancing in the consolidation of an integrated, standardized, and auditable system for disclosing sustainability information, based on the principle of double materiality, Brazil still presents a scenario marked by regulatory fragmentation, the sectoral action of different regulatory bodies, and the absence of a transversal normative framework. The study examines the historical evolution of corporate socio-environmental responsibility, the international consolidation of the ESG agenda, and the role of recent instruments, such as CVM Resolution No. 193/2023 and Law No. 15,042/2024, which established the Brazilian Emissions Trading System (SBCE). In conclusion, it is argued that the main challenge for the Brazilian legal system lies in promoting greater integration between ESG reporting mechanisms, economic instruments for environmental regulation, and climate policies, in order to ensure greater comparability, reliability, and effectiveness of the information disclosed, strengthening corporate governance and the efficient allocation of capital towards sustainability.