{ "schemaVersion": "1.0.0", "lastUpdated": "2026-07-24", "scopeNote": "A source-backed comparison of selected major sustainability and climate reporting frameworks and legal requirements. Local law, listing rules, regulator guidance and court decisions remain authoritative.", "records": [ { "id": "eu", "jurisdiction": "EU", "region": "Europe", "status": "Mandatory, scope and standards revised", "scopeSummary": "Large undertakings and certain non-EU groups within the current CSRD scope; confirm the latest thresholds and national implementation.", "firstReportingPeriod": "Phased from 2024, with later cohorts and requirements revised", "reportingBasis": "CSRD and ESRS", "coverage": "Sustainability-wide, double materiality", "scope3Treatment": "Required where material under the applicable ESRS disclosures", "assuranceTreatment": "Limited assurance, subject to the applicable national framework", "regulator": "European Commission and national authorities", "primarySourceUrl": "https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/corporate-sustainability-reporting-directive_en", "guideUrl": "/esg/csrd/" }, { "id": "uk", "jurisdiction": "UK", "region": "Europe", "status": "Mixed: existing duties plus voluntary UK SRS", "scopeSummary": "Existing company, listed issuer, energy and carbon rules continue; UK SRS S1 and S2 are currently available for voluntary use.", "firstReportingPeriod": "Existing requirements vary; future UK SRS duties depend on final regulator rules", "reportingBasis": "Companies Act climate disclosures, FCA rules, SECR and UK SRS", "coverage": "Climate and energy duties today; sustainability-wide UK SRS baseline available", "scope3Treatment": "Depends on the applicable rules and materiality", "assuranceTreatment": "No single economy-wide UK SRS assurance duty yet", "regulator": "UK government and FCA", "primarySourceUrl": "https://www.gov.uk/government/publications/uk-sustainability-reporting-standards-uk-srs-s1-and-uk-srs-s2", "guideUrl": "/esg/uk-srs-ifrs-s2-climate-disclosures/" }, { "id": "us-federal", "jurisdiction": "US federal", "region": "North America", "status": "Federal climate rule proposed for rescission", "scopeSummary": "No settled ISSB-style federal reporting baseline. Public companies must track the SEC rulemaking and other existing disclosure duties.", "firstReportingPeriod": "No current settled start date for the 2024 climate rule", "reportingBasis": "SEC securities disclosure rules and current rulemaking", "coverage": "Climate-related financial disclosure", "scope3Treatment": "Not required by the 2024 SEC final rule", "assuranceTreatment": "Proposed requirements are not a stable current filing timetable", "regulator": "US Securities and Exchange Commission", "primarySourceUrl": "https://www.sec.gov/rules-regulations/rulemaking-activity", "guideUrl": "/esg/sec-climate-disclosure-rules-2026/" }, { "id": "california", "jurisdiction": "California", "region": "North America", "status": "Mandatory state laws under implementation", "scopeSummary": "Large entities doing business in California, subject to the revenue thresholds and current implementation guidance.", "firstReportingPeriod": "First emissions and climate-risk duties are being implemented from 2026", "reportingBasis": "SB 253, SB 261 and SB 219", "coverage": "Emissions and climate-related financial risk", "scope3Treatment": "Included under SB 253, with later timing than Scope 1 and 2", "assuranceTreatment": "Phased assurance for emissions reporting", "regulator": "California Air Resources Board", "primarySourceUrl": "https://ww2.arb.ca.gov/rulemaking/2025/california-corporate-greenhouse-gas-reporting-and-climate-related-financial-risk", "guideUrl": "/esg/california-climate-disclosure-laws-explained/" }, { "id": "brazil", "jurisdiction": "Brazil", "region": "Latin America", "status": "Voluntary, comply or explain", "scopeSummary": "Public companies may use the CBPS and ISSB standards; companies that do not adopt disclose that choice to the market.", "firstReportingPeriod": "Voluntary framework retained after CVM Resolution 244 in May 2026", "reportingBasis": "CVM Resolutions 193 and 244, CBPS and ISSB standards", "coverage": "Sustainability-related financial information", "scope3Treatment": "Follows the adopted standards and applicable reliefs when a company opts in", "assuranceTreatment": "Applies within the voluntary reporting framework where required", "regulator": "Comissao de Valores Mobiliarios", "primarySourceUrl": "https://www.gov.br/cvm/pt-br/assuntos/noticias/2026/cvm-altera-resolucao-193-para-revogar-obrigatoriedade-da-divulgacao-de-informacoes-financeiras-relacionadas-a-sustentabilidade", "guideUrl": null }, { "id": "australia", "jurisdiction": "Australia", "region": "Oceania", "status": "Mandatory, phased", "scopeSummary": "Entities meeting the Corporations Act thresholds enter in three groups, beginning with the largest reporters.", "firstReportingPeriod": "Financial years beginning on or after 1 January 2025, 1 July 2026 or 1 July 2027 by cohort", "reportingBasis": "AASB S2; AASB S1 remains voluntary", "coverage": "Climate-related financial disclosure", "scope3Treatment": "Required under AASB S2, subject to transition relief", "assuranceTreatment": "Phased assurance under the Australian framework", "regulator": "AASB, ASIC and the Australian government", "primarySourceUrl": "https://standards.aasb.gov.au/sustainability-reporting-standards", "guideUrl": "/esg/australia-climate-reporting-rules/" }, { "id": "hong-kong", "jurisdiction": "Hong Kong", "region": "Asia", "status": "Listing rules, phased", "scopeSummary": "Main Board issuers, with earlier mandatory treatment for LargeCap issuers and comply-or-explain phases for others.", "firstReportingPeriod": "Financial years beginning on or after 1 January 2025, with later mandatory phases", "reportingBasis": "HKEX ESG Reporting Code climate requirements", "coverage": "Climate-related disclosure aligned closely with IFRS S2", "scope3Treatment": "Phased and subject to the HKEX implementation reliefs", "assuranceTreatment": "No single mandatory assurance timetable across all issuers", "regulator": "Hong Kong Exchanges and Clearing", "primarySourceUrl": "https://www.hkex.com.hk/News/Regulatory-Announcements/2024/240419news?sc_lang=en", "guideUrl": "/esg/hong-kong-climate-reporting-rules/" }, { "id": "india", "jurisdiction": "India", "region": "Asia", "status": "Mandatory and phased", "scopeSummary": "BRSR applies to the top 1,000 listed entities by market capitalisation; BRSR Core phases across smaller cohorts.", "firstReportingPeriod": "BRSR mandatory from FY 2022-23; BRSR Core phased from FY 2023-24", "reportingBasis": "SEBI BRSR and BRSR Core", "coverage": "Sustainability-wide business responsibility reporting", "scope3Treatment": "Value-chain treatment has been eased and should be checked against the current SEBI circular", "assuranceTreatment": "Assessment or assurance treatment varies by cohort and current SEBI reliefs", "regulator": "Securities and Exchange Board of India", "primarySourceUrl": "https://www.sebi.gov.in/legal/circulars/jul-2023/brsr-core-framework-for-assurance-and-esg-disclosures-for-value-chain_73854.html", "guideUrl": "/esg/india-sustainability-reporting-rules/" }, { "id": "japan", "jurisdiction": "Japan", "region": "Asia", "status": "Mandatory timetable, phased", "scopeSummary": "Prime Market companies enter by market-cap cohort, with the largest groups first.", "firstReportingPeriod": "Phased under the FSA roadmap, beginning with the largest Prime Market companies", "reportingBasis": "SSBJ standards and securities reporting rules", "coverage": "Sustainability-related financial information", "scope3Treatment": "Follows SSBJ climate disclosure requirements and transition reliefs", "assuranceTreatment": "Assurance is planned on a phased path", "regulator": "Financial Services Agency and Sustainability Standards Board of Japan", "primarySourceUrl": "https://www.fsa.go.jp/en/news/2026/20260409/02.pdf", "guideUrl": "/esg/japan-sustainability-reporting-rules/" }, { "id": "malaysia", "jurisdiction": "Malaysia", "region": "Asia", "status": "Mandatory, phased", "scopeSummary": "Large Main Market issuers enter first, followed by other listed issuers and qualifying non-listed companies.", "firstReportingPeriod": "Phased from annual reporting periods beginning on or after 1 January 2025", "reportingBasis": "National Sustainability Reporting Framework using IFRS S1 and IFRS S2", "coverage": "Sustainability-related financial information", "scope3Treatment": "Subject to cohort timing and transitional reliefs", "assuranceTreatment": "Phased assurance pathway under the national framework", "regulator": "Securities Commission Malaysia and Bursa Malaysia", "primarySourceUrl": "https://www.sc.com.my/nsrf", "guideUrl": "/esg/malaysia-sustainability-reporting-rules/" }, { "id": "new-zealand", "jurisdiction": "New Zealand", "region": "Oceania", "status": "Mandatory climate reporting", "scopeSummary": "Large listed issuers, banks, insurers, credit unions and investment managers meeting statutory thresholds.", "firstReportingPeriod": "Accounting periods beginning on or after 1 January 2023", "reportingBasis": "Aotearoa New Zealand Climate Standards", "coverage": "Climate-related disclosure", "scope3Treatment": "Required within greenhouse-gas disclosure, with applicable reliefs", "assuranceTreatment": "Assurance over greenhouse-gas emissions disclosures", "regulator": "External Reporting Board and Financial Markets Authority", "primarySourceUrl": "https://www.xrb.govt.nz/standards/climate-related-disclosures/resources/", "guideUrl": null }, { "id": "singapore", "jurisdiction": "Singapore", "region": "Asia", "status": "Mandatory, phased by company type", "scopeSummary": "Timetables differ for STI constituents, other listed issuers and large non-listed companies.", "firstReportingPeriod": "Climate reporting phases from FY 2025, with later cohorts through 2030", "reportingBasis": "ISSB-aligned climate reporting requirements", "coverage": "Climate-related disclosure", "scope3Treatment": "Deferred or voluntary for several cohorts until further notice", "assuranceTreatment": "External limited assurance phases separately from initial reporting", "regulator": "ACRA, SGX RegCo and Ministry of Finance", "primarySourceUrl": "https://www.acra.gov.sg/regulations/sustainability-reporting/requirements-timeline/", "guideUrl": "/esg/singapore-climate-reporting-rules/" }, { "id": "south-korea", "jurisdiction": "South Korea", "region": "Asia", "status": "Mandatory, phased from 2028", "scopeSummary": "KOSPI companies enter by consolidated-asset cohort, starting with companies at or above KRW10 trillion.", "firstReportingPeriod": "Financial year 2027, reported in 2028 for the first cohort", "reportingBasis": "Korean sustainability disclosure standards and financial-authority roadmap", "coverage": "Sustainability-related financial information", "scope3Treatment": "Delayed three years for each reporting cohort", "assuranceTreatment": "Planned from 2030", "regulator": "South Korean financial authorities and KSSB", "primarySourceUrl": "https://www.fsc.go.kr/eng/pr010101/87276", "guideUrl": "/esg/south-korea-esg-reporting-rules-2028/" } ] }