State Ownership and Sustainability in Asia

3. Sustainability reporting and disclosure

Abstract

This chapter explores mandatory and voluntary sustainability reporting frameworks applicable to SOEs in the reviewed countries, including regulatory requirements for listed and non-listed entities. It also outlines the gaps in assurance, aggregation and enforcement, and the resulting implications for transparency and SOE governance.

3.1. Sustainability reporting and disclosure frameworks

As highlighted in the OECD Guidelines on Corporate Governance of State-Owned Enterprises, state owners should expect SOEs to be subject to appropriate reporting and disclosure requirements – in line with listed companies – based on consistent, comparable and reliable information. Sustainability reporting and disclosure should be aligned with internationally recognised standards that facilitate consistency and comparability across markets, jurisdictions and companies.

Across the reviewed jurisdictions, the extent of sustainability-related reporting obligations varies. There are differences in obligations according to the sector, enterprise size and ownership structure, and there is no comprehensive regulatory framework applying sustainability requirements to non-listed SOEs, although there is a gradual alignment with interoperable global standards. As a result, transparency and disclosure practices remain fragmented, with regulatory and oversight bodies responsible for monitoring disclosure facing enforcement capacity and resource constraints and some SOEs facing difficulties in implementing reporting requirements.

As set out in Table 3.1, legal and regulatory developments across the reviewed countries have predominantly focused on listed entities, including listed SOEs. Several jurisdictions (e.g. China, Japan) have included large non-listed companies within the phased implementation of frameworks based on IFRS S1 and S2. However, it will take several years before even the largest non-listed SOEs are required to disclose sustainability-related information on comparable terms to listed SOEs. Capacity and resourcing limitations are often cited as reasons for the absence of (or limited) reporting obligations placed on non-listed enterprises.

Table 3.1. Overview of sustainability reporting: A comparison between listed and non-listed SOEs

Country	Listed SOEs (Regulatory requirements and practices)	Non-listed SOEs (Regulatory requirements and practices)
China	Mandatory: Stock exchanges mandate sustainability disclosure for certain listed companies, with a double materiality threshold. As of 2024, companies in key indices (Shanghai Stock Exchange (SSE) 180, STAR 50, Shenzhen Stock Exchange (SZSE) 100, ChiNext) and dual-listed firms must publish annual sustainability reports. Previously, companies on the SSE, STAR Market and SZSE 100 Index were already required to disclose ESG information, and heavy polluters are required to report environmental data.	Mandatory: SASAC issued guidelines in 2008 requiring all central SOEs to publish CSR reports. Compliance was effectively treated as mandatory, leading to an increase in reporting by SOEs.
	Voluntary/Guidance: For other listed companies, including listed SOEs, sustainability disclosure is encouraged through soft-law mechanisms, notably stock exchange self-regulatory guidelines and corporate governance codes (e.g. SSE’s 2024 Sustainability Report Guidelines; Code of Corporate Governance for Listed Companies) rather than imposed as a binding obligation. The new climate-related reporting standard released in January 2026 is substantively based on IFRS and is initially voluntary, although it is expected to become mandatory.	Voluntary/Guidance: In 2016, SASAC reinforced that fulfilling social responsibility is essential for sustainable development. While no unified law mandates sustainability reports from unlisted SOEs, many large SOEs now voluntarily release annual CSR or sustainability reports (often referencing GRI standards). SASAC’s official guidance has made sustainability reporting a normative expectation for SOEs. Disclosures in accordance with the new climate-related reporting standard applicable to listed companies is also voluntary (and expected to become mandatory) for unlisted SOEs.
India	Mandatory: The Securities and Exchange Board of India (SEBI) requires the top 1 000 listed companies to include a Business Responsibility and Sustainability Report (BRSR) in annual reports from FY2022–23. Additionally, SEBI has introduced enhanced requirements (a BRSR Core subset with limited assurance for top 500 companies' value chains for FY2025-26).	Mandatory: Department of Public Enterprises (DPE) guidelines apply to CPSEs. The DPE Guidelines on CSR and Sustainability (2013) effectively require CPSEs to report on social and environmental performance. The Companies Act 2013 also mandates that large companies (including SOEs) report their CSR activities and spending (with a 2% average net profit expenditure requirement on CSR for eligible firms without an explanation).
	Voluntary/Guidance: The BRSR format is based on India’s national guidelines – (initially the National Voluntary Guidelines of 2011 and subsequently updated to the National Guidelines for Responsible Business Conduct of 2019) – and is broadly aligned with global standards. Many listed SOEs also voluntarily publish standalone sustainability or ESG reports following frameworks like GRI, complementing the mandatory BRSR.	Voluntary/Guidance: The government introduced National Voluntary Guidelines (2011) urging all businesses to integrate and report on social, environmental, and economic responsibilities. In practice, many SOEs produce sustainability reports or dedicated CSR sections in annual reports to meet these guidelines. The state expects SOEs to be leaders in responsible business conduct and move from pure philanthropy to structured sustainability reporting.
Indonesia	Mandatory: The Financial Services Authority, Otoritas Jasa Keuangan (OJK), issued Rule No. 51/POJK.03/2017 obligating all public companies and financial institutions to publish annual sustainability reports. This requirement was phased in by company size: large issuers submitted their first sustainability reports in 2021 (for 2020 data), medium issuers by 2023, and all others by 2025. OJK’s regulation does not mandate adherence to a particular standard – although many companies report in adherence with GRI standards. Separately, Indonesia’s Company Law (Article 74 of Law 40/2007) requires companies engaged in natural resources to undertake and report on CSR, which covers many SOEs. Regulation based on IFRS international standards is expected to be introduced.	Mandatory: Unlisted SOEs are not directly covered by OJK Rule No. 51, but other transparency laws apply. The Public Information Disclosure Law (No.14/2008) obliges SOEs to provide certain information to the public upon request.
		Voluntary/Guidance: There is no statutory requirement for a standalone sustainability report, yet government policy encourages it. Many large SOEs voluntarily publish sustainability/CSR reports to showcase compliance with the CSR mandate under Law 40/2007 and to meet stakeholder expectations. These reports often follow GRI Standards or other international frameworks.
Japan	Mandatory: Recent regulatory changes have introduced sustainability disclosure into Japan’s reporting regime. The Financial Services Agency (FSA) now requires listed companies to disclose material ESG information (covering environmental issues, human rights, anti-corruption measures, and related risk management) in their securities reports. In addition, companies listed on the premier “Prime Market” segment of the TSE must specifically analyse and disclose climate-related risks and opportunities, in line with TCFD recommendations. Regulation based on IFRS international standards is to be introduced.	Mandatory: Japan's SOEs are generally subject to public-sector disclosure rules rather than commercial disclosure requirements. There is no specific legal mandate for stand-alone sustainability reporting by unlisted SOEs. Regulation based on IFRS international standards applies to large non-listed companies.
	Voluntary/Guidance: Japan’s Corporate Governance Code also calls for companies to “appropriately disclose their initiatives on sustainability” as part of their business strategy (on a comply-or-explain basis). This has led many listed companies – including SOEs – to adopt integrated reporting and global frameworks. For instance, a significant number of SOEs use Carbon Disclosure Project questionnaires for climate and GRI standards for broader ESG topics.	Voluntary/Guidance: Many government-owned or affiliated companies voluntarily issue sustainability or CSR reports in line with Japan’s commitment to the SDGs and international standards. Unlisted or quasi-governmental entities have begun voluntary sustainability reporting and initiatives to support the country’s green transition and social goals.
Korea	Mandatory: Korea is moving towards comprehensive ESG disclosure for listed companies. Since 2021, an amendment to the Environmental Technology and Industry Support Act mandates that all large, listed companies (assets over KRW 2 trillion) disclose environmental management information (e.g. pollution reduction plans). Additionally, the Financial Services Commission announced a roadmap to phase in mandatory ESG reporting for all KOSPI-listed firms by 2030. Corporate governance disclosures were earlier enforced – since 2019, KOSPI companies above a certain size must publish annual governance reports. Regulation based on IFRS international standards is expected to be introduced.	Mandatory: The Act on the Management of Public Institutions (2007) and the Official Information Disclosure Act (1998) require public-sector companies to be transparent about their operations. This means key information on SOE activities and performance must be publicly disclosed as a matter of law (e.g. financial results, budgets, with some non-financial aspects). There is no specific obligation for unlisted SOEs to produce a separate sustainability report, but government policy strongly incentivises it.
	Voluntary/Guidance: Stock exchange and regulators encourage alignment with global standards (the Korean Exchange has supported DJSI and TCFD adoption). Many large listed SOEs already follow GRI guidelines and issue externally assured sustainability reports.	Voluntary/Guidance: Most large Korean SOEs and public institutions voluntarily publish annual sustainability or social responsibility reports, in line with government guidance. These often adhere to international frameworks (GRI, ISO 26000) and demonstrate how the SOE is contributing to social and environmental objectives in line with government priorities. The MOFE has also recently released ESG Guidelines for public institutions (including SOEs), with voluntary disclosure indicators including climate risk and biodiversity.
Malaysia	Mandatory: Bursa Malaysia’s listing requirements oblige listed companies (including SOEs) to provide sustainability disclosures. Since 2016, listed companies have had to include a Sustainability Statement in annual reports, and in September 2022 the sustainability reporting framework was further enhanced with a phased rollout from FY2023. Under the updated rules, all Main and ACE Market listed firms must disclose a set of common sustainability matters and indicators, and provide climate-related disclosures aligned with TCFD recommendations. They must also state whether their sustainability information has undergone internal review or independent assurance. Regulation based on IFRS international standards is expected to be introduced.	Mandatory: There are no specific requirement for unlisted SOEs or “Government-linked companies” to publish sustainability reports.
	Voluntary/Guidance: Bursa Malaysia’s guidelines encourage reference to international standards (e.g. IFRS, GRI) and many companies seek external assurance of ESG data.	Voluntary/Guidance: A 2009 Securities Commission circular provided guidance on corporate responsibility disclosure and reporting. While these are not mandatory, they signal clear government expectations. Consequently, many major GLCs and unlisted SOEs produce sustainability or integrated reports voluntarily. They often use GRI Standards and align with Malaysia’s sustainability reporting frameworks. The government also promotes recognition (e.g. annual CSR awards) to incentivise transparency in this sector.
Philippines	Mandatory: There are currently no listed Government-Owned or -Controlled Corporations (GOCCs) in the Philippines. The Securities and Exchange Commission (SEC) introduced Sustainability Reporting Guidelines for Publicly-Listed Companies in 2019 under SEC Memorandum Circular No. 4 series of 2019. Initially, publicly listed companies were required to report sustainability (referred to as economic, environmental, social and governance (EESG)) performance on a “comply or explain” basis. From 2023 onwards, the SEC made sustainability reporting mandatory for all listed companies, to be submitted alongside annual financial reports. Companies must either comply or explain any omissions, ensuring full coverage of sustainability topics. In 2026, the SEC announced the adoption of the Philippine Financial Reporting Standards (PFRS) on Sustainability Disclosures, based on IFRS S1 and S2, expected to apply to large and publicly listed companies over the coming years.	Mandatory: There is currently no requirement compelling non-listed GOCCs to issue sustainability reports. Although, the Governance Commission for GOCCs (GCG) encourages transparency and accountability with governance scorecards for GOCCs and the inclusion of metrics for CSR or sustainability reporting in evaluations (for example, GOCCs are asked whether they have a separate CSR/sustainability section or report). Regulation based on IFRS international standards is expected to be introduced.
	Voluntary/Guidance: The SEC provides? a Sustainability Reporting Template aligned with internationally accepted frameworks (including GRI Standards, SASB and TCFD recommendations). This alignment helps companies meet global norms, and many listed firms in the Philippines now follow GRI or similar standards when preparing their reports.	Voluntary/Guidance: In practice, some GOCCs – especially larger ones in sectors such as energy or infrastructure – voluntarily publish annual sustainability or CSR reports to showcase their social and environmental contributions. These often draw on global standards (e.g. GRI) and align with national development goals. The trend is towards increasing disclosure, and extension of sustainability reporting requirements beyond the listed sector in the coming years is being considered.
Singapore	Mandatory: The Singapore Exchange (SGX) requires all listed companies (including SOEs) to conduct sustainability reporting on a comply-or-explain basis. This rule, in place since FY2016, obliges listed issuers to publish an annual sustainability report covering material ESG factors, targets, policies and performance. In recent years SGX has specifically strengthened climate disclosure where, from 2022, climate reporting consistent with TCFD recommendations is required for all listed companies (on a "comply or explain" basis), with full mandatory TCFD-aligned reporting phased in for certain industries (e.g. financial, agriculture, energy from 2023 and materials and transportation from 2024). Regulation for large, listed companies based on IFRS international standards is expected to be introduced.	Voluntary: Unlisted SOEs are not subject to a dedicated sustainability reporting requirement. Many large SOEs and government-linked companies voluntarily produce sustainability reports or include extensive ESG disclosures in their annual reports. For example, Temasek-owned companies often publish sustainability information to demonstrate alignment with Singapore’s national sustainability agenda. These entities commonly adopt global reporting standards such as GRI or align with the ISO 26000 social responsibility guidance. The state’s expectations (though not codified in law) are that SOEs lead by example on transparency and environmental stewardship, so voluntary sustainability reporting has become standard practice in the public corporate sector.
	Voluntary/Guidance: SGX guidelines advise companies to use internationally recognised frameworks and standards for their reports. Listed SOEs typically follow GRI Standards or other global frameworks and must disclose the framework chosen. Assurance of sustainability data is encouraged by regulators, though not compulsory for all.
Thailand	Mandatory: The Securities and Exchange Commission (SEC) revamped listed company (including SOEs) disclosure with the Form 56-1 One Report system in 2020. This integrated annual report format (fully effective by 2022) requires all Main Board listed companies to report on their sustainability performance alongside financial results. Under the One Report, companies must disclose material ESG activities and metrics, including GHG emissions and human rights issues, among others (Only SMEs listed on a separate SME exchange are exempt and may report voluntarily).	Voluntary: There are no specific requirements for unlisted SOEs to report on and disclose sustainability or CSR. SOEs are required to report to SEPO on the attainment of financial and non-financial KPIs, including on social and environmental performance metrics, however reporting and disclosure on sustainability is not mandated. Although there are no formal requirements, many large SOEs voluntarily issue sustainability or CSR reporting against listed-company standards. These often follow GRI or integrated reporting frameworks.
	Voluntary/Guidance: The SEC’s guidance for One Report explicitly references international frameworks – companies are expected to use reporting standards proportional to their size and complexity, with the GRI Standards cited as a key reference. The SEC became an official “TCFD supporter” in 2020 and encourages climate-risk disclosure.
Viet Nam	Mandatory: The Ministry of Finance introduced a regulation in 2020 (Circular 96/2020/TT-BTC) that requires publicly listed companies (including SOEs) to report on environmental and social impacts as part of their annual report. Since 2021, listed companies must disclose a range of sustainability information (e.g. environmental protection efforts, treatment of employees and community impact) in their reporting to shareholders. This has expanded prior voluntary guidance and has effectively made sustainability disclosure a standard element of listed company reporting.	Mandatory: The government has imposed broad transparency obligations on SOEs. Decree 81/2015/ND-CP on information disclosure for SOEs compels wholly state-owned enterprises to publish both financial and non-financial information. On the latter, SOEs’ annual reports include information on corporate social responsibility activities, environmental protection, and employee policies. These reports must be made public (e.g. on company websites) and submitted to supervising ministries. In practice, compliance has been uneven.
	Voluntary/Guidance: The State Securities Commission, in collaboration with the International Finance Corporation, issued an Environmental and Social Disclosure Guide in 2016 to help companies report in line with international standards. Companies are encouraged (though not obligated) to use GRI Standards or similar frameworks for more comprehensive sustainability reports.	Voluntary/Guidance: Beyond the decree, large SOEs that are preparing for equitisation or seeking international investment often voluntarily adopt global standards (such as GRI or integrated reporting) in their sustainability reporting to enhance credibility. The continued push for better SOE governance and accountability is gradually raising the prevalence of sustainability reporting.

Source: Secretariat compilation from questionnaire responses from national authorities, desktop research and OECD, (2025[1]), Corporate Governance Factbook, https://doi.org/10.1787/f4f43735-en.

Table 3.2 provides an overview of the references to various international sustainability reporting standards in the domestic regulation and guidance set out above in Table 3.1.

Table 3.2. Sustainability reporting frameworks applicable to listed companies and/or SOEs

Country	TCFD	GRI	SASB	IFRS S1 / S2
China				
India	●	●	●	
Indonesia		●		●
Japan	●	●	●	●
Korea		●		
Malaysia	●	●	●	●
Philippines	●	●	●	●
Singapore	●	●	●	●
Thailand	●	●		
Viet Nam		●	●

Note: ● = referenced in current national framework  = under consideration to be referenced in forthcoming proposed local standards. China’s sustainability related disclosure standards of its listing rules are local standards with no direct alignment with international frameworks. It has proposed reporting standards based on IFRS S1 and S2.

Source: Secretariat desktop research, submissions from national authorities, OECD Corporate Governance Factbook

Both the GRI and SASB frameworks are widely referenced in regulation and guidance across the region. This prevalence is reflected in practice: SOEs in India, Japan, Korea, Malaysia, the Philippines, Singapore and Viet Nam commonly use both GRI Standards and SASB standards; and SOEs in Indonesia and Thailand use mostly GRI Standards (GRI, 2024[2]; KPMG International, 2024[3]; SASB, 2025[4]).

As explained further below, new IFRS-aligned national disclosure frameworks will slowly be phased in and will build on existing TCFD-aligned frameworks where applicable. While most frameworks apply primarily to listed entities, their coverage of SOEs remains partial and disparate, which may limit the comparability and extensiveness of disclosures. Reasons for this include coverage gaps (e.g. different obligations for listed/non-listed SOEs), uneven or fragmented regulatory or stakeholder expectations (e.g. focusing on specific industries or sectors) and enterprise-specific capacity limitations.

3.1.1. Mandatory regulatory requirements and voluntary initiatives for listed SOEs

Across the surveyed jurisdictions, listed SOEs are generally subject to the same sustainability reporting and disclosure requirements that apply to other listed companies. In practice, securities regulators and stock exchanges are the primary sources of regulatory oversight for listed-entity sustainability disclosures, with requirements typically embedded in listing rules, securities regulation, or associated regulatory guidance. Given these regimes are designed for listed entities as a category - rather than for SOEs specifically - SOE coverage is often incidental (i.e. dependent on whether an SOE is listed and/or falls within size and sector thresholds), which contributes to uneven disclosure practices across the state-owned sector.

From TCFD based initiatives to standards based on IFRS S1/S2

To date, several surveyed countries have relied on the TCFD framework as a basis for initial national sustainability reporting initiatives, typically combining mandatory requirements for high-impact sectors with “comply or explain” expectations for other listed issuers. Until the recent introduction of IFRS S1 and S2-aligned disclosures, Singapore’s listed entities were required to disclose climate-related information in line with the TCFD framework, made mandatory for certain sectors (e.g. energy, finance, agriculture) and otherwise on a “comply or explain” basis. Since 2021, Malaysia has embedded TCFD disclosure requirements into its Bursa Malaysia Listing Requirements. Japan’s listed entities were also initially required to disclose climate-related information in accordance with TCFD on a “comply or explain” basis. Compliance became mandatory in 2023 as part of new sustainability reporting rules implemented by the Financial Services Agency. The Philippines took a similar approach in first requiring listed companies to make climate-related disclosures on a “comply or explain” basis with the intention to move towards mandatory reporting. India and Thailand have been less prescriptive: Thailand’s SEC has encouraged listed companies to disclose in accordance with TCFD requirements, while India’s BRSR framework recognises cross-referencing to TCFD disclosures without mandating alignment.

The listing rules in China, Malaysia and Singapore each require the disclosure of metrics related to sustainability-related goals, and China and Malaysia also require disclosure of value chain information. China’s Ministry of Finance has also provided codes regarding sustainability-related disclosures that apply to all enterprises (in addition to the mandatory listing rules), with standards based on IFRS S1 and S2.

Following the completion of TCFD’s remit and its disbandment, many of the reviewed countries are aligning with a global shift towards IFRS S1 and S2-compliant reporting.1 As set out in Table 3.2, most countries (Indonesia, Japan, Korea, Malaysia, the Philippines, Singapore, Thailand) have developed, or are developing, national sustainability-related disclosure standards based on IFRS S1 and S2. China and India have also referred to IFRS standards in developing local disclosure standards. In January 2026, China’s Ministry of Finance released a Corporate Climate Reporting Standard based on IFRS S2 to initially apply as a voluntarily trial and progressively become mandatory. These new national frameworks are generally expected to build on existing TCFD-aligned practices where applicable and will be phased in.

The reviewed countries are at different stages of approval and implementation, but the majority remain committed to mainstreaming sustainability disclosure obligations. Notably, Singapore has extended implementation timelines to take a more “targeted and proportionate approach”, and Korea put the development of a national sustainability disclosure standard on hold in 2025 due to global regulatory shifts. On 5 March 2026, Korea’s Accounting Standards Board released its final sustainability reporting standards for mandatory sustainability disclosures along with a draft roadmap for their implementation.

Viet Nam is an exception as it has not proposed any sustainability-related standards in accordance with IFRS S1 and S2. Currently, many public and listed companies (including some public or listed SOEs) must disclose non-financial information (including sustainability-related information) in annual reports under Circular No. 96/2020/TT-BTC. There are also specific environmental reporting obligations under decrees and circular regulations, resulting in government filings rather than sustainability reports. For consistent and comparable reporting, it will be important that the national integration of sustainability reporting is aligned with national standards, rather than facilitating a fragmented disclosure regime via multiple decrees and circular regulations.

Importantly, most national sustainability disclosure regimes are designed for listed entities generally. This means that SOE coverage is incidental (by virtue of listing or sector), rather than tailored to the nature of these enterprises. To the extent that SOEs are covered by a national regime, the focus is on listed SOE disclosures. In terms of international frameworks informing public sector disclosures more generally, Box 3.1 provides an overview of recent international guidance for governments and public sector entities to report on climate-related risks and opportunities.

Initiatives to increase interoperability of global reporting standards, including the European Financial Reporting Advisory Group (EFRAG)’s work, will be helpful in reducing disparities but are unlikely to remove differences entirely. For example, the GRI Standards’ impact materiality approach, which is in part integrated within the European Sustainability Reporting Standards (ESRS) (i.e. reporting standards under the EU Corporate Sustainability Reporting Directive (CSRD), may not fit neatly with the financial materiality thresholds of IFRS S1 and S2. The result would be different concepts of materiality, and consequently different disclosure thresholds. Additionally, as explained above, interoperability may improve comparability for listed SOEs, while unlisted SOE comparability will still depend heavily on state-owner policies and public accessibility. This is also relevant to the aggregate reporting practices of state-owners as further discussed below in Section 3.2.

Box 3.1. First international sustainability reporting standard for the public sector

In January 2026, the International Public Sector Accounting Standards Board (IPSASB) released its Climate-related disclosure standard (IPSASB SRS 1) as guidance for governments and public sector entities to report on climate-related risks and opportunities.

The standard is designed for use by public sector entities (including national, regional and local governments) that meet all three following criteria:

• responsible for the delivery of services to benefit the public and/or redistribute income and wealth

• mainly finance their activities by taxes and/or transfers from other levels of government, social contributions, debt or fees

• do not have the primary objective to make profits.

The standard is aligned with IFRS S2 but has been developed to more directly take account of the particular context of public sector operations. IPSASB SRS 1 will apply to general purpose financial reports for annual reporting periods beginning on or after 1 January 2028, with earlier adoption permitted. While the standards do not specifically refer to SOEs, it can be assumed that various public sector bodies, including governments, will refer to the expectations to inform national initiatives.

Figure 3.1. Overview of IPSASB disclosures

Source: IPSASB (2026[5]), IPSASB SRS 1, Climate-related Disclosures, https://ifacweb.blob.core.windows.net/publicfiles/2026-01/IPSASB-SRS-1-AAG.pdf; IPSASB SRS, (2026[6]), IPSASB SRS 1, Climate-related Disclosures, https://ifacweb.blob.core.windows.net/publicfiles/2026-01/IPSASB-SRS-1-Climate-related-Disclosures.pdf.

Differences in disclosure regimes with reference to structure and sector

Among the reviewed jurisdictions that have incorporated a national disclosure framework based on IFRS S1 and S2, there are several national nuances in both the application of the framework and the specific reporting requirements as set out in Table 3.3.

Table 3.3. National models for sustainability frameworks based on IFRS S1 / S2

Country	Phased requirements			Mandated disclosures	Scope 3 GHG emissions disclosure relief
	Type of enterprise / market	Commencement year	Report due
Indonesia	-	FY commencing on or after 1 January 2027	2028	TBC (current draft is only climate)
Japan	Voluntary adoption	FY2026	2026	-	Liability protection for misstatements of Scope 3 emissions, provided there is a reasonable internal process for estimation
	Prime Market of TSE with market cap ≥ JPY 3 trillion	FY ending 31 March 2027	2027
	Prime Market of TSE with market cap JPY 1 trillion < 3 trillion	FY ending 31 March 2028	2028
	Prime Market of TSE with market cap JPY 500 billion < 1 trillion. *Subject to further discussion.	FY ending 31 March 2029	2029
	All other Prime Market of TSE	Not expected until 2030s	TBC
Korea [1]	Listed on KOSPI Index with assets > KRW 30 trillion	FY commencing on or after 1 January 2027	2028	Only climate for first year	Relief for first three years of reporting
	Listed on KOSPI with assets > KRW 10 trillion	FY commencing on or after 1 January 2028	2029
Malaysia	Main Market (e.g. corporations, REITS, business trusts) with market cap ≥ MYR 2 billion	FY beginning on or after 1 January 2025	2026	Only climate for first two years	Relief for first two years of reporting
	Other Main Market	FY beginning on or after 1 January 2026	2027	Only climate for first two years	Relief for first two years of reporting
	ACE Market Large non-listed with annual revenue ≥ MYR 2 billion	FY beginning on or after 1 January 2027	2028	Only climate for first three years	Relief for first three years of reporting
Philippines [2]	Publicly listed with market cap > PHP 50 billion	FY commencing on or after 1 January 2026	2027	Only climate for first year	Relief for first two years of reporting
	Other publicly listed with market cap > PHP 3 billion	FY commencing on or after 1 January 2027	2028
	Other publicly listed with market cap ≤ PHP 3 billion Large non-listed with annual revenue > PHP 15 billion	FY commencing on or after 1 January 2028	2029	Only climate for first two years
Singapore	STI constituent listed (with Scope 1 and 2 disclosures for all issuers)	FY commencing on or after 1 January 2025	2026	Only climate	Relief for first year of reporting
	Issuers with market cap ≥ SGD 1 billion	FY commencing on or after 1 January 2028	2029		Voluntary only
	All other issuers	FY commencing on or after 1 January 2030	2031		Voluntary only
Thailand	SET50 listed	FY2027	2028	Only climate for first five years. Sustainability-related information disclosed on a “comply or explain” basis.	Relief for first five years of reporting
	SET100 listed	FY2028	2029
	Other SET listed	FY2029	2030
	Listed in Market for Alternative Investments, REITS, Infrastructure Trusts, and Property and Infrastructure Funds	FY2030	3031

Note: This table only includes countries with new, finalised sustainability disclosure frameworks in accordance with IFRS S1 and S2. China’s proposed Corporate Climate Reporting Standard has not been included in the above table given the positioning as a voluntary ‘trial’, notwithstanding intentions to make related disclosures mandatory overtime.

[1] The draft roadmap for the implementation of Korea’s sustainability disclosure regime indicates that there may be a further expansion to require smaller enterprises to report depending on readiness and international developments. [2] As there are currently no listed GOCCs in the Philippines, the sustainability disclosure regime does not apply to GOCCs unless they are considered a large non-listed enterprise with an annual revenue exceeding PHP 15 billion required to prepare a sustainability report for FY2028. Notably, the national legislation implementing the standards specifically states that “the Governance Commission for Government-Owned or -Controlled Corporations (GCG) shall not be precluded from establishing an appropriate sustainability reporting framework for government-owned or controlled corporations (GOCCs). Government corporations classified as Commercial Public Sector Entities and other entities regulated by the Insurance Commission will commence reporting following separate guidelines and timelines.”

Source: Secretariat compilation based on questionnaire responses from national authorities and desktop research.

Phasing and implementation: entity size, sector, and climate-first approaches

Across the region, the determination of which entities must adhere to national disclosure frameworks is typically based on one or more criteria: enterprise size, type and/or sector. Japan and Malaysia consider both size and type (large, listed companies in Japan; and in Malaysia, large listed and certain large unlisted entities - discussed further below). Singapore, Thailand and the Philippines apply requirements more widely to listed companies and financial institutions (with Singapore narrowing scope to large financial institutions). Notably, the Philippines is also running pilot programmes for GOCCs. China and Indonesia also use sectoral criteria, often placing disclosure obligations on financial institutions in addition to public companies and (in China) large SOEs.

Segmented phasing is also evident in the roll-out of requirements, with Japan, Malaysia, the Philippines, Singapore and Thailand setting timelines for gradual implementation by entity size (often determined by market capitalisation). Indonesia is considering a similar approach, with timelines still being determined. Several jurisdictions are also adopting a “climate-first” sequencing: Korea, Malaysia, the Philippines and Thailand require climate-related disclosures first, with broader sustainability disclosures phased in later or initially applied on a “comply or explain” basis. Several countries are phasing in Scope 3 emissions disclosures, given the complexities further set out in Box 3.2 below.

In Korea and the Philippines, only climate-related disclosures will be required in the first year of reporting (and the first two years for companies required to start reporting from 2028 in the Philippines; i.e. smaller publicly listed companies). Malaysia requires only climate-related disclosures for the first two years of reporting for its Main Market listed issuers, and the first three years for ACE market (designed for growth companies) listed corporations and large non-listed companies. Thailand’s climate-first approach lasts for the first five years of reporting, during which broader sustainability-related information shall be disclosed on a “comply or explain” basis. Indonesia is also proposing sustainability-related disclosures as voluntary, while requiring climate-related information, but this is subject to further confirmation.

India illustrates how multiple frameworks can operate in parallel. A draft disclosure framework focused on climate-related risks for regulated banks aligns with the structure of IFRS S1 and S2 (governance, strategy, risk management, metrics and targets) and would apply in addition to the SEBI BRSR framework, which draws on GRI, SASB and TCFD frameworks (SEBI, 2021[7]; SEBI, 2023[8]). Combined, these approaches would require:

• the top 1 000 listed entities by market capitalisation to report environmental information including governance and process disclosures, and performance metrics

• the top 500 listed entities by market capitalisation2 to disclose additional KPIs and metrics, including value chain parameters (e.g. Scope 2 and Scope 3 GHG emissions, and other impacts)

• regulated banks to make climate-related disclosures aligned with the IFRS-style structure.

Common reference frameworks and specific metric/value chain requirements

Both the GRI and SASB frameworks are widely referenced in regulation and guidance across the region, and this prevalence is reflected in practice. Sustainability disclosures of selected SOEs commonly use both the GRI Standards and SASB Standards in India, Japan, Korea, Malaysia, the Philippines, Singapore and Viet Nam, but in Indonesia and Thailand the GRI Standards are more common. In addition, listing rules in China, Malaysia and Singapore require disclosure of metrics related to sustainability-related goals.

The incremental development of India’s disclosure framework indicates an ongoing and growing focus on sustainability disclosures, but may also prove complex and burdensome for SOEs, and the state as an owner due to overlapping frameworks.

The Philippines is the only reviewed country that has distinguished between SOEs and other corporations in the development of its sustainability disclosure framework, by announcing that plans for listed company and financial institutions reporting should not preclude the development of a reporting framework for GOCCs (Senate of the Philippines, 2024[9]). Instead, it is more common to prioritise listed enterprise disclosures, regardless of ownership.

Box 3.2. Scope 3 GHG emissions

What are Scope 3 GHG emissions?

IFRS S2 defines Scope 3 greenhouse gas emissions as indirect GHG emissions (not included in Scope 2 GHG emissions) that occur in the value chain of an entity, including both upstream and downstream emissions.

Scope 3 GHG emissions include the following Scope 3 categories in the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011): purchased goods and services; capital goods; fuel- and energy-related activities (not included in Scope 1 or Scope 2 GHG emissions); upstream transportation and distribution; waste generated in operations; business travel; employee commuting; upstream leased assets; downstream transportation and distribution; processing of sold products; use of sold products; end-of-life treatment of sold products; downstream leased assets; franchises; and investments.

Why are measurements of Scope 3 GHG emissions challenging?

Measuring an enterprise’s Scope 3 GHG emissions is well-recognised as a complex task as it requires emissions data from third parties (upstream and downstream value chain) which can present challenges with respect to data availability and quality.

How are sustainability-related disclosure frameworks recognising this challenge?

IFRS S2 directly recognises the expected use of estimation in the calculation of Scope 3 GHG emissions, rather than solely comprising direct measurement. The disclosure framework also permits entities to rely on relief from disclosing Scope 3 emissions in the first annual reporting period in which the standard is applied.

The national implementations of IFRS S2 by the surveyed jurisdictions have provided further relief. In the Philippines and Malaysia, Scope 3 emissions disclosures are not required for the first two years of reporting (and first three for ACE Market listed corporations and large non-listed companies in Malaysia). Thailand will not require Scope 3 emissions disclosures for the first five years of reporting. India’s BRSR core framework requires disclosures related to the value chain only from the top 500 listed entities by market capitalisation on a “comply or explain” basis. Japan focuses on liability in specifying there can be no liability attaching to disclosures of Scope 3 emissions provided there is a reasonable internal process for estimation.

Source: Callahan et al. (2011[10]), Corporate Value Chain (Scope 3) Accounting and Reporting Standard Supplement to the GHG Protocol Corporate Accounting and Reporting Standard GHG Protocol Team, https://ghgprotocol.org/sites/default/files/standards/Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf; IFRS (2023[11]), IFRS S2 Climate-related Disclosures, https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s2-climate-related-disclosures/#standard.

3.1.2. Mandatory regulatory requirements and voluntary initiatives for unlisted SOEs

In most surveyed countries, unlisted SOEs fall outside mandatory sustainability disclosure requirements applicable to large or listed companies, resulting in fragmented sustainability reporting across the state-owned sector. While some unlisted SOEs may be captured through size or sectoral criteria (e.g. requirements applying to large companies or financial institutions), many are not. This is a material governance issue for state ownership: where disclosure obligations are not public-facing or not standardised, public accessibility may be limited (or disclosures may be confined to government filings), and regulatory oversight may shift from market regulators to line ministries, state-owner entities, or sectoral regulators - often without consistent disclosure scope or comparability.

Partial coverage and notable exceptions

While most frameworks primarily target listed entities, some jurisdictions extend coverage beyond.

• China applies disclosure expectations to listed companies and SOEs, but with coverage that may be limited to large SOEs, alongside broader Ministry of Finance codes and trial standards. Compliance with the proposed Corporate Climate Reporting Standard will initially be voluntary, however the Ministry of Finance has indicated that it will “expand its application from listed companies to non-listed companies [and] from large enterprises to SMEs” (Ministry of Finance of the People's Republic of China, 2026[12]; Segal, 2026[13]).

• India’s Companies Act 2013 mandates large companies to report their CSR activities and spending irrespective of whether they are publicly listed, as further discussed in Table 2.1. and Table 3.1.

• Malaysia places obligations not only on listed issuers but also on certain large unlisted companies, expanding coverage relative to jurisdictions that rely solely on listing status.

• The Philippines has indicated that listed-company and financial-institution sustainability reporting plans should not preclude the development of a reporting framework for GOCCs, and it is also running pilot programmes for GOCCs.

These examples underscore that, even where unlisted SOEs are included, coverage is often partial and defined by thresholds (size, sector, or institutional form), rather than by SOE-specific policy decisions. Viet Nam is an exception in that it has not proposed sustainability-related standards based on IFRS S1 and S2. Currently, many public and listed companies (including some public or listed SOEs) must disclose non-financial information (including sustainability-related information) in annual reports under Circular No. 96/2020/TT-BTC. There are also specific environmental reporting obligations under decrees and circular regulations, which can result in government filings rather than publicly accessible sustainability reports.

Implications for SOE governance

Despite growing alignment with IFRS S1 and S2 across the region, no surveyed country has adopted a fully standardised approach to SOE sustainability-related disclosures.

As set out in Table 3.1, the majority of sustainability-related disclosure obligations of unlisted SOEs have been derived from state-owner expectations and voluntary guidance set out in decrees, circulars, codes, ownership policies, ministry guidance or SOE performance frameworks. This is notably distinct from market regulator requirements, and there is limited evidence of active monitoring and enforcement.

Compliance is phased and piecemeal, which risks inconsistent reporting across SOE portfolios. Disparities in reporting appear to be driven by coverage gaps between listed and unlisted SOEs; uneven or fragmented regulatory expectations (e.g. sector-specific focus, financial institution emphasis); varying degrees of public accessibility (public sustainability reports vs non-public filings); and enterprise-specific capacity limitations.

Initiatives to standardise reporting and promote interoperability of reporting standards will likely reduce some fragmentation. This expected convergence is also relevant to state-owner aggregate reporting practices, as discussed further below in section 3.2.

Phased implementation timelines — especially those determined by market capitalisation or listing status — may also delay SOE alignment with international standards, particularly for unlisted SOEs. To uphold public accountability and facilitate comparability across the state-owned portfolio, governments could consider ensuring that SOEs are included in early compliance phases where feasible and anchored through the application of standards consistent for listed companies.

3.1.3. Independent assurance and verification

The SOE Guidelines recognise that independent assurance of sustainability reporting increases trust in the accuracy and quality of reported data. SOEs should seek to obtain limited or reasonable assurance from an independent, competent, and qualified service provider using robust methodologies. Limited assurance remains more widespread than reasonable assurance among listed companies globally, including among companies that obtain assurance for their Scope 1 and 2 GHG emissions, with under 15% providing reasonable assurance (OECD, 2024[14]).

Across the reviewed jurisdictions, disclosure requirements are advancing faster than assurance requirements. This is expected as assurance markets, issuer readiness, and regulator capacity are being developed. Independent assurance helps to enhance the accountability of state owners and SOEs to the public. Obtaining this assurance should be a priority for SOEs, because sustainability disclosures often serve dual purposes: (i) market transparency (where applicable), and (ii) accountability for the delivery of PPOs, which may include social and environmental goals.

The International Auditing and Assurance Standards Board has published its International Standard on Sustainability Assurance (ISSA) 5000 which provides a framework for both limited and reasonable sustainability assurance engagements other than specific GHG emissions statements, where the International Standards on Assurance Engagements (ISAE) 3410 standard applies. While some jurisdictions including Malaysia have adopted ISSA 5000, adherence to these standards may be too costly or burdensome for some jurisdictions, and accordingly national frameworks should be commensurate to the capacity of both assurance providers and entities.

Requirements for annual assurance attestations can be phased in, as has been reflected in Singapore and Japan’s proposed national sustainability-related assurance frameworks. Thailand and the Philippines are first focusing on assurance over emissions calculations (Scope 1 and 2 GHG emissions).

India already requires independent assurance at a “reasonable” level over the KPIs disclosed under the BRSR framework. A range of providers provide assurance, including statutory auditors, accredited sustainability assurance or assessment service providers, without any accreditation by a public organisation.

Capacity and resourcing constraints are often cited as common explanations for limited disclosure obligations on non-listed entities. Those constraints apply even more strongly to assurance, where SOEs may face shortages of competent assurance providers, internal systems that are not yet audit-ready, and uneven compliance by SOEs to existing reporting requirements.

3.2. Sustainability in aggregate reporting

Aggregate reporting at portfolio level is a critical element of state-owner accountability and performance monitoring. The SOE Guidelines call on ownership entities to report publicly on SOE performance, including non-financial information. Embedding sustainability metrics in aggregate reporting can support policy coherence, enable monitoring of national sustainability targets, and reduce fragmentation across SOE disclosures.

Regular reporting on the activities and performance of SOEs are essential pillars of transparency and accountability. Generally, aggregate reporting practices are more prevalent in countries with centralised or coordinated ownership arrangements with strong coordination and effective oversight practices. The extent to which aggregate reporting captures non-financial information, and specifically sustainability-related information, varies across surveyed countries. Where ownership oversight is centralised and disclosure infrastructure is effective, aggregate reporting or disclosure platforms provide a basis for portfolio-wide comparison.

Thailand’s reporting practices cover both financial and non-financial aspects of SOE performance, with SEPO mandated to publish annual evaluations of SOEs on its website. Notably, these reports do not include information on the achievement of PPOs, which can often be aligned to national sustainability goals. Korea’s consolidated online disclosure platform, ALIO, can be considered an equivalent to aggregate reporting. The MOFE provides a set of guidelines for the types of information to be disclosed by SOEs and reviews the data accordingly. In 2021, the list of disclosure items was expanded to include various social value indicators measuring safety, environment, and social contributions (World Bank, 2022[15]). However, ministerial oversight and enforcement initiatives are mainly focused on whether SOEs have complied with disclosure obligations, rather than assessing the performance trends evident in the information. India collects annual information from its CPSEs with a focus on material financial information, but aggregate reports also cover CSR expenditure and projects, sustainability initiatives and energy efficiency and green practices.

In Viet Nam and Malaysia, portfolio-level sustainability aggregation remains limited. Ownership entities do not yet substantively report climate- or broader sustainability-related issues in an aggregate annual report (OECD, 2020[16]). There is also no underlying dataset that aggregates GHG emissions at a portfolio level in Viet Nam, and disclosures may remain fragmented across sectoral reports, enterprise reports and national strategies. Similarly in Malaysia, a report of the aggregate financial information of major SOEs is published online, but it does not meaningfully cover sustainability-related performance.

To enhance sustainability-related performance and reporting, relevant indicators should be aggregated in state ownership reporting and made publicly available. International practices suggest that portfolio-level sustainability reporting often begins with aggregated GHG emissions, then expands to other indicators (OECD, 2025[17]), with Austria, Finland, Norway and Sweden providing examples of more comprehensive aggregation, including adoption rates of specific sustainability targets (Finland, Sweden), UN SDGs prioritised by SOEs (Finland, Norway) and state-owner performance in meeting specific sustainability goals (Austria).

However, aggregate information is only as strong as the underlying entity-level data. The insights derived from aggregate reporting are limited where there are piecemeal or inconsistent disclosures across the portfolio. The incremental development and coverage of sustainability reporting obligations as outlined above mean that state owners may need to identify and disclose any assumptions, contingencies and dependencies used to inform aggregate reports in the near to medium-term.

References

[10] Callahan, W. et al. (2011), Corporate Value Chain (Scope 3) Accounting and Reporting Standard Supplement to the GHG Protocol Corporate Accounting and Reporting Standard GHG Protocol Team, https://ghgprotocol.org/sites/default/files/standards/Corporate-Value-Chain-Accounting-Reporing-Standard_041613_2.pdf (accessed on 23 March 2026).

[2] GRI (2024), GRI global adoption by top companies continues to grow, https://www.globalreporting.org/news/news-center/gri-global-adoption-by-top-companies-continues-to-grow/ (accessed on 13 October 2025).

[11] IFRS (2023), IFRS S2 Climate-related Disclosures, IFRS Foundation, https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s2-climate-related-disclosures/#standard (accessed on 21 August 2025).

[5] IPSASB (2026), IPSASB SRS 1, Climate-related Disclosures, https://ifacweb.blob.core.windows.net/publicfiles/2026-01/IPSASB-SRS-1-AAG.pdf.

[6] IPSASB SRS (2026), IPSASB SRS1, Climate-related disclosure, https://ifacweb.blob.core.windows.net/publicfiles/2026-01/IPSASB-SRS-1-Climate-related-Disclosures.pdf.

[3] KPMG International (2024), The move to mandatory reporting Survey of Sustainability Reporting 2024 2 | The move to mandatory reporting, https://assets.kpmg.com/content/dam/kpmgsites/xx/pdf/2024/11/the-move-to-mandatory-reporting-web-copy.pdf.coredownload.inline.pdf (accessed on 15 October 2025).

[12] Ministry of Finance of the People’s Republic of China (2026), Notice on the issuance of the Corporate Sustainability Disclosure Standard No. 1 - Climate (Trial)., https://kjs.mof.gov.cn/zhengcefabu/202512/t20251225_3980202.htm (accessed on 7 January 2026).

[1] OECD (2025), OECD Corporate Governance Factbook 2025, OECD Publishing, Paris, https://doi.org/10.1787/f4f43735-en.

[17] OECD (2025), State-Owned Enterprises and Sustainability: Leading by Example, OECD Publishing, Paris, https://doi.org/10.1787/c99c7ef0-en.

[14] OECD (2024), Global Corporate Sustainability Report 2024, OECD Publishing, Paris, https://doi.org/10.1787/8416b635-en.

[16] OECD (2020), Transparency frameworks for state-owned enterprises in Asia, https://doi.org/10.1787/d3f5a12d-en (accessed on 16 October 2025).

[4] SASB (2025), SASB reporters, https://sasb.ifrs.org/company-use/sasb-reporters/ (accessed on 15 October 2025).

[8] SEBI (2023), BRSR Core - Framework for assurance and ESG disclosures for value chain, https://www.sebi.gov.in/legal/circulars/jul-2023/brsr-core-framework-for-assurance-and-esg-disclosures-for-value-chain_73854.html (accessed on 15 October 2025).

[7] SEBI (2021), SEBI Board Meeting, https://www.sebi.gov.in/media/press-releases/mar-2021/sebi-board-meeting_49648.html (accessed on 15 October 2025).

[13] Segal, M. (2026), China Releases Corporate Climate Reporting Standard, ESG Today, https://www.esgtoday.com/china-releases-corporate-climate-reporting-standard/ (accessed on 7 January 2026).

[9] Senate of the Philippines (2024), An Act Establishing the Framework Strategy on Sustainability Reporting Covering Environmental, Social and Governance (ESG) Considerations, Institutionalizing Assurance Therefor, and for Other Purposes, https://www.fsb-tcfd.org/recommendations/. (accessed on 15 October 2025).

[15] World Bank (2022), “Public Reporting on State-Owned Enterprises : Managing the Relationship between SOE Aggregate Reporting and Public Sector Consolidated Financial Statements - A Guidance Note”, https://documents.worldbank.org/pt/publication/documents-reports/documentdetail/099618010192225944 (accessed on 16 October 2025).

Notes

← 1.  As of the end of 2024, IFRS sustainability standards were the second most commonly used sustainability-related disclosure standards by countries surveyed (17%) as part of the OECD Corporate Governance Factbook 2025, behind the European Sustainability Reporting Standards (ESRS) (46%): https://doi.org/10.1787/f4f43735-en.

← 2.  SEBI implemented a phased approach to compliance with BRSR Core: top 150 listed entities for FY23-24; top 250 listed entities for FY24-25; top 500 listed entities for FY25-26; and top 1 000 listed entities for 2026-2027 and onwards. Accordingly, at the time of this report, the top 500 listed entities will be required to comply, but this will increase to the top 1 000 listed entities in future reporting periods.