This new chapter analyses corporate sustainability frameworks in line with the G20/OECD Principles of Corporate Governance. Chapter 5 covers information on sustainability-related disclosure requirements and recommendations, as well as the coverage of sustainability disclosures in relation to transition planning and value chain information. The chapter also outlines board responsibilities for sustainability policies, the regulatory frameworks for ESG rating agencies and index providers, and the assurance of sustainability-related information.
5. Corporate sustainability
Copy link to 5. Corporate sustainabilityAbstract
Infographic 5.1. Key facts and figures on corporate sustainability
Copy link to Infographic 5.1. Key facts and figures on corporate sustainability
5.1. Sustainability-related disclosure
Copy link to 5.1. Sustainability-related disclosureNearly all Factbook jurisdictions have established regulatory or voluntary provisions pertaining to sustainability-related disclosure, largely grounded in internationally recognised standards. Sixty-three percent of the relevant requirements and recommendations apply to both listed and non-listed companies, while 71% of jurisdictions offer flexibility for smaller listed companies. In most cases, companies’ approval processes for sustainability disclosures align with those of financial reporting. In 65% of Factbook jurisdictions, sustainability disclosures are primarily intended to serve multiple stakeholders and not just investors.
The G20/OECD Principles of Corporate Governance (hereafter “G20/OECD Principles”) were revised in 2023 to include a new chapter on corporate sustainability and resilience. This new chapter reflects the growing challenges corporations face in managing climate-related and other sustainability risks and opportunities. The Factbook includes a corresponding new chapter on corporate sustainability, which covers a range of policies related to recommendations from the G20/OECD Principles on corporate disclosure, the dialogue between a company and its shareholders and stakeholders on sustainability-related matters, and the role of the board in addressing these matters.
5.1.1. Sustainability-related disclosure requirements and disclosure standards
As investors have considered disclosures about how companies assess, identify and manage material sustainability-related risks and opportunities, jurisdictions have increasingly introduced sustainability-related disclosure requirements. While 79% of Factbook jurisdictions require sustainability-related disclosure in their law or regulations, 11% set requirements in their listing rules, and 8% recommend sustainability-related disclosure in codes or principles (hereafter “recommendations”) (Figure 5.1, Panel A). This compares to nearly two-thirds of jurisdictions that had a legal or regulatory requirement, 8% with requirements in listing rules, and 24% that included sustainability-related disclosure as a recommendation at the end of 2022.
As recommended in sub-Principle VI.A.2., sustainability-related disclosure frameworks should be consistent with internationally recognised standards that aid comparability across markets. In line with sub-Principle VI.A.2., 71% of Factbook jurisdictions use either the European Sustainability Reporting Standards (ESRS), International Financial Reporting Standards (IFRS) Sustainability Standards or other standards such as the Task Force on Climate Related Financial Disclosures (TCFD) (Figure 5.1, Panel B), up from 12% of jurisdictions using internationally recognised standards at the end of 2022.
As of the end of 2024, the most frequently adopted standard, at 46%, was the ESRS. The EU’s Corporate Sustainability Reporting Directive (CSRD) requires companies to report against the ESRS, which was developed by EFRAG and subsequently adopted by the European Commission (EU, 2022[1]). The ESRS consists of cross-cutting standards – applicable to listed and non-listed companies – and topical standards covering environmental, social and governance issues. However, in February 2025, the EU announced an Omnibus Package, which seeks to ease reporting requirements for companies. The Omnibus proposes to revise the ESRS to reduce the number of required data points, clarify unclear provisions, and remove the requirement for sector-specific ESRS.
The second most commonly used sustainability standard among Factbook jurisdictions was the International Financial Reporting Standards (IFRS) Sustainability Standards at 17%. In June 2023, the International Sustainability Standards Board (ISSB) issued its inaugural IFRS Sustainability Disclosure Standards – General Requirements for Disclosure of Sustainability-related Financial Information and Climate-related Disclosures (IFRS Foundataion, 2023[2]; 2023[3]). Among the Factbook jurisdictions that reported the adoption of IFRS Sustainability Standards, three (Australia, Canada, Türkiye) are creating their own local sustainability reporting standards based on the IFRS Sustainability Standards (Table 5.1).
Four Factbook jurisdictions (Colombia, Costa Rica, New Zealand, the United Kingdom) have adopted other international sustainability standards, such as the Task Force on Climate-Related Financial Disclosure (TCFD) Recommendations. Finally, while 12% of Factbook jurisdictions (China, Germany, Hong Kong (China), India, Peru, Saudi Arabia) have developed local standards, 17% of Factbook jurisdictions do not establish a sustainability disclosure standard to be followed by companies (Table 5.1).
Figure 5.1. Sustainability-related disclosure frameworks
Copy link to Figure 5.1. Sustainability-related disclosure frameworks
Note: Panels A and B are based on 52 jurisdictions. The category “IFRS Sustainability Standards” in Panel B includes both jurisdictions that have adopted integrally the IFRS Sustainability Standards and jurisdictions that have developed local standards largely based on IFRS Sustainability Standards. See Table 5.1 for data.
5.1.2. Coverage of companies, approval process for sustainability disclosure and users of sustainability information
Sixty-three percent of Factbook jurisdictions’ sustainability disclosure frameworks apply to both listed and non-listed companies while the remaining cover listed companies only (Table 5.1). In addition, 71% of Factbook jurisdictions provide flexibility for smaller companies (Figure 5.2, Panel A). Sub-Principle VI.A.3 promotes the connection between the disclosures of sustainability-related and financial information. In 76% of Factbook jurisdictions, companies’ approval process for sustainability disclosure is the same as for financial disclosure (Figure 5.2, Panel A). This effectively means that, in a substantial majority of jurisdictions, the same corporate body (e.g. the shareholder meeting or the board of directors) approves both the financial and sustainability disclosures.
The primary intended users of sustainability-related disclosures among Factbook jurisdictions are multiple stakeholders at 65%, including EU member states, while investors are the only primary users in 17% of jurisdictions and 18% of jurisdictions do not specify an intended primary user (Figure 5.2, Panel B). The identification of primary users is directly related to the scope of the information that the company must disclose: if multiple stakeholders are the primary users, the company will likely need to disclose more datapoints and qualitative information than if only investors were the main intended users.
Figure 5.2. Flexibility for smaller listed companies, the approval process for sustainability disclosure and the primary users of sustainability-related disclosure
Copy link to Figure 5.2. Flexibility for smaller listed companies, the approval process for sustainability disclosure and the primary users of sustainability-related disclosure
Note: Panels A and B are based on 51 jurisdictions. The United States is excluded from the analysis due to the absence of any sustainability disclosure provisions that are requirements or recommendations. See Table 5.1 for data.
5.2. Sustainability disclosure content coverage
Copy link to 5.2. Sustainability disclosure content coverageEighty-five percent of Factbook jurisdictions require or recommend the disclosure of metrics related to sustainability-related goals, while 60% require or recommend the disclosure of transition planning. Another 10% reported undertaking public consultation or actively considering introducing such provisions. Value chain disclosure is required or recommended in 71% of jurisdictions. Reporting relates to all material sustainability matters in 85% of Factbook jurisdictions, while two only require reporting on climate-related matters.
In recent years, an increasing number of companies have set sustainability-related goals. If companies publicly set sustainability-related goals, from a market efficiency and investor protection perspective, the disclosure framework should ensure sufficient, consistent, comparable and reliable information and metrics. This allows investors to assess the credibility of the announced goal and management’s progress towards meeting it, as articulated in sub-Principle VI.A.4.
In 85% of Factbook jurisdictions, there is a requirement or recommendation to disclose metrics related to sustainability-related goals (Figure 5.3, Panel A), an increase from 53% in 2022. Specifically, 69% of the jurisdictions require the disclosure of metrics related to sustainability-related goals by law or regulation. In three jurisdictions (China, Malaysia, Singapore), it is a requirement via the listing rules to disclose metrics related to sustainability-related goals while it is recommended in five jurisdictions.
Transition planning is a legal or regulatory requirement in 58% of Factbook jurisdictions, and 2% require transition planning based on their listing rules. Iceland, Japan, Korea, the Netherlands and the United Kingdom are undertaking public consultation or actively considering introducing requirements. Twenty-nine percent of Factbook jurisdictions do not have such a provision nor were they actively considering adopting one as of end of 2024 (Figure 5.3, Panel B).
The disclosure of value chain information is required by law or regulations in 62% of Factbook jurisdictions. China and Singapore require value chain information in their listing rules, and Canada, Iceland and Korea suggest this information in their recommendations. Twenty-seven percent of Factbook jurisdictions do not have any requirements regarding value chain information (Figure 5.3, Panel B). Additionally, 85% of jurisdictions require or recommend reporting on all material sustainability matters, while New Zealand and the United Kingdom only require reporting on climate-related matters (Table 5.2).
Figure 5.3. Metrics for sustainability-related goals, and the disclosure of transition planning and value chain information
Copy link to Figure 5.3. Metrics for sustainability-related goals, and the disclosure of transition planning and value chain information5.3. Corporate sustainability governance
Copy link to 5.3. Corporate sustainability governanceIn more than two-thirds of Factbook jurisdictions, boards are explicitly required or recommended to approve policies on sustainability matters. However, requirements or recommendations for boards to supervise lobbying activities and/or political donations are infrequent. Half of the jurisdictions do not set specific requirements or recommendations for the disclosure of lobbying activities and political donations.
Principle VI.C. recommends that the corporate governance framework should ensure that boards adequately consider sustainability risks and opportunities that may impact the company’s long-term value creation. Consistent with this, 71% of Factbook jurisdictions explicitly require or recommend that the board approve policies on sustainability matters (Figure 5.5, Panel A), an increase from 51% at the end of 2022. For example, in Indonesia, issuers’ sustainability reports must include a statement from the board of directors outlining the company’s sustainability strategies and policies, and how they address the challenges of implementing such strategies. Jurisdictions that require boards to adopt sustainability-related policies through laws or regulations account for 38%, while 23% of jurisdictions recommend it. In 10% of the jurisdictions (China, Hong Kong (China), Singapore, South Africa, Sweden), it is a requirement through the listing rules for boards to have responsibility for sustainability-related policies. In 29% of the jurisdictions, there is no formal requirement or recommendation for boards to have responsibilities for sustainability policies.
Sub-Principle VI.C.1. states that “boards should ensure companies’ lobbying activities are coherent with their sustainability-related goals and targets.” In some jurisdictions, boards have a role in overseeing their companies’ political donations and lobbying activities (Figure 5.4). While over four-fifths of Factbook jurisdictions do not set explicit requirements or recommend boards to have an oversight of lobbying activities and/or political donations, 15% of jurisdictions set requirements by law or regulations (Figure 5.5, Panel B). For example, in India, the Companies Act enables a company to contribute to any political party, but the conditions are that the contribution should (i) be authorised by the board, (ii) not be made in cash, and (iii) be disclosed in the company’s income statement.
Figure 5.4. Factbook jurisdictions with provisions on corporate sustainability governance
Copy link to Figure 5.4. Factbook jurisdictions with provisions on corporate sustainability governance
Note: The figure displays Factbook jurisdictions that require or recommend the disclosure of lobbying activities and/or political donations, as well as the related responsibilities of the boards. White denotes no provision. See Table 5.3 for data.
For the disclosure of lobbying activities, 23% of Factbook jurisdictions explicitly require or recommend disclosure by law or regulations and 23% set requirements through recommendations (Figure 5.5, Panel B). For the disclosure of political donations, 27% of Factbook jurisdictions set requirements by law or regulations and 23% set recommendations (Figure 5.5, Panel B). No jurisdiction sets requirements for the disclosure of lobbying activities and political donations through listing rules.
Figure 5.5. Board responsibilities for sustainability-related policies and oversight of lobbying activities and/or political donations
Copy link to Figure 5.5. Board responsibilities for sustainability-related policies and oversight of lobbying activities and/or political donations5.4. ESG rating agencies and index providers
Copy link to 5.4. ESG rating agencies and index providersFrameworks for ESG rating agencies and index providers are still limited to a few jurisdictions outside the EU. Among non-EU Factbook jurisdictions with such frameworks, approaches vary in combining laws, regulations and voluntary codes of conduct. In jurisdictions with frameworks for ESG rating agencies only, most adopt a principles or code-based non-mandatory approach. Only three jurisdictions outside the EU (Australia, China and Norway) have frameworks for index providers.
The G20/OECD Principles recognise that the investment chain in today’s global capital markets relies on many service providers that support institutional investors for analysis and advice. In particular, ESG rating and index providers can have significant impact on companies’ governance and sustainability policies and practices given their rating methodologies and index inclusion criterion. As such, Principle III.D. advocates for the disclosure and minimisation of conflicts of interest and that the methodologies used by service providers be publicly available.
In 2021, the International Organization of Securities Commissions (IOSCO) published a report on ESG ratings and data providers, highlighting key challenges and proposing ten recommendations for regulators and market participants (IOSCO, 2021[4]). In 2022, IOSCO issued a Call for Action, promoting good practices such as robust and transparent methodologies, conflict management, protection of non-public information, efficient data collection, and clear communication with rated entities (IOSCO, 2022[5]). In response, Hong Kong (China), Japan, Singapore and the United Kingdom have since introduced codes of conduct based on these recommendations.
One-third of Factbook jurisdictions do not have any frameworks for ESG rating and index providers. Among the 54% that do have frameworks for both types of providers, all require or recommend the disclosure of methodologies and the management of conflicts of interest (Table 5.4). These jurisdictions are primarily EU member states, which are subject to the Benchmarks Regulation and the ESG Ratings Regulation (EU, 2016[6]; EU, 2024[7]).
Outside of the EU, India, Japan and the United Kingdom have frameworks for both ESG rating agencies and index providers, which all require or recommend the disclosure of methodologies and the management of conflicts of interest (Table 5.4). However, each of these jurisdictions have different approaches. India takes a regulation-based approach to ESG rating agencies and index providers, addressing key issues such as conflict of interest and methodology transparency. In the United Kingdom, ESG rating agencies are currently overseen based on a code of conduct, although the UK government published draft legislation in 2024 with the goal to bringing ESG rating providers into a formal regulatory regime. Index providers in the United Kingdom are regulated through the Benchmarks Regulations, which have been retained after the country left the EU (HM Treasury, 2024[8]). In Japan, ESG rating agencies and index providers may follow recommendations in a code of conduct.
Of the four Factbook jurisdictions (Costa Rica, Hong Kong (China), Korea, Singapore) that only have frameworks for ESG rating agencies, all except Costa Rica have voluntary provisions through a code of conduct. In Costa Rica, a law or regulation-based approach is taken to the management of conflicts of interest whereas there are no requirements regarding the disclosure of methodologies (Table 5.4). Australia, China and Norway have frameworks for index providers only (Table 5.4). In China, while index providers operate within a framework, there are no requirements for disclosing their methodologies or managing conflicts of interest.
5.5. Sustainability assurance frameworks
Copy link to 5.5. Sustainability assurance frameworksSixty-two percent of Factbook jurisdictions require or recommend sustainability assurance frameworks and 17% are actively considering introducing such a policy. Fifty-eight percent of jurisdictions require assurance on all sustainability information whereas 13% of jurisdictions limit assurance to certain sustainability information such as GHG emissions. Of the jurisdictions that seek to phase in assurance requirements, the majority plan to introduce limited assurance while reasonable assurance is less common.
5.5.1. Sustainability assurance frameworks and assurance service providers
The majority of Factbook jurisdictions require or recommend sustainability assurance frameworks (Figure 5.6, Panel A). Sixty percent require sustainability assurance through the law or regulations while Argentina recommends sustainability assurance via a code. Seventeen percent of Factbook jurisdictions are undertaking public consultations or actively considering introducing sustainability assurance frameworks. For example, in December 2024, Hong Kong (China) published a roadmap for the development of a comprehensive ecosystem to support sustainability disclosure, which encompasses sustainability assurance.
The scope of information subject to assurance in 58% of Factbook jurisdictions is all sustainability information (Figure 5.7). However, as suggested in sub-Principle VI.A.5, where high quality assurance for all disclosed sustainability-related information may not be possible or is too costly, mandatory assessment for the most relevant sustainability-related metrics or disclosures, such as GHG emissions, may be considered. For example, New Zealand limits assurance to scope 1, 2 and 3 GHG emissions while Singapore and Spain limit assurance to scope 1 and 2 GHG emissions.
Where sustainability assurance frameworks are in use or will be phased in over time, assurance providers play an important role in enhancing investors’ confidence in the information disclosed and the possibility to compare sustainability-related information between companies and markets. However, jurisdictions take different approaches regarding which entities can provide sustainability assurance. In 40% of Factbook jurisdictions, only statutory auditors, which are permitted to audit financial statements, may provide sustainability assurance services. One-fifth of jurisdictions allow both statutory auditors and other assurance service providers with accreditation by a public organisation to provide sustainability assurance services (Figure 5.6, Panel B). In Korea and New Zealand, assurance providers without an accreditation and statutory auditors may also provide sustainability assurance services.
Figure 5.6. Sustainability assurance requirements and assurance service providers
Copy link to Figure 5.6. Sustainability assurance requirements and assurance service providersFigure 5.7. Scope of assurance requirements
Copy link to Figure 5.7. Scope of assurance requirements5.5.2. Assurance standards
Under the EU’s CSRD, companies are required to obtain independent assurance over their sustainability disclosures, starting with limited assurance. For the initial limited assurance phase, EU member states may allow the use of national assurance standards, provided they are aligned with international best practices. The European Commission is developing EU-wide assurance standards for limited assurance, expected to be adopted by 2026. However, as part of the EU Omnibus Package, the proposal removes the possibility for the European Commission to decide on moving from a limited assurance to a reasonable assurance requirement.
Across Factbook jurisdictions, 38% reported that phasing in of assurance requirements was not under active consideration. Conversely, 62% of jurisdictions plan to phase in assurance requirements, of which 30 countries plan to phase in limited assurance and 6 plan to phase in reasonable assurance (Figure 5.8). Three countries (New Zealand, Norway, Türkiye) have already introduced limited assurance as the end of 2024. “Reasonable assurance” is the level typically required in the external auditing of financial statements, while “limited assurance”, as the name suggests, involves a less detailed review.
Of the 26 jurisdictions that have adopted an assurance standard, 9 disclosed the use of ISAE 3000. ISAE 3000 (Revised) is an international assurance standard issued by the International Auditing and Assurance Standards Board (IAASB) for assurance engagements other than audits or reviews of historical financial information. It is widely used for non-financial reporting, including sustainability disclosures, and provides a framework for both limited and reasonable assurance.
Furthermore, five countries (Brazil, Estonia, Greece, Malaysia, Spain) reported the adoption of ISSA 5000, a new standard for assurance of sustainability information issued by the IAASB in November 2024. ISSA 5000 is neutral with respect to the accounting standard used by the issuer, applicable to both limited and reasonable assurance engagements, and is designed to enhance consistency and quality across global sustainability assurance practices.
Five countries (Belgium, Bulgaria, Hungary, Lithuania, Singapore) allow the use of multiple assurance standards, while five (Australia, Ireland, Mexico, Poland, Türkiye) have the intention to adopt international standards or develop assurance standards with reference to international standards. For example, in Australia, the Auditing and Assurance Standards Board recently approved the adoption of ISSA 5000 as well as the Australian Standard on Sustainability Assurance (ASSA) 5010.
Finally, France and New Zealand have opted to use local assurance standards. For instance, in France, the Limited Assurance Guidelines of the French High Authority for Audit have been issued in line with the requirements under the EU’s CSRD.
Figure 5.8. Phasing in requirements across jurisdictions
Copy link to Figure 5.8. Phasing in requirements across jurisdictions
Note: The figure displays Factbook jurisdictions that currently have limited assurance requirements, those which seek to phase in limited assurance and those which seek to phase in reasonable assurance. See Table 5.5 for data.
Table 5.1. Sustainability-related disclosure
Copy link to Table 5.1. Sustainability-related disclosure|
Jurisdiction |
Sustainability-related disclosure |
Disclosure standards1 |
Coverage of companies |
Is the approval process for sustainability disclosure the same as for financial disclosure? |
Phasing in implementation |
Primary users of the sustainability-related disclosure |
Key source(s) |
|
|---|---|---|---|---|---|---|---|---|
|
Listed companies only/Listed and non‑listed companies |
Flexibility for smaller listed companies2 |
|||||||
|
Argentina |
L, C |
- |
Listed companies only |
Yes |
No |
- |
Multiple stakeholders |
|
|
Australia |
L |
Local standards (based on IFRS Sustainability Standards) |
Listed and non-listed companies |
Yes |
Yes |
2025-2028 |
Investors |
Corporations Act 2001 Part 2M.3 |
|
Austria |
L |
- |
Listed and non‑listed companies |
Yes |
- |
- |
- |
|
|
Belgium |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Code of companies and associations Law 2 2024 (CSRD transposed) |
|
Brazil |
L, C5 |
IFRS Sustainability Standards |
Listed companies only / Listed and non-listed companies |
No |
No / Yes |
2024 to 2026 voluntary / mandatory as of 2026 |
Multiple stakeholders |
|
|
Bulgaria |
L, R, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Independent Financial Audit and Assurance of Sustainability Reporting Act (CSRD transposed) |
|
Canada |
C |
Local standards (based on IFRS Sustainability Standards6) |
Listed companies |
Yes |
- |
- |
Multiple stakeholders |
National Instruments 51-102 and 58-101 Canadian Securities Administrators Staff Notice 51-333, 51-358, 51-354 |
|
Chile |
L |
Local standards (based on GRI, TCFD, Integrated Reporting, SASB metrics and IFRS Sustainability Standards7) |
Listed companies and other entities supervised by CMF |
Yes |
Yes |
2026 |
Investors |
General Rule (GR) No. 30, amended by GR No. 461 and No. 519 of CMF |
|
China8 |
R, C |
Local |
Listed and non‑listed companies |
No |
No |
2026 |
Multiple stakeholders |
Guidelines No. 14 of Shanghai Stock Exchange for Self-Regulation of Listed Companies—Sustainability Report (Trial) Self-Regulatory Guidelines No. 17 for Companies Listed on Shenzhen Stock Exchange—Sustainability Report (For Trial Implementation) Corporate Sustainability Disclosure Standards—Basic Standards (Trial) |
|
Colombia |
L |
TCFD, SASB |
Listed companies only |
Yes |
Yes |
- |
Investors |
|
|
Costa Rica |
C |
GRI, IR, SASB, TCFD |
Listed companies only |
No |
- |
- |
Investors |
Voluntary Guidelines to disclose ESG information for issuing companies |
|
Croatia |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Accounting Act (CSRD transposed) |
|
Czechia |
L |
ESRS |
Listed and non-listed companies9 |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
(CSRD transposed) |
|
Denmark |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
(CSRD transposed) |
|
Estonia |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Accounting Act § 24(6) (CSRD transposed) |
|
Finland |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
(CSRD transposed) |
|
France |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
- |
Multiple stakeholders |
Article L225-102-1 of the Commercial Code (CSRD transposed) |
|
Germany |
L, C |
Local |
Listed companies only |
Yes |
Yes |
- |
Investors |
German Commercial Code (Section 289b to 289e) |
|
Greece |
L, L, L, L, C, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Law 5164/2024 (CSRD transposed) |
|
Hong Kong (China)10 |
R |
Local |
Listed companies only |
No |
No |
- |
- |
Main Board: Environmental, Social and Governance Reporting Guide GEM Board: Environmental, Social and Governance Reporting Guide |
|
Hungary |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
|
|
Iceland |
L, C |
- |
Listed and non-listed companies |
No |
Yes |
- |
- |
Act on annual accounts, Art. 66d ESG Reporting Guide 2.0 |
|
India |
L |
Local |
Listed companies only11 |
Yes |
No |
- |
Multiple stakeholders |
Listing Obligations and Disclosure Requirements Regulations, 2015 Circular on Business Responsibility and Sustainability Reporting (BRSR) by listed entities |
|
Indonesia |
L |
- |
Listed and non-listed companies |
No |
No |
2019-202512 |
Multiple stakeholders |
OJK Regulation Number 51/POJK.03/2017 and |
|
Ireland |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Corporate Sustainability Reporting Regulations 2024 c (CSRD transposed) |
|
Israel |
L, C |
‑13 |
Listed companies only |
No |
Yes |
- |
Multiple stakeholders |
|
|
Italy |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Legislative Decree No. 125/ 2024 (CSRD transposed) |
|
Japan14 |
L, C |
Local standards (based on TCFD, IFRS Sustainability Standards) |
Listed and some non-listed companies |
No |
Yes |
- |
- |
|
|
Korea15 |
C |
- |
Listed companies only |
No |
No |
2026 |
- |
|
|
Latvia |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Financial instruments market law and Law on Governance of Capital Shares of a Public Person and Capital Companies Law on Sustainability Disclosure (CSRD transposed) |
|
Lithuania |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
The Law on Reporting by Undertakings and by Groups of Undertakings of the Republic of Lithuania (CSRD transposed) |
|
Luxembourg |
L, C |
ESRS |
Listed companies only |
No |
Yes |
- |
Multiple stakeholders |
The X Principles of Corporate Governance (X Principles) of the Luxembourg Stock. Exchange |
|
Malaysia |
R |
IFRS Sustainability Standards |
Listed and non-listed companies16 |
Yes |
Yes |
2025 |
Investors |
Practice Note 9 and Practice Note 9A of the Main Market Listing Requirements Guidance Note 11 and Guidance Note 11A of the ACE Market Listing Requirements |
|
Mexico |
L |
IFRS Sustainability Standards |
Non-Financial Listed companies only |
- |
2026 |
Multiple stakeholders |
Regulatory amendment to the issuer’s provisions related to sustainability reporting17 |
|
|
Netherlands |
L, C |
ESRS |
Large listed companies only |
No |
No |
- |
- |
|
|
New Zealand |
L, R |
Local standards (based on TCFD) |
Listed and non-listed companies18 |
No |
Yes |
- |
Investors |
|
|
Norway19 |
L |
ESRS Local |
Listed and non-listed companies |
Yes |
Yes |
2025-2029 |
Multiple stakeholders |
|
|
Peru |
L |
Local |
Listed companies only |
Yes |
Yes20 |
- |
Investors |
Resolution 18/2020-SMV/02 on Corporate Sustainability Report |
|
Poland |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Act of 6 December 2024 amending the Accounting Act Best Practice for GPW Listed Companies 2021 (CSRD transposed) |
|
Portugal |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
- |
Multiple stakeholders |
|
|
Romania |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Ministry of Finance Orders (Order No. 1802/2014 and No. 2844/2016) (CSRD transposed) |
|
Saudi Arabia |
C |
Local |
Listed companies only |
Yes |
Yes |
- |
Investors |
|
|
Singapore |
R |
IFRS Sustainability Standards (for climate reporting) |
Listed companies only |
Yes |
Yes |
2026 202721 |
Multiple stakeholders |
|
|
Slovak Republic |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Measure of the Ministry of Finance of the Slovak Republic No. MF/009347/2024-74 Act No. 105/2024 (CSRD transposed) |
|
Slovenia |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Act Amending and Supplementing the Auditing Act Act Amending and Supplementing the Companies Act Act Amending and Supplementing the Market in Financial Instruments Act Companies Act |
|
South Africa |
R, C |
- |
Listed companies only |
No |
-22 |
- |
- |
|
|
Spain |
L |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
|
|
Sweden |
L, C |
ESRS |
Listed and non-listed companies |
Yes |
Yes |
2025-20293 |
Multiple stakeholders |
Public: The Annual Accounts Act Private: The Swedish Corporate Governance Code (CSRD transposed) |
|
Switzerland |
L |
- |
Listed and non-listed companies |
Yes |
Yes |
- |
- |
|
|
L, C |
Local standards (based on IFRS Sustainability Standards) |
Listed companies (C) Listed companies and financial market institutions (L) |
Yes |
Yes |
2024 |
Multiple stakeholders |
||
|
United Kingdom |
R, L |
TCFD |
No |
Yes |
- |
- |
FCA’s Climate related Disclosure Regime: UK Listing Rules UKLR 6.6.6(8), UKLR 14.3.24, UKLR 16.3.23 and UKLR 22.2.24 |
|
|
United States |
- |
- |
SEC-registered public companies |
Yes |
- |
- |
- |
|
Key: L = requirement by the law or regulations; R = requirement by the listing rules; C = recommendation by the codes or principles, including frameworks set by the regulator or stock exchange following a “comply or explain” approach; “-” = absence of a specific requirement or recommendation.
1. In “Disclosure standard”, jurisdictions that require or recommend companies to follow any disclosure standard, therefore providing flexibility for companies to choose the specific standard to be used, are indicated as “-” in the column.
2. “Flexibility for listed smaller companies” refers to the existence of different requirements for listed companies according to their size, which may be assessed in different forms such as total assets, number of employees or market capitalisation. Jurisdictions that have a phase‑in period for sustainability‑related disclosure requirements based on the companies’ size are not considered to have “flexibility” in this table if, at the end of the phase‑in period, all requirements apply equally to all listed companies. While the adoption of a “comply or explain” system does allow flexibility for smaller companies not to comply with a recommendation, the adoption of such a system is not considered to allow “flexibility” in this table if all listed companies – without exceptions to smaller companies – need to report on their compliance. Finally, while it is acknowledged that some regulatory frameworks adopt flexible requirements for smaller non-listed companies, only flexibility for listed companies is considered in the column “Flexibility for listed smaller companies”.
3. The EU’s 2022 Corporate Sustainability Reporting Directive (CSRD) generated some important changes in EU member countries’ regulatory frameworks. One of the most relevant innovations brought by the CSRD is that companies subject to the Directive have to disclose sustainability‑related information according to the EU Sustainability Reporting Standards (ESRS).The application of the Directive takes place in four stages: (i) reporting in 2025 for companies already subject to the NFRD; (ii) reporting in 2026 for large companies that are not currently subject to the NFRD; (iii) reporting in 2027 for listed small and medium enterprises; and (iv) reporting in 2029 for third-country undertakings with net turnover above EUR 150 million in the European Union if they have at least one subsidiary or branch in the EU exceeding certain thresholds. As of the end of December 2024, some EU member states had transposed CSRD into their respective laws which is reflected in Table 5.1 under “key sources(s)” as “(CSRD transposed)”. It is also important to note that in February 2025, the European Commission proposed the EU Omnibus Package which, among other areas, aims to streamline corporate sustainability reporting to boost Europe’s competitiveness.
Note: In June 2023, the International Sustainability Standards Board (ISSB) issued its first two IFRS Sustainability Disclosure Standards, IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures. IFRS S1 provides a set of disclosure requirements designed to enable companies to communicate to investors about the sustainability-related risks and opportunities they face over the short, medium and long term. IFRS S2 sets out specific climate-related disclosures and is designed to be used with IFRS S1. Both fully incorporate the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). Some jurisdictions are creating their own local sustainability reporting standards with some changes but they are mainly based on IFRS Sustainability Standards as reflected in Table 5.1.
4. In Argentina, the national corporate governance code briefly mentions the need for the company to disclose sustainability information on its website, as well as to provide relevant corporate social responsibility information to its shareholders. Companies must include in their annual reports information about their environmental or sustainability policies. Finally, public offering rules establish that prospectuses must include a description of the company’s environmental or sustainability policies and, if the company does not have such policies, it must provide an explanation why.
5. In Brazil, there is a recommendation for companies to disclose climate‑related risks according to TCFD recommendations. Companies need to explain in case they prefer to use another standard. However, disclosure on some sustainability issues, such as the workforce composition according to gender and race, is binding.
6. In Canada, the Canadian Sustainability Standards Board (CSSB) standards are voluntary until mandated by provincial and territorial regulators.
7. In Chile, General Rule No. 30 aligns with international standards, requiring the reporting of SASB indicators and, from 2026, the adoption of IFRS S1 and S2. Implementation began in 2022 with the largest entities and will conclude with the 2026 Annual Reports, when IFRS S1 and S2 become mandatory. The rule was updated in 2024 to include these ISSB requirements and introduce flexibility for smaller entities. Specifically, entities with average consolidated assets below 1 000 000 inflation-indexed units (approx. USD 39 million) over the past two years are exempt from preparing an Integrated Annual Report and may submit a Simplified Annual Report instead, though voluntary adoption of the full standard is permitted.
8. In China, both the listing rules of the stock exchanges and the codes of the Ministry of Finance have provisions regarding sustainability-related disclosure. The listing rules are applicable to listed companies, whereas the codes apply to all enterprises. Consequently, some cells in Table 5.1, Table 5.2 and Table 5.3 include multiple inputs. In such cases, the former denotes the listing rules, and the latter denotes the codes. In China, the standards of the listing rules are local standards with no direct alignment with international frameworks, while the standards (trial) of the code are based on IFRS Sustainability Standards.
9. In Czechia, only large listed companies over 500 employees and large banks and insurers are covered in the first phase.
10. In Hong Kong (China), there is no flexibility for smaller listed issuers under the current regime. However, the Main Board and GEM Board ESG reporting guides were revised and issued as Environmental, Social and Governance Reporting Code with effect from 1 January 2025 (Main Board: Environmental, Social and Governance Reporting Code and GEM Board: Environmental, Social and Governance Reporting Code). The Environmental, Social and Governance Reporting Code contains new climate disclosure requirements developed based on IFRS S2 Climate-related Disclosures and are implemented in phases: (1) all Main Board issuers will disclose on a “comply or explain” basis from 1 January 2025; (2) large-cap issuers will disclose on a mandatory basis from 1 January 2026; and (3) GEM issuers may disclose voluntarily. A phased approach is adopted for the implementation of the new climate requirements.
11. In India, the sustainability‑related disclosure requirement applies to the top 1000 listed entities by market capitalisation.
12. In Indonesia, reporting periods are set as follows: 2019 for larger commercial banks (BUKU 3, BUKU 4) and foreign banks; 2020 for smaller commercial banks (BUKU 1, BUKU 2), various financing, insurance and public companies; 2022 for larger financial services institutions (BPRKU 3), rural banks (BPRS) with equivalent core capital, securities companies administering customer accounts and medium-scale issuer companies; 2024 for smaller financial services institutions (BPRKU 1, BPRKU 2), corresponding BPRS, small-scale issuer companies, certain securities, mortgage and securitisation companies; and 2025 for pension fund companies with at least IDR 1 trillion in assets.
13. In Israel, the Israel Securities Authority recommends that reporting corporations that choose to publish an annual CSR report draft the report in accordance with generally accepted international standards.
14. In Japan, the Sustainability Standards Board of Japan (SSBJ) finalised its sustainability disclosure standards, which are functionally aligned with the ISSB, in March 2025. The Financial Services Agency (FSA) plans to make these standards mandatory through a phased approach, starting from fiscal years beginning April 2026 with companies listed on the Prime Market and a market capitalisation of JPY 3 trillion or more. In Japan, all listed companies are recommended to develop a basic policy and disclose initiatives on the company’s sustainability. However, companies listed on the Prime Market should also enhance the quality and quantity of climate‑related disclosure based on TCFD recommendations or equivalent international frameworks.
15. In Korea, KOSPI-listed companies with total assets over KRW 500 billion must disclose a corporate governance report. From 2026, this requirement will extend to all KOSPI-listed companies. The report must state whether the company complies with key principles of the Korea Institute of Corporate Governance and Sustainability’s Code of Best Practices, which includes sustainability-related recommendations, and explain any non-compliance. The KOSPI index comprises Korea’s largest companies by capitalisation. The Korean Sustainability Standards Board (KSSB) are developing the local disclosure standards based on the ISSB standards. However, the KSSB standards are currently only in the draft stage, therefore, listed companies in Korea are voluntarily disclosing sustainability information to the Korea Exchange by referencing various international standards including ISSB, TCFD, SASB and GRI.
16. In Malaysia, non-listed companies (NLCos) with annual revenue of MYR 2 billion and above. The threshold is calculated based on consolidated group revenue of MYR 2 billion or more for two consecutive financial years preceding the current financial year. The disclosure requirements for NLCos will take effect from 1 January 2027 and will be mandated through amendments of relevant legislation. In Malaysia, under the new requirement, listed issuers on the Main Market with market capitalisation of below MYR 2 billion, as well as those listed on the ACE Market are provided with a longer period to comply with the new reporting requirements (i.e. 2026 and 2027 respectively).
17. In Mexico, public offer prospectuses and annual reports must include relevant sustainability information, particularly on environmental matters. Disclosures must cover climate risks, the impact of environmental laws and related policies or certifications. Annual reports must also include social data such as unionised and temporary workers. From 2026, non-financial issuers must submit a Sustainability Report aligned with ISSB standards, covering 2025. Foreign issuers may report under IFRS S1 and S2 or their home country’s applicable regulations. The regulatory amendments were published in the Federal Gazette on January 28, 2025, following public consultation.
18. In New Zealand, large financial markets participants are required to undertake climate reporting. This is set out in Part 7A of the Financial Markets Conduct Act 2013. Likewise, large listed issuers must produce climate reports (see Section 461P of the Financial Markets Conduct Act 2013).
19. In Norway, in addition to the Accounting Act, an Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions was enacted in 2021. The Act applies to larger enterprises that are resident in Norway and that offer goods and services in or outside Norway. The Act also applies to larger foreign enterprises that offer goods and services in Norway, and that are liable to pay taxes in the country. For the purposes of this Act, larger enterprises mean enterprises that exceed two out of three thresholds, including one for sales revenues (NOK 35 million) and another one for the average number of employees (50 full-time equivalent). Parent companies shall be considered larger enterprises if the conditions are met for the parent company and subsidiaries as a whole. As such, the Act is not limited to listed companies only. Further, Norway’s implementation of the EU Corporate Sustainability Reporting Directive (CSRD) follows a phased approach, with the first reports due in 2025. These initial disclosures apply to large public-interest entities—such as listed companies, banks and insurance firms—with more than 500 employees, based on their fiscal year 2024 data. In 2026, the reporting obligation extends to all large companies that meet at least two of the following criteria: more than 250 employees, a balance sheet total exceeding NOK 290 million, or net turnover above NOK 580 million, based on fiscal year 2025. By 2027, listed small and medium-sized enterprises (SMEs), small and non-complex credit institutions, and captive insurance undertakings will be required to report based on their 2026 fiscal year. However, listed SMEs have the option to defer reporting until 2029, based on fiscal year 2028.
20. In Peru, the Corporate Sustainability Report (CSR) is an annex to the Annual Report that issuers must submit during the first quarter of each year, along with their audited financial statements. In this regard, the approval of the audited financial statements and the Annual Report (which includes the CSR and the Report on Compliance with the Code of Good Corporate Governance for Peruvian Corporations as annexes) is carried out at the General Shareholders' Meeting, which companies are required by law to hold within three months of the end of the fiscal year.
21. In Singapore, the Listing Rules require all issuers to start reporting Scope 1 and Scope 2 greenhouse gas (GHG) emissions beginning with FY 2025 with first disclosures due in 2026. Their climate-related disclosures must also start to incorporate the climate-related requirements in the IFRS Sustainability Disclosure Standards. SGX RegCo will review issuers’ experience and readiness before establishing the implementation roadmap for reporting Scope 3 GHG emissions. The current plan is to prioritise larger issuers by market capitalisation with the intention that they report Scope 3 GHG emissions from FY 2026 with first disclosures due in 2027.
22. In South Africa, the King Code on Corporate Governance provides that the governing body should oversee reports such as sustainability reports on an “apply or explain” basis.
23. In Türkiye, the “IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information” and “IFRS S2 Climate-related Disclosures” standards published by ISSB were translated into Turkish by the KGK (Public Oversight Accounting and Auditing Standards Authority) as “TSRS 1 Provisions on Disclosure of Sustainability-related Financial Information” and “TSRS 2 Climate-related Disclosures” and these standards came into force upon publication in the Official Gazette dated 29.12.2023 / numbered 32414. In Türkiye, listed companies on the Sub Market, Main Market and Star Market are subject to the Capital Markets Board’s (CMB) Sustainability Principles Compliance Framework, effective from 2020 Annual Reports. Disclosures follow a voluntary “comply or explain” approach, requiring companies to state whether they comply and, if not, why. Separately, in December 2023, the Public Oversight Authority (KGK) issued the Turkish Sustainability Reporting Standards (TSRS), aligned with ISSB standards. From reporting periods starting 1 January 2024, listed companies and financial institutions must apply TSRS if they exceed two of the following in two consecutive years: TRY 500 million in assets, TRY 1 billion in net sales or 250 employees. Banks are included regardless of thresholds.
24. In the United Kingdom, coverage applies to listed equity issuers as well as certain UK registered companies and Limited Liability Partnerships (LLPs).
25. In the United States, Regulation S-K sets forth requirements for disclosure under both the Securities Act and the Exchange Act and is applicable to both public offerings and ongoing reporting requirements. On 4 April 2024, the U.S. Securities and Exchange Commission (SEC) issued an order staying the climate-related disclosure rules it adopted on 6 March 2024. As a result, the effective date of those rules is stayed pending judicial review of the rulemaking.
Table 5.2. Sustainability disclosure content coverage
Copy link to Table 5.2. Sustainability disclosure content coverage|
Jurisdiction |
Disclosure of metrics for sustainability-related goals |
Transition planning |
Value chain information |
Sustainability matters |
|---|---|---|---|---|
|
Argentina |
- |
- |
- |
- |
|
Australia |
L |
L |
L |
- |
|
Austria |
C |
- |
- |
- |
|
Belgium |
L |
L |
L |
All material sustainability matters |
|
Brazil |
L |
L |
L |
All material sustainability matters |
|
Bulgaria |
L |
L |
L |
All material sustainability matters |
|
Canada |
C1 |
- |
C1 |
All material sustainability matters |
|
Chile |
L |
L |
L |
All material sustainability matters |
|
China |
R, C |
R, C |
R |
All material sustainability matters |
|
Colombia |
L |
- |
- |
All material sustainability matters |
|
Costa Rica |
C |
- |
- |
All material sustainability matters |
|
Croatia |
L |
L |
L |
All material sustainability matters |
|
Czechia |
L |
L |
L |
All material sustainability matters |
|
Denmark |
L |
L, C |
L |
All material sustainability matters |
|
Estonia |
L |
L |
L |
All material sustainability matters |
|
Finland |
L |
L |
L |
All material sustainability matters |
|
France |
L |
L |
L |
All material sustainability matters |
|
Germany |
- |
- |
- |
- |
|
Greece |
L, C |
L |
L |
All material sustainability matters |
|
Hong Kong (China) |
C2 |
- |
- |
All material sustainability matters |
|
Hungary |
L |
L |
L |
All material sustainability matters |
|
Iceland |
L, C |
PC |
C |
All material sustainability matters |
|
India |
L |
- |
L |
All material sustainability matters |
|
Indonesia |
- |
- |
- |
- |
|
Ireland |
L |
L |
L |
All material sustainability matters |
|
Israel |
- |
- |
- |
All material sustainability matters |
|
Italy |
L |
L |
L |
All material sustainability matters |
|
Japan |
L |
PC |
-3 |
All material sustainability matters |
|
Korea |
- |
PC |
C |
All material sustainability matters |
|
Latvia |
L |
L |
L |
All material sustainability matters |
|
Lithuania |
L |
L |
L |
All material sustainability matters |
|
Luxembourg |
L |
L |
L |
All material sustainability matters |
|
Malaysia |
R |
- |
- |
All material sustainability matters4 |
|
Mexico5 |
L |
L |
L |
All material sustainability matters |
|
Netherlands |
- |
PC |
PC |
All material sustainability matters |
|
New Zealand |
L |
L |
L |
Only climate-related matters |
|
Norway |
L |
L |
L |
All material sustainability matters |
|
Peru |
L |
- |
L |
All material sustainability matters |
|
Poland |
L |
L |
L |
All material sustainability matters |
|
Portugal |
L |
L |
L |
All material sustainability matters |
|
Romania |
L |
L |
L |
All material sustainability matters |
|
Saudi Arabia |
- |
- |
- |
All material sustainability matters |
|
Singapore6 |
R |
- |
R |
All material sustainability matters |
|
Slovak Republic |
L, C |
L |
L |
All material sustainability matters |
|
Slovenia |
L |
L |
L |
All material sustainability matters |
|
South Africa |
C |
- |
- |
All material sustainability matters |
|
Spain |
L |
L |
L |
All material sustainability matters |
|
Sweden |
L |
L |
L |
All material sustainability matters |
|
Switzerland |
L |
L |
L |
All material sustainability matters |
|
Türkiye7 |
L, C |
L, C |
L, C |
All material sustainability matters |
|
United Kingdom |
L, R |
PC |
- |
Only climate-related matters8 |
|
United States |
- |
- |
- |
- |
Key: PC = public consultation or under active consideration; L = requirement by the law or regulations; R = requirement by the listing rule; C = recommendation by the codes or principles; "-" = absence of a specific requirement or recommendation.
Note: The EU’s CSRD and the ESRS require the disclosure of transition plans, value chain information and all material sustainability matters. However, as of the end of December 2024, some EU member states had not transposed CSRD into their respective national laws which may reflect the differences across EU members in Table 5.2.
1. In Canada, the CSSB standards are voluntary until mandated by provincial and territorial regulators.
2. In Hong Kong (China), listed issuers have been required to disclose certain sustainability metrics on a “comply-or-explain” basis in accordance with the Environmental, Social and Governance reporting guides. Effective 1 January 2025, listed issuers are required to disclose certain climate-related information such as their climate-related metrics and targets, transition plans and effects of climate-related risks and opportunities on value chain pursuant to the Environmental, Social and Governance Reporting Code (see footnote 10 under Table 5.1 for further information on the phased implementation of the new climate disclosure requirements).
3. In Japan, the SSBJ finalised its sustainability disclosure standards, which require the disclosure of sustainability information related to the value chain, in March 2025.
4. In Malaysia, the National Sustainability Reporting Framework (NSRF) adopts a phased approach, allowing in-scope companies to begin with climate-related disclosures (IFRS S2) and focus on principal business segments for 2–3 years. Additional time is provided for complex areas like Scope 3 emissions under NSRF. Large Main Market issuers (market cap ≥ MYR 2 billion) start reporting from January 2025, followed by other Main Market issuers in 2026, and ACE Market issuers and large NLCOs in 2027. However, the Listing Requirements for Main Market and ACE Market have been updated since December 2024 to align with the NSRF/ISSB requirements. The requirement for ACE Market listed issuers to produce a basic plan to transition towards a low carbon economy has been removed.
5. In Mexico, the Issuers’ Provisions will require an annual Sustainability Report aligned with ISSB standards, covering metrics, transition plans, value chain data (including Scope 3 GHG), and other relevant sustainability matters. The amendments were published in the Federal Gazette on 28 January 2025, following public consultation.
6. In Singapore, sustainability reports must disclose material sustainability matters on a ‘comply or explain’ basis. Climate-related disclosures will be mandatory from FY 2025 with disclosures due in 2026, with all other key components required from FY 2026 with disclosures due in 2027. In March 2024, SGX RegCo encouraged issuers to consider transition plans, though these are not yet mandated.
7. In Türkiye, listed companies on the Sub, Main and Star Markets must disclose against the CMB’s Sustainability Principles Compliance Framework on a “comply or explain” basis, effective from 2020 Annual Reports.
8. In the United Kingdom, in addition to TCFD-related reporting, certain entities are also required to disclose information on environmental matters (including the impact of the company’s business on the environment), the company’s employees, and social, community and human rights issues.
Table 5.3. Corporate sustainability governance
Copy link to Table 5.3. Corporate sustainability governance|
Jurisdiction |
Board responsibilities for sustainability-related policies |
Key resources for board responsibilities for sustainability-related policies |
Disclosure of lobbying activities |
Disclosure of political donations |
Board oversight of lobbying activities and/or political donations |
|
|---|---|---|---|---|---|---|
|
Argentina |
- |
- |
- |
- |
- |
|
|
Australia1 |
- |
- |
L, R |
L |
L |
|
|
Austria |
L |
Section 243b and Section 267b Austrian Commercial Code; Section 96 and Section 258 Stock Corporation Act; |
- |
- |
- |
|
|
Belgium |
L |
C |
C |
- |
||
|
Brazil |
- |
- |
- |
- |
- |
|
|
Bulgaria |
L |
Accountancy Act, Public Offering of Securities Act |
C |
C |
L |
|
|
Canada2 |
- |
- |
L |
L |
- |
|
|
Chile3 |
- |
- |
- |
- |
- |
|
|
China |
R, C |
Corporate Sustainability Disclosure Standards—Basic Standards (Trial) |
- |
- |
- |
|
|
Colombia |
C4 |
Sustainable Finance Website |
- |
- |
- |
|
|
Costa Rica |
- |
- |
- |
- |
- |
|
|
Croatia |
- |
- |
C |
C |
- |
|
|
Czechia |
- |
- |
C |
C |
- |
|
|
Denmark |
L, C |
L, C |
L, C |
L, C |
||
|
Estonia |
L |
Accounting Act § 24(6) |
C |
C |
- |
|
|
Finland |
‑5 |
- |
L, C |
C |
L |
|
|
France |
L |
C |
C |
- |
||
|
Germany |
C |
- German Corporate Governance Code |
L |
L |
L |
|
|
Greece |
L |
L, C |
L, C |
- |
||
|
Hong Kong (China) |
R |
Environmental, Social and Governance Reporting Guide (effective up to 31 Dec 2024): (Part A, paragraphs 10 and 13 of Appendix C2 to the Main Board Listing Rules / Appendix C2 of the GEM Listing Rules) Implementation Guidance for Climate Disclosures under HKEX ESG Reporting Framework |
- |
- |
- |
|
|
Hungary |
L |
Section 23 of Act CVIII of 2023 (ESG Act) |
C |
C |
- |
|
|
Iceland |
L, C |
- |
- |
- |
||
|
India6 |
L |
- |
L |
L |
L |
|
|
Indonesia |
L7 |
- |
- |
- |
- |
|
|
Ireland |
L8 |
- |
- |
- |
||
|
Israel |
- |
- |
- |
L9 |
- |
|
|
Italy |
C |
L, C |
L, C |
-10 |
||
|
Japan |
C |
- |
- |
- |
||
|
Korea |
C |
C |
- |
- |
||
|
Latvia |
C |
C |
- |
|||
|
Lithuania |
- |
- |
C |
C |
- |
|
|
Luxembourg |
L, C |
The X Principles of Corporate Governance (X Principles) of the Luxembourg Stock. Exchange |
- |
- |
- |
|
|
Malaysia |
Malaysian Code on Corporate Governance, Practice 4.1 |
- |
- |
- |
||
|
Mexico |
- |
- |
- |
- |
- |
|
|
Netherlands |
C |
- |
- |
- |
||
|
New Zealand |
C |
- |
L |
- |
||
|
Norway |
- |
- |
- |
|||
|
Peru14 |
- |
- |
- |
- |
- |
|
|
Poland |
L |
Act on Statutory Auditors, Audit Firms and Public Supervision |
L, C |
L, C |
- |
|
|
Portugal |
- |
- |
- |
- |
||
|
Romania |
L, C |
L, C |
- |
|||
|
Saudi Arabia |
C |
ESG Guidelines Page 13 |
- |
- |
- |
|
|
Singapore |
- |
- |
- |
|||
|
Slovak Republic |
L |
L, C |
L, C |
L |
||
|
Slovenia |
C |
C |
C |
- |
||
|
South Africa |
- |
- |
- |
- |
||
|
Spain |
L |
- |
- |
- |
||
|
Sweden |
R |
CSRD standards |
L, C |
L, C |
L |
|
|
Switzerland |
L |
- |
- |
- |
||
|
Türkiye |
C |
- |
- |
- |
||
|
United Kingdom |
- |
- |
- |
L |
- |
|
|
United States |
- |
- |
- |
- |
- |
|
Key: L = requirement by the law or regulations; R = requirement by the listing rules; C = recommendation by the codes or principles; “-” = absence of a specific requirement or recommendation.
Note: The European Sustainability Reporting Standards (ESRS) are the EU’s mandatory framework for sustainability reporting under the CSRD. They consist of cross-cutting standards, which apply to all companies, and topical standards, which are subject to a company’s double materiality assessment. One topical standard, ESRS G1 (Business Conduct), includes disclosures on lobbying activities, political donations and board oversight of these areas. Companies are only required to report against ESRS G1 if these topics are deemed material. If they are not considered material, reporting is not required—though companies must still disclose the outcome and process of their materiality assessment. Therefore, in Table 5.3, “C” has been entered in the columns for “disclosure of lobbying activities,” and “disclosure of political donations” for countries that had transposed the CSRD by December 2024. In the EU, the European Directive on Corporate Sustainability Due Diligence imposes a duty on very large companies to identify and address adverse human rights and environmental impacts in their own operations, those of their subsidiaries and, with some limitations, in their value chains. In addition to sustainability due diligence, the Directive also requires companies to adopt a transition plan for climate change mitigation. EU Member States will need to transpose the Directive, i.e. bring their national laws in line its requirements, by July 2027 but, depending on their size, companies will have additional time to comply with it.
1. In Australia, companies must disclose lobbying activities done on behalf of third parties. Companies must also disclose political donations above the disclosure threshold ($16,900) to the Australian Electoral Commission, which maintains a public register of donations. Directors’ duties under the Corporations Act 2001 and common law are a source of board responsibility for compliance with these disclosure obligations.
2. In Canada, the fiduciary duty in Section 122 of the Canada Corporations Act permits boards to consider non-shareholder interests in their decision-making. The Canada Lobbying Act regulates the lobbying of public office holders.
3. In Chile, current legislation establishes that legal persons are not allowed to make donations to parties or campaigns, whereas the Lobby Law requires respective officials targeted by these actions (“passive subjects”) to report lobbying activities.
4. In Colombia, the Financial Superintendency has outlined industry-specific expectations regarding the incorporation of ESG factors in the Governance, Strategy, Risk Management and Disclosure policies and processes.
5. In Finland, the board is not explicitly required or recommended to approve policies on sustainability‑related matters. However, it is indirectly expressed already in the travaux preparatoires of the Finnish Limited Liability Companies Act (Government Bill 109/2005, p. 39) that generating profits for the company in the long term and maximising the value of the share often require that the company complies with societally acceptable conduct even where the law does not compel such conduct. That said, the matter of complying with the applicable ESG standards can be considered to have an effect on the public image and thereby profitability of a given company, and consequently it is advisable for the management of a company to take into account such standards, where relevant.
6. In India, Section 182 of Companies Act, 2013 (Companies Act) enables an Indian company to contribute to any political party. The conditions are that the contribution should (i) be authorised by the Board; (ii) not be made in cash; and (iii) be disclosed in the Company’s P&L account. Principle 7 of the BRSR Core sets disclosure requirement, stating that “Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent.”
7. In Indonesia, OJK Regulations (OJK Regulation Number 51/POJK.03/2017, OJK Regulation Number 29/POJK.04/2016, SEOJK 16/2021) require issuers’ sustainability reports to include a statement from the board of directors about sustainability strategies and policies for responding to challenges of implementing company sustainability.
8. In Ireland, the Corporate Sustainability Reporting Directive (EU) 2022/2464 amends the Companies Act 2014 and requires that directors describe the company’s policies in relation to sustainability matters in the annual report (Companies Act 2014 Section 1590(2)(d)).
9. In Israel, under disclosure regulations, listed companies are required to disclose their donation policies. However, these regulations do not explicitly cover political donations.
10. In Italy, Law 231/2001 requires companies to adopt a model to prevent crimes, including corruption. Within this model, companies should also consider the risks of crimes that could arise from lobbying activities.
11. In Latvia, while not explicitly required, board approval of sustainability-related policies is implied under the Accounting Law and the Sustainability Disclosure Law. The Sustainability Disclosure Law (Article 4, Paragraph 2) requires certain companies to include a sustainability report as part of their annual statement. Under the Accounting Law (Article 31, Paragraph 2, Clause 1 and Article 1, Paragraph 1, Clause 5), the head of the company must issue and ensure compliance with accounting organisation documents, which define procedures for maintaining accounting records, preparing and handling source documents, conducting inventories, and preparing annual and other financial statements.
12. In Malaysia, Practice 4.1 of the Malaysian Code on Corporate Governance recommends that the board together with management take responsibility for the setting of a listed issuer’s sustainability strategies, priorities and targets. The board should also take into account sustainability considerations when exercising its duties, including the development and implementation of company strategies, business plans, major plans of action, and risk management.
13. In Norway, the Norwegian Code of Practice for Corporate Governance applies to companies listed on regulated markets while the provisions on Human Rights under the Transparency Act apply to larger enterprises that are resident in Norway and that offer goods and services in or outside Norway.
14. In Peru, company directors and executives must consider risk management, environmental impact and climate change in their roles. Issuers must disclose in their Corporate Sustainability Report whether they have board-approved environmental policies or management systems, including risk and impact assessments; labour and human rights policies; stakeholder risk plans; third-party certifications or reports on GHG emissions and water footprint; and whether annual evaluations of these policies are conducted and reported to the board. Although there is no explicit recommendation at the level of law or code, if an issuer receives political donations and these qualify as a relevant fact, in accordance with the Relevant Facts and Reserved Information Regulation, approved by Resolution SMV No. 005-2014, the issuer is obliged to inform and disclose said event to the market as soon as such event occurs or the issuer becomes aware of it, and in no case beyond the day on which it occurred or was known.
15. In Portugal, Board Members are obliged to observe “duties of loyalty, in the interest of the company, considering shareholders’ long-term interests and weighing the interests of other stakeholders relevant for the sustainability of the company, such as its employees, customers, and creditors” (Article 64/1/b of the Portuguese Companies Code). Board Members are also responsible for the information disclosed in the non-financial disclosure, which contains information on sustainability policies.
16. In Romania, under the BVB Corporate Governance Code, companies must have an internal control and risk management framework aligned with their strategy, size and risk profile, including environmental and social impacts. The Board should define the risk appetite and ensure policies for identifying, managing and monitoring key risks, including sustainability and cybersecurity. Additionally, sustainability must be integrated into strategy and operations, with oversight from the Board and a dedicated committee to address environmental and social impacts.
17. In Singapore, the Listing Rules require issuers’ sustainability reports to include a statement from the Board that it has considered sustainability issues in the issuer’s business and strategy, determined the material ESG factors, and overseen the management and monitoring of the material ESG issues. The Listing Rules also require issues to provide a description of the governance structure for sustainability practices in their sustainability reports.
18. In South Africa, the Companies Act and its regulations require a listed public company to have a Social and Ethics Committee comprising at least three directors, one of which must be independent. The Social and Ethics Committee must report to the Board and shareholders at the Annual General Meeting. The Committee is responsible for monitoring the company's activities regarding social and economic development (including environmental considerations), good corporate citizenship, environmental, health and safety matters, consumer relationships, and labour and employment matters. Sustainability matters, policies and performance are reviewed by the Social and Ethics Committee of most listed companies. Sustainability reporting is addressed in the King IV Code, as part of the integrated reporting approach advocated by the code. The Listing requirements apply integrated reporting on a “comply or explain” basis.
Table 5.4. ESG rating agencies and index providers
Copy link to Table 5.4. ESG rating agencies and index providers|
Jurisdiction |
ESG rating agencies and index providers |
|||
|---|---|---|---|---|
|
Framework |
Disclosure of methodologies |
Management of conflicts of interest |
||
|
Setting the policy |
Disclosure of policy |
|||
|
Argentina |
No1 |
- |
- |
- |
|
Australia |
Yes (index providers only)2 |
L |
L |
L |
|
Austria |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Belgium |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Brazil |
No |
- |
- |
- |
|
Bulgaria |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Canada |
No |
- |
- |
- |
|
Chile |
No |
- |
- |
- |
|
China |
Yes (index providers only) |
- |
- |
- |
|
Colombia |
No |
- |
- |
- |
|
Costa Rica |
Yes (ESG rating providers only) |
- |
L |
L |
|
Croatia |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Czechia |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Denmark |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Estonia |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Finland |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
France |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Germany |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Greece |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Hong Kong (China) |
Yes (ESG rating providers only) |
C3 |
C |
C |
|
Hungary4 |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Iceland |
No |
- |
- |
- |
|
India5 |
Yes |
L, L |
L, L |
L, L |
|
Indonesia |
No |
- |
- |
- |
|
Ireland |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Israel |
No |
- |
- |
- |
|
Italy |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Japan |
Yes6 |
C |
C |
C |
|
Korea7 |
Yes (ESG rating providers only) |
C |
C |
C |
|
Latvia |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Lithuania |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Luxembourg |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Malaysia |
No |
- |
- |
- |
|
Mexico |
No |
- |
- |
- |
|
Netherlands |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
New Zealand |
No |
- |
- |
- |
|
Norway |
Yes (index providers only) |
L |
L |
L |
|
Peru |
No8 |
- |
- |
- |
|
Poland |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Portugal |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Romania |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Saudi Arabia |
No |
- |
- |
- |
|
Singapore9 |
Yes (ESG rating providers only) |
C |
C |
C |
|
Slovak Republic |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Slovenia |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
South Africa10 |
No |
- |
- |
- |
|
Spain |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Sweden |
Yes |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
L (index), L (ESG rating) |
|
Switzerland |
No |
- |
- |
- |
|
Türkiye |
- |
- |
- |
|
|
United Kingdom |
L (index), C (ESG rating) |
L (index), C (ESG rating) |
L (index), C (ESG rating) |
|
|
United States |
- |
- |
- |
- |
Key: L = requirement by the law or regulations; R = requirement by the listing rules; C = recommendation by the codes or principles; “-” = absence of a specific requirement or recommendation.
Note: The Benchmarks Regulation and the ESG Ratings Regulation set requirements for the disclosure of methodologies and the management of conflicts of interest which reflects “L (index), L (ESG rating)” in the last three columns of Table 5.4 for all EU member countries.
1. In Argentina, credit rating agencies that evaluate sustainable bonds are regulated and supervised by the securities regulator (CNV).
2. In Australia, the regulatory framework for index providers falls under Section 5 of the ASIC Corporations (Significant Financial Benchmarks) Instrument which includes the S&P/ASX 200 Index.
3. In Hong Kong (China), the Hong Kong Code of Conduct for ESG Ratings and Data Products Providers was published in October 2024 by an industry-led working group. SFC supported and sponsored the development of the Code for voluntary adoption by ESG ratings and data products providers offering products and services in Hong Kong.
4. In Hungary, the ESG Act (Act CVIII of 2023) regulates conflicts of interest rules, stating that “…a rating provider may not provide ESG rating services to a company or its subsidiaries if it provides ESG consultancy services to the company or subsidiaries regarding the specific financial year” (Section 35(4) of ESG Act). The ESG Act does not require ESG rating providers to define or disclose a conflicts of interest policy.
5. In India, regulations for ESG Rating Providers (ERPs) set out registration requirements, general obligations, inspection procedures and a code of conduct. Separate index provider regulations establish a governance framework to promote transparency and accountability in the administration of indices in the securities market.
6. In Japan, the Code of Conduct is not composed of laws or regulations that uniformly require actions of parties concerned, but designed to be a voluntary code on a “comply or explain” basis.
7. In Korea, the consultative body of ESG ratings providers released the Guidance for ESG Ratings Providers (on 1 September 2023) The guidance recommends the disclosure of evaluation methodologies, internal controls and related aspects in accordance with the Guidance. Institutions that are members of the consultative body should follow the Guidance, and if not, they are required to explain the reason for non-compliance under the comply-or-explain principle.
8. In Peru, SMV-authorised risk rating agencies may assess ESG factors when relevant to credit ratings.
9. In Singapore, the Code of Conduct for ESG Rating and Data Product Providers was published in December 2023. The Singapore Code aims to establish baseline industry standards for transparency in methodologies and data sources, governance, and management of conflicts of interest that may compromise the reliability and independence of the products. It builds upon the International Organization of Securities Commissions’ (“IOSCO”) recommendations for good practices for such providers.
10. South Africa has recently published a second draft Benchmark regulation.
11. In Türkiye, the CMB has regulatory power on capital market rating activities according to Capital Markets Law No. 6362 clauses 1, 62, 63 and 128. Although the CMB is planning to cover sustainability rating issues, currently no specific provision is in effect.
12. In the United Kingdom, the UK Benchmarks Regulations (BMR) define an index as a figure that is publicly available and is regularly determined, either by applying a formula or other calculation, or by making an assessment based on the value of one or more underlying assets/prices (including estimated prices, actual or estimated interest rates, quotes and committed quotes, or other values or surveys). An index becomes a benchmark within the scope of the BMR where: it is used to determine the amount payable under a financial instrument or financial contract, or the value of a financial instrument; or it is used to measure the performance of an investment fund for the purpose of tracking the return, defining the asset allocation or a portfolio, or computing the performance fees. In November 2024, HM Treasury published draft legislation and the consultation response on bringing ESG ratings providers into regulation in the United Kingdom. The FCA will work with the Government on next steps and plans to consult on the proposed regulatory regime once legislation is finalised in 2025.
Table 5.5. Sustainability assurance frameworks
Copy link to Table 5.5. Sustainability assurance frameworks|
Jurisdiction |
Framework |
Key source(s) |
Assurance service providers |
Scope |
Application year(s) |
Assurance Standard1 |
||
|---|---|---|---|---|---|---|---|---|
|
Phasing in implementation |
Limited assurance |
Reasonable assurance |
||||||
|
Argentina |
C |
Handbook for voluntary reporting and disclosure of ESG information |
- |
- |
No |
- |
- |
- |
|
Australia |
L |
A |
PO (Scope 1 and 2)2 |
Yes |
2025-2030 |
2028-2033 |
ASSA 5010 (ISSA 5000) |
|
|
Austria |
L, PC |
Report of the Chamber of Tax Advisors and Auditors KFS/PE 28 |
A |
W |
No |
- |
- |
ISAE 3000 |
|
Belgium |
L |
A |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000 ISAE 3400 (ISSA 5000) |
|
|
Brazil |
L |
A |
W |
Yes |
2024-2025 |
2026 |
ISSA 5000 |
|
|
Bulgaria |
L |
Independent Financial Audit and Assurance of Sustainability Reporting Act |
A, S |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000 (ISSA 5000) |
|
Canada |
- |
- |
- |
- |
No |
- |
- |
- |
|
Chile |
-3 |
- |
- |
- |
No |
- |
- |
- |
|
China |
- |
- |
- |
- |
No |
- |
- |
- |
|
Colombia |
PC |
- |
W |
Yes |
2025-2026 |
2026-2027 |
- |
|
|
Costa Rica |
- |
- |
- |
- |
No |
- |
- |
- |
|
Croatia |
L |
A |
W |
Yes |
2025-2029 |
- |
ISAE 3000 |
|
|
Czechia |
L |
A |
W |
Yes |
2025-2029 |
- |
ISAE 3000 |
|
|
Denmark |
L |
A, S |
W |
Yes |
2025 - 2029 |
- |
- |
|
|
Estonia |
L |
A |
W |
Yes |
2025-2029 |
- |
ISSA 5000 |
|
|
Finland |
L |
Accounting Act (1336/1997) Accounting Act (605/2024) Auditing Act (1141/2015) |
A, S |
W |
Yes |
2025 - 2029- |
- |
- |
|
France |
L |
Articles L232-6-3 and L233-28-4 of the French Commercial Code |
A, S |
PO |
Yes |
2025 – 2028 |
- |
Limited assurance guidelines of the French High Authority for Audit (English version) |
|
Germany4 |
PC |
S |
W |
Yes |
2025 - 2029 |
- |
- |
|
|
Greece |
L |
A, S |
W |
Yes |
2025-2029 |
- |
ISSA 5000 |
|
|
Hong Kong (China)5 |
PC |
HKSAR Government’s Roadmap on Sustainability Disclosure in Hong Kong |
- |
- |
No |
- |
- |
- |
|
Hungary |
L |
A |
W |
Yes |
2025-2029 |
- |
ISAE 3000 (ISSA 5000) |
|
|
Iceland |
PC |
Public Consultation on plans to implement CSRD |
- |
- |
No |
- |
- |
- |
|
India |
L |
Listing Obligations and Disclosure Requirements Regulations, 2015 |
A, S |
PO (Scope 1 and 2)6 |
Yes |
2024 – 20257 |
2027 – 20287 |
- |
|
Indonesia |
- |
- |
- |
- |
No |
- |
- |
- |
|
Ireland |
L |
Corporate Sustainability Reporting Regulations 2024 (amending Companies Act 2014) |
A8 |
W |
Yes |
2025 - 2029 |
- |
(ISAE 3000) |
|
Israel |
- |
- |
- |
- |
No |
- |
- |
- |
|
Italy |
L |
A |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000 |
|
|
Japan |
PC |
The Working Group on Disclosure and Assurance of Sustainability-related Financial Information) |
- |
- |
No |
- |
- |
- |
|
Korea |
PC |
O |
W |
No |
- |
- |
-9 |
|
|
Latvia |
L |
A |
W |
Yes |
2025-2029 |
- |
ISAE 3000 |
|
|
Lithuania |
L |
Law on audit of financial statements and other assurance services |
A, S |
W |
Yes |
2025-2029 |
- |
ISSA 5000 ISAE 3000 |
|
Luxembourg |
L |
A |
W |
Yes |
2025-2029 |
- |
- |
|
|
Malaysia |
PC |
A, O |
PG (Scope 1,2)10 |
Yes |
- |
2027 2028 2029 |
ISSA 5000 |
|
|
Mexico |
L |
A |
W |
Yes |
2027 |
2028 |
(ISSA 5000) |
|
|
Netherlands |
PC |
A |
W |
Yes |
2025-2029 |
- |
- |
|
|
New Zealand |
L |
O |
PG |
No |
2024 |
- |
NZ SAE 1: Assurance Engagements over Greenhouse Gas emissions Disclosure |
|
|
Norway |
L |
Private Limited Liability Companies Act |
A |
W |
No |
2024 |
- |
- |
|
Peru |
- |
- |
- |
- |
No |
- |
- |
- |
|
Poland |
L |
A |
W |
Yes |
2025- 2029 |
- |
(MSUA 3002PL) |
|
|
Portugal |
L |
- |
A |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000 |
|
Romania |
L |
Emergency Ordinance no. 137/2024 amending and supplementing Law No. 162/2017 on the statutory audit of annual financial statements and consolidated annual financial statements |
A |
W |
Yes11 |
2025 - 2029 |
- |
- |
|
Saudi Arabia |
- |
- |
- |
- |
No |
- |
- |
- |
|
Singapore |
PC |
A, S |
PG (Scope 1, 2) |
Yes |
2027-2029 |
- |
(a) A Singapore standard equivalent to ISSA 5000; or (b) Singapore Standard ISO 14064-3 |
|
|
Slovak Republic |
L |
A |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000R |
|
|
Slovenia |
L |
A |
W |
Yes |
2025 - 2029 |
- |
ISAE 3000 |
|
|
South Africa |
- |
- |
- |
- |
No |
- |
- |
- |
|
Spain |
L |
A, S |
PG (scope 1,2) |
Yes |
2025-2027 |
2027-2030 |
ISSA 5000 |
|
|
Sweden |
L |
A |
W |
Yes |
2025 – 2029 |
- |
ISAE 3000 |
|
|
Switzerland |
L |
Art. 964a et seq. CO |
PC12 |
W |
Yes |
- |
- |
- |
|
Türkiye |
L |
S13 |
W |
Yes |
2024 |
- |
(ISAE 3000) (ISAE 3410) |
|
|
United Kingdom |
- |
- |
- |
- |
No |
- |
- |
- |
|
United States |
- |
- |
- |
- |
No |
- |
- |
- |
Key: PC = public consultation or under active consideration; L = requirement by the law or regulations; R = requirement by the listing rule; C = recommendation by the codes or principles; "-" = absence of a specific requirement or recommendation.
Key: A = statutory auditors; S = sustainability-related assurance service providers with accreditation by a public organisation; O = assurance service providers without any accreditation by a public organisation.
Key: W = whole sustainability information; PG = part of sustainability information: only GHG emissions; PO = part of sustainability information: GHG emissions and other information. The parentheses indicate which scopes of GHG emissions are subject to assurance.
1. For assurance standards, the international standards in parentheses indicate that the regulator announced the intention to adopt the international standards or develop domestic assurance standards with reference the international standards.
Note: Under the EU’s Corporate Sustainability Reporting Directive (CSRD), companies are required to obtain limited independent assurance over their sustainability disclosures. The requirements for limited assurance follows those of the sustainability-related disclosure and will be phased in: (i) reporting in 2025 for companies already subject to the NFRD; (ii) reporting in 2026 for large companies that are not currently subject to the NFRD; (iii) reporting in 2027 for listed small and medium enterprises; and (iv) reporting in 2029 for third-country undertakings with net turnover above EUR 150 million in the European Union if they have at least one subsidiary or branch in the EU exceeding certain thresholds. Assurance can be provided by statutory auditors or, subject to national rules, by other independent assurance service providers, provided they meet the required standards of independence and professional competence.
EU member states may allow the use of national assurance standards, provided they are aligned with international best practices. The European Commission is developing EU-wide assurance standards for limited assurance, expected to be adopted by 2026.
2. In Australia, requirements commence with limited assurance of governance, strategy and Scope 1 and 2 emissions (PO) for a company’s first sustainability report, moving to reasonable assurance of the entire sustainability report (W) for a company’s fourth and subsequent reports.
3. In Chile, while sustainability assurance is not mandatory, General Rule No. 30 requires supervised entities to disclose in their annual report whether ESG information has undergone independent assurance, specifying the scope of the review and the standard applied.
4. In Germany, the limited assurance standard is going to be applied until the European Commission has adopted standards to obtain reasonable assurance for the assurance of the sustainability report. The standards for obtaining limited assurance have not yet been adopted. An alignment with international standards has not yet been officially announced.
5. In Hong Kong (China), the Government published a roadmap on sustainability disclosure in Hong Kong (China) in December 2024, setting out the approach for adopting the ISSB Standards and the development of a comprehensive ecosystem (including sustainability assurance) to support the sustainability framework.
6. Under India's BRSR Core framework, in-scope companies are required to disclose nine ESG attributes including: GHG footprint (Scope 1 and 2 only), water footprint, energy footprint, embracing circularity, details related to waste management by the entity, employee wellbeing and safety, enabling inclusive development, fairness in engaging with customers and suppliers, and the openness of business.
7. In India, limited assurance will apply to the top 150 listed companies with first disclosures due in 2024–25. In India, reasonable assurance will apply to the top 1 000 listed companies with first disclosures due in 2027–28.
8. In Ireland, the responsible individual at the statutory auditor responsible for the sustainability assurance work must be approved as a sustainability assurance service provider by a recognised accountancy body.
9. In Korea, there is currently no specific framework for sustainability assurance. However, various sustainability assurance institutions (e.g. consulting firm, law firm, accounting firm) offer assurance services to companies. Relevant framework and standards for sustainability assurance will be developed in the future.
10. In Malaysia, the framework for sustainability assurance is subject to consultation with stakeholders. The proposed approach is for reasonable assurance on Scope 1 and 2 GHG emissions to be phased in the following order: 2027 (main market listed issuers with market cap. of MYR 2 billion and above), 2028 (other main market listed issuers) and 2029 (ACE market listed issuers and non-listed companies with annual revenue of MYR 2 billion and above.
11. In Romania, the obligation to prepare the sustainability report (for which the assurance opinion is issued) applies starting in 2024, as follows: (i) in 2024 by large entities that have over 500 employees; (ii) in 2025 by large entities other than those previously mentioned; and (iii) in 2026 by small and medium-sized entities that have securities admitted to trading.
12. In Switzerland, it is anticipated that statutory auditors and independent assurance providers will be allowed to conduct sustainability assurance. Provisions on limited assurance are currently under public consultation.
13. In Türkiye, sustainability assurance must be conducted by auditors authorised for independent audits and possessing relevant expertise. Since September 2024, the KGK has been holding exams to certify auditors for this purpose.
References
[7] EU (2024), Regulation - EU - 2024/3005 -, https://eur-lex.europa.eu/eli/reg/2024/3005/oj/eng (accessed on 16 May 2025).
[1] EU (2022), Directive - 2022/2464 CSRD Directive, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2464 (accessed on 16 May 2025).
[6] EU (2016), Regulation - 2016/1011 - Benchmark Regulation, https://eur-lex.europa.eu/eli/reg/2016/1011/oj/eng (accessed on 16 May 2025).
[8] HM Treasury (2024), Future regulatory regime for Environmental, Social, and Governance (ESG) ratings providers, https://www.gov.uk/government/consultations/future-regulatory-regime-for-environmental-social-and-governance-esg-ratings-providers (accessed on 16 May 2025).
[2] IFRS Foundataion (2023), IFRS - IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information, https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s1-general-requirements/ (accessed on 16 May 2025).
[3] IFRS Foundation (2023), IFRS - IFRS S2 Climate-related Disclosures, https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s2-climate-related-disclosures/ (accessed on 16 May 2025).
[5] IOSCO (2022), CALL FOR ACTION (IOSCO GOOD SUSTAINABLE FINANCE PRACTICES), https://www.iosco.org/library/pubdocs/pdf/IOSCOPD690.pdf (accessed on 16 May 2025).
[4] IOSCO (2021), Environmental, Social and Governance (ESG) Ratings and Data Products Providers Final Report, http://www.iosco.org (accessed on 16 May 2025).