Sustainability KPIs in heritage-city hotels: why one-size-fits-all ESG frameworks fail and what should replace them

Over the past decade, the global hotel industry has converged around a common sustainability vocabulary organized around environmental, social, and governance (ESG) frameworks such as the Global Reporting Initiative, the Sustainability Accounting Standards Board, and the Global Sustainable Tourism Council Industry Criteria for Hotels (1,2). These frameworks have been integrated into corporate disclosure obligations across major hotel chains (3,4), most recently formalized in the Universal Sustainability KPIs presented at COP29 by the World Sustainable Hospitality Alliance (19), and have proven valuable in their original context of large purpose-built chain hotels. Their global proliferation, however, rests on the assumption that a universal set of KPIs can be effectively applied to properties varying significantly in size, location, and architectural context.This assumption deserves careful analysis. The accommodation sector in heritage cities, hotels in centuries-old buildings on UNESCO sites at scales far smaller than chain hotels, faces realities for which dominant ESG frameworks were not developed (5,6). In Bukhara, a UNESCO-listed historic city since 1993, eight cultural heritage sites operate as hotels, and the regional sector comprises 601 establishments by 2024: one five-star, three four-star, and 592 standard small properties. Tourist arrivals grew from 1.45 million in 2017 to 4.88 million in 2023, with foreign arrivals expanding more than eightfold (7,23). The structural mismatch between a KPI architecture calibrated for chain hotels and a region of small heritage and family-run properties in a high-volatility tourism environment merits substantive analysis.This opinion article argues that universal ESG frameworks show systematic limitations in heritage cities along three structural dimensions: heritage-architectural constraints, scale and ownership patterns inappropriate for small properties, and tourism-volatility profiles producing signals that diverge from underlying performance. The argument is calibrated to heritage-city contexts, combining these three features; in mature markets dominated by chain properties, standard frameworks remain operationally appropriate. Methodologically, this is a conceptual contribution that draws on a single illustrative case (Bukhara region) to anchor the argument empirically; secondary statistical data from publicly available regional tourism reports (7) are used illustratively to demonstrate the structural mismatch between standard ESG frameworks and heritage-city realities, not as the basis for inferential claims. The contribution is therefore opinion-based and theory-driven, with empirical material serving an evidential rather than analytical role. We draw on three theoretical frameworks: Elkington's Triple Bottom Line (8); Ritchie and Crouch's destination competitiveness model (9); and the Resource-Based View (10), which explains heritage cultural assets as non-replicable competitive advantages. Building on these and on Bukhara tourism statistics for 2017-2024, we propose a six-cluster heritage-sensitive KPI panel that preserves the comparability benefits of global ESG frameworks while substituting context-appropriate indicators.Three structural features of the accommodation sectors in heritage cities highlight the limitations of standard ESG frameworks: protected architectural structure, the predominance of small properties, and high interannual tourism volatility.Eight heritage sites in Bukhara operate as hotels, embedded within 347 heritage objects across the region (7). These structures, restored caravanserais, madrasas, and merchant houses from the 16th-19th centuries, are subject to UNESCO conservation requirements prohibiting alterations to envelopes, fenestration, and load-bearing walls (11). Standard ESG environmental KPIs assume envelope retrofit, mechanical ventilation upgrades, and rooftop solar installation, none of which is generally permissible in protected premises. Energy intensity benchmarks calibrated to modern hotel buildings, therefore tend to underrepresent the achievable performance of heritage hotels; the frameworks are calibrated to a different reference class (12,21).Of 601 accommodation establishments in the Bukhara region (2024), one is five-star, three are four-star, and 592 are standard-tier small properties; 307 family-run guesthouses, 82 hostels, and 3 motels complete the sector (7). Standard ESG governance indicators, board-level committees, third-party assurance, integrated disclosure, and ESG-linked compensation are meaningful for chain properties but less applicable to sub-twenty-room family-run properties that lack legal-personality boards or audit functions (3,13,20). Social-pillar metrics such as supplier-diversity quotas similarly presume corporate procurement systems smaller heritage hotels lack. The dominant 99 percent of Bukhara's accommodation supply is therefore evaluated against criteria the property structure cannot, by design, fully satisfy -a structural pattern across SMEs in developing economies (25).Tourist arrivals to Bukhara grew from 1.45 million in 2017 to 3.64 million in 2019, collapsed to 250,000 in 2020 under pandemic restrictions, and recovered to 4.88 million by 2023 (7). Standard ESG panels report intensity per occupied room-night and benchmark performance through year-on-year change, implicitly assuming demand stability typical of mature high-income markets (1,4). Under tenfold volatility within four years, annual intensity ratios may become artefacts of demand cycles rather than indicators of effort. The benchmarking logic of ESG frameworks, while appropriate in stable mature markets, can therefore generate signals that diverge from underlying performance in high-volatility heritage-city contexts.The panel developed below is offered as a conceptual provocation illustrating how context-calibrated substitution might operate in practice, and not as a fully specified operational manual; consistent with the opinion-article format and the single-case, illustrative use of data noted in the Introduction, the specific formulations, room-count cut-points, and revenue threshold that follow are heuristic devices intended to demonstrate feasibility in principle. They are not empirically derived, field-tested specifications, and their precise calibration is left to the staged validation pathway set out in the Limitations section below.Three broad approaches exist for addressing context misfit between global ESG frameworks and heritagecity realities. The first, contextual adaptation, retains the architecture of global ESG frameworks but reweights individual indicators to local conditions; while administratively economical, this approach preserves the underlying assumption of cross-context comparability that the heritage case challenges (15). The second, parallel reporting, requires properties to disclose against both global and locally developed indicator sets; this approach generates richer information but doubles the compliance burden for small operators with limited managerial capacity (20). The third, targeted substitution, replaces context-blind indicators with context-calibrated equivalents while preserving comparable measurement logic. The panel proposed in this article adopts the third approach, because it best reconciles the comparability strengths of global ESG frameworks with the operational realities of heritage-city accommodation. The proposed KPI panel below is based on three principles. First, it maintains comparability across sites by retaining quantitative, auditable metrics rather than descriptive disclosures. Second, it replaces context-agnostic metrics with context-calibrated equivalents that account for architectural constraints, site scale, and tourism volatility. Third, it introduces three clusters, integration of craft supply, contribution to heritage conservation, and inclusive seasonal occupancy, that reflect place-specific value aspects central to hotel performance in heritage cities but absent from global ESG frameworks (14,15). Recent evidence from Silk Road heritage cities confirms that visitor satisfaction and economic outcomes in such contexts are mediated by place-specific cultural, event-based, and infrastructural experiences that conventional metrics do not capture (18). Table 1 presents the resulting six-cluster panel as an illustrative operationalization sketch rather than a finished measurement protocol: each KPI is accompanied by a candidate definition, an indicative formulation, and a plausible verification source, offered to demonstrate that contextcalibrated substitution is conceptually feasible and to provide a concrete starting point for the empirical calibration process described in the Limitations section, not as fixed operational specifications ready for deployment. The three theoretical frameworks operate at distinct yet interlocking levels within the proposed panel. The Triple Bottom Line (8) defines what requires measurement (economic, environmental, and socio-cultural dimensions); the destination competitiveness model ( 9) specifies how infrastructure, governance, and qualifying determinants enable or constrain sustainable performance at the destination level; and the Resource-Based View (10) explains why heritage-embedded cultural assets -UNESCO-protected fabric, artisan economies, place-specific competencies -constitute non-replicable competitive endowments that warrant their own measurement architecture. The interaction is the following: heritage-architectural constraints (cluster 1) and governance structures (cluster 2) jointly determine which TBL dimensions can be operationally measured at the property level, while RBV-grounded clusters (4-5) capture the placespecific value dimensions that conventional measurement systems cannot detect. The six-cluster panel thus emerges from a triangulation of theoretical lenses rather than from their additive aggregation, and is presented schematically, as an illustrative sketch rather than a finished protocol, in the operationalization table below. Achievable for the 99% small-property segment of Bukhara's accommodation supply while still generating verifiable, comparable disclosure (13,20,25).Three-year rolling intensity average with shock-period correction factorIllustrative formulation: Captures whether residents secure year-round livelihoods or only seasonal employment in volatile destinations (24).[(intensity_t-2 + intensity_t-1 + intensity_t) ÷ 3] × correction_factor,Bottom Line (8); Ritchie & Crouch = destination competitiveness model ( 9); RBV = Resource-Based View (10) Implementation in Bukhara and analogous heritage destinations requires three coordinated actions. First, the regional tourism department should establish a municipal disclosure registry accepting cluster 2 declarations and aggregating sector-level indicators annually; institutional infrastructure already exists, as the department publishes baseline accommodation statistics (7). Second, conservation-permissible baselines for cluster 1 should be set through a one-time joint technical assessment by the regional tourism department and the cultural heritage agency (11,22). Third, artisan-procurement integration for cluster 4 should be supported through a standardized supplier-registry interface linking the 2,550 registered Bukhara artisans and 21 craft centers directly to accommodation procurement (16). These actions are sequential: registry → cluster 2; baselines → cluster 1; supplier interface → cluster 4.The framework is not universally applicable. Three conditions limit its scope. First, it assumes a heritagetourism context combining protected architecture, small-property dominance, and inter-annual demand volatility; in mature markets dominated by chain properties, standard ESG concepts remain appropriate (3,4). Second, it requires municipal coordination capabilities to operate the disclosure register and supplier interface; without these, clusters 2 and 4 cannot be reliably operationalized. Third, it assumes a regulated heritage-conservation regime, without which cluster 1 baseline calibration is not possible. Heritage contexts not meeting all three conditions fall outside the framework's scope. Within the eligible scope, several heritage-city contexts beyond Central Asia share the three structural features on which the argument is built: protected architecture, small-property dominance, and volatile visitor demand. Cartagena de Indias (Colombia), Hoi An (Vietnam), Luang Prabang (Lao PDR), and Lalibela (Ethiopia) are illustrative cases in this respect. Structural similarity along these three dimensions is not, however, sufficient for transferability, and direct global applicability should not be assumed. Two further axes of variation are likely to condition, and in some cases undermine, the panel's operability. First, ownership structure: Clusters 2 and 4 presuppose an identifiable, addressable population of owner-operators, as in Bukhara's family-run guesthouse sector; destinations where heritage accommodation is instead organized through leasehold concessions, absentee ownership, cooperative management, or state-owned heritage estates would require a substantially redesigned governance and disclosure architecture, not a simple recalibration of thresholds. Second, governance style: the framework assumes a single, identifiable subnational authority -in Bukhara's case, the regional tourism department acting alongside the cultural heritage agency -capable of operating a registry, certifying conservation baselines, and maintaining an artisan database. Destinations with decentralized, federal, NGO-led, or fragmented heritage governance may lack an equivalent authority altogether, which would compromise Clusters 1, 2, and 4 independently of property-level willingness to comply. The four comparator cities above should therefore be read as illustrating structural similarity on the demand and property-scale dimensions rather than as evidence that the panel would transfer intact; ownership-structure and governance-style transferability are separate, untested assumptions that would need to be examined case by case. Cross-city comparison is the appropriate empirical test, incorporated in the validation pathway below.Three categories of implementation risk warrant explicit consideration. First, administrative burden for small operators: even a one-page disclosure declaration (cluster 2) imposes a marginal compliance cost on sub-ten-room family-run properties whose owner-operators already function under thin managerial capacity (13,20). A room-count threshold is therefore proposed to scale Cluster 2 obligations to property capacity: properties with fewer than 10 rooms file a reduced two-field declaration (energy, water only); properties with 10-20 rooms file the standard five-field declaration; properties above 20 rooms file the five-field declaration alongside a brief narrative addendum. This threshold directly addresses the 307 family-run guesthouses and sub-twenty-room segment identified as least able to absorb full disclosure burden, while preserving comparable minimum data for aggregation; without such targeted simplification the panel risks reproducing in miniature the very burden it seeks to alleviate. Second, bureaucratization of sustainability: where the municipal disclosure registry becomes an end in itself rather than a substantive feedback mechanism, properties may comply formally while heritage-sustainability practice remains unchanged, a pattern documented across compliance-driven sustainability regimes (15). Mitigation requires that the registry be paired with feedback loops linking disclosure data to operator-facing benchmarks and conservation-funding decisions. Third, limited institutional capacity at the local level: cluster 1 baselines and cluster 4 supplier registries presuppose technical and coordination capabilities that municipal heritage and tourism authorities may not yet possess, particularly in lower-income heritage destinations beyond Bukhara; pre-implementation capacity assessment and, where needed, technical assistance from international heritage organizations (11,27) should therefore precede full panel adoption. These risks do not invalidate the proposed framework, but they qualify the conditions under which it can be expected to deliver substantive, rather than purely procedural, sustainability outcomes.As an opinion article, this contribution is conceptually grounded but empirically untested: each cluster's substitution logic is supported by the structural patterns documented above, but no validation of the proposed indicators has been conducted. The framework is calibrated to a single heritage-destination case (Bukhara region), and its transferability to other UNESCO heritage cities requires further documentation.A further, more fundamental limitation concerns where the framework locates administrative burden rather than whether it removes it. The panel is motivated by the observation that small heritage operators lack the managerial capacity to sustain standard ESG reporting; the proposed correction, however, does not eliminate that burden so much as relocate it, from private operators to public institutions. Clusters 1, 2, and 4 collectively presuppose a municipal disclosure registry, a heritage-agency baseline-certification function, and a maintained artisan-supplier database -a state-capacity package that is itself far from guaranteed. Bukhara's regional tourism department already publishes baseline accommodation statistics (7), which somewhat lowers this bar locally, but the same institutional infrastructure cannot be assumed in lower-income or lower-capacity heritage destinations, where municipal tourism authorities may have neither the staff, the data systems, nor the budget to operate a registry, let alone to issue conservationpermissible energy baselines or maintain a craft-supplier register. In such settings the framework, as specified, is not implementable, and its adoption would require either sustained external technical assistance (11,27) well beyond the pilot stage, or a lighter-weight variant confined to the clusters (3,5,6) that do not depend on a standing municipal registry. This is a structural limitation of the substitution logic itself -a relocation of burden from a private-sector actor with limited capacity to a public-sector actor whose capacity is not established -and not merely an implementation risk to be mitigated through better design.A staged empirical validation pathway is therefore proposed for subsequent research. A first stage would involve a Delphi study with 15-20 experts (heritage hotel managers, conservation authorities, municipal tourism officials) across two to three iterative rounds to refine indicator definitions and thresholds. A second stage would conduct a multi-city comparison across three to five heritage destinations to test transferability assumptions, including destinations with ownership structures and governance styles distinct from Bukhara's. A third stage would pilot property-level implementation across ten to fifteen heritage hotels over twelve months to assess data-collection burden, behavioral effects, and signal quality relative to standard ESG reporting (17).Hotels in heritage cities operate under three structural conditions -protected architectural fabric, a predominance of small properties, and tenfold inter-annual tourism volatility that lie outside the design scope of global ESG frameworks calibrated to large purpose-built chain hotels. The proposed panel preserves the comparative advantages of global frameworks while replacing indicators less relevant to heritage settings with context-specific indicators and adding three site-specific clusters that capture aspects of value not captured by standard frameworks. The panel is conceptually sound but has not been empirically tested; its next task is to implement a promising pilot program in a sample of heritage cities, following the stepwise validation process described above. For heritage cities such as Bukhara, the operational question is no longer whether to measure sustainability, but how, through frameworks that fit the destination, complementing rather than replacing global ESG reporting.