We propose a more expansive analysis of accounting regulation, highlighting the significance of a regulatory network and the importance of examining the recursive processes involved in the transition from formal law to practice. Our analysis is grounded in the sociology of law and is exemplified by the case of a corporate disclosure regulation for Canada's extractive industry. The paper examines how the regulator, in concert with intermediary actors, works to clarify and influence the practice of law, what we refer to as operationalization. In providing a historically and socially contextualized analysis, the paper treats regulation as a dynamic process that includes multistakeholder working groups, legislative debates, regulatory procedures, and shifting meanings of compliance and enforcement. We examine operationalization as a distinct regulatory dynamic and explore its significance for an expanded understanding of accounting regulation.

Taking inspiration from studies of performance measurement systems and an understanding of the materiality of inscription devices, we examine how a loose network of funding agencies and non-governmental organizations (NGOs) assemble a performance and management system out of accountability requirements. As part of the funding process, international development agencies provide NGOs with a series of planning and project reporting requirements such as budgets, operational plans, and strategic plans. Our study focusses on how these requirements' visual features enable users to perform the calculative properties of the performance system, as a whole. Specifically, we learn how a planning and performance measurement device such as the logical framework accumulates financial, chronological, and strategic modes of ordering through a patchwork of interventions to address perceived and unexpected shortcomings. We find that it is not just a matter of adding patches to improve, but also about fostering engagement with the changing assemblage of devices and development concerns. Our study is based on field research in Guatemala and El Salvador and contributes to our understanding of how governing bodies intervene in the constitution of a calculative workspace. By analysing an accounting system's relation with other devices and their modes of ordering and calculating, we learn how a workspace for providing accounts is assembled and engaged with for actors to perform a mode of governing.

We examine responses to pressures to act on extractive firm country-by-country reporting (CbCR) by three regulators: the International Accounting Standards Board, the European Commission, and the Securities and Exchange Commission. Debates over CbCR of payments that extractive firms make to governments center on improvements to transparency, governance, and accountability and raise questions about the division of regulatory labor in terms of where and by whom global reporting issues are undertaken and why. Our comparative analysis suggests that while the three regulators resist or respond reluctantly to similar pressures to act on CbCR, each responds in distinct ways that reflect and impact regulatory mandates. Specifically, we show how the regulators’ responses constitute the purpose, problematize the objectives, and construct the perceived interests served by CbCR in relation to each regulator’s mandate. We highlight how these responses can be understood through modes of discursive ignorance (McGoey, 2019) and the uncomfortable knowledge (Rayner, 2012) that each regulator may engage with when pressures challenge how regulators make sense of the world. Our study highlights that regulatory responses are based partly on what regulators assume are their mandates, their legitimacy and ways of operating. It analyzes their self-understandings and defense mechanisms, thereby providing an elaboration of responses to pressures for action and offering a richer political economy of regulation that highlights sensemaking in these processes. We further elaborate on what these responses imply for the division of regulatory labor around pressures to act on global reporting issues, as well as broader implications for participation in and ignorance around accounting regulatory projects.