Environmental Disclosure and Green Legitimacy in PT KAI Subsidiaries

Abstract

This study analyzes how subsidiaries within a single Indonesian state-owned holding company adopt different environmental disclosure strategies to build and sustain organizational legitimacy. Using content analysis of the 2024 annual reports of four PT Kereta Api Indonesia (Persero) subsidiaries—KAI Logistik, KAI Commuter, KAI Bandara, and KAI Wisata—and guided by Legitimacy Theory and Signaling Theory, the research compares disclosure patterns based on GRI Standards. The findings reveal significant heterogeneity in disclosure practices across subsidiaries. KAI Logistik demonstrates the most comprehensive approach, reporting full-scope greenhouse gas emissions, holding ISO 14001:2015 certification, and providing carbon intensity metrics. KAI Commuter emphasizes infrastructure-based environmental initiatives such as green stations and renewable energy plans but lacks quantitative data. KAI Bandara introduces an innovative, consumer-oriented sustainability initiative (ReLIFE), yet its disclosures remain qualitative. Unexpectedly, KAI Wisata provides detailed, GRI-aligned quantitative environmental data, including energy use, fuel consumption, water usage, and disaggregated emissions, indicating that disclosure quality is driven more by organizational commitment than sector type. The study interprets these findings through two legitimacy models: a compliance-accountability model among transportation subsidiaries and a narrative-engagement model among service-oriented entities, with KAI Wisata representing a hybrid form. This research contributes to sustainability accounting by introducing the concept of intra-holding disclosure heterogeneity within state-owned enterprises in developing economies, challenging assumptions that sector determines disclosure quality, and suggesting that standardized GRI-based reporting across subsidiaries could reduce greenwashing risks and enhance overall corporate credibility