Environmental, social and governance reporting is converging around common standards, but it is not becoming one global filing rule. Company thresholds, start dates, Scope 3 reliefs and assurance duties still depend on the jurisdiction.
Use this directory to compare reporting rules across 13 major jurisdictions, identify the rule owner and open the relevant regulator source or detailed TPB guide. International Sustainability Standards Board (ISSB) alignment is shown separately from the local duty to file.
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Detailed reporting guides
2 jurisdictions
Europe
The EU and UK share some reporting architecture, but current filing duties, thresholds and assurance routes remain different.
| Jurisdiction | Status | Who is in scope | Timing and basis | Scope 3 and assurance | Source and guide |
|---|---|---|---|---|---|
| EUSustainability-wide | Mandatory, scope and standards revised | Large undertakings and certain non-EU groups within the current CSRD scope; confirm the latest thresholds and national implementation. | Phased from 2024with later cohorts and requirements revised | Required where material under the applicable ESRS disclosures Limited assurance, subject to the applicable national framework | European Commission and national authoritiesRead the CSRD guide |
| UKMixed framework | Mixed: existing duties plus voluntary UK SRS | Existing company, listed issuer, energy and carbon rules continue; UK SRS S1 and S2 are currently available for voluntary use. | Existing requirements vary; future UK SRS duties depend on final regulatorExisting requirements vary; future UK SRS duties depend on final regulator rules | Depends on the applicable rules and materiality No single economy-wide UK SRS assurance duty yet | UK government and FCARead the UK SRS guide |
3 jurisdictions
The Americas
Federal, state and securities-market rules create distinct reporting routes across the US, California and Brazil.
| Jurisdiction | Status | Who is in scope | Timing and basis | Scope 3 and assurance | Source and guide |
|---|---|---|---|---|---|
| US federalFederal climate rule | Federal climate rule proposed for rescission | No settled ISSB-style federal reporting baseline. Public companies must track the SEC rulemaking and other existing disclosure duties. | No current settled start date for the 2024 climate ruleSEC securities disclosure rules and current rulemaking | Not required by the 2024 SEC final rule Proposed requirements are not a stable current filing timetable | US Securities and Exchange CommissionRead the SEC guide |
| CaliforniaCAState climate laws | Mandatory state laws under implementation | Large entities doing business in California, subject to the revenue thresholds and current implementation guidance. | First emissions and climate-risk duties are being implemented from 2026SB 253, SB 261 and SB 219 | Included under SB 253, with later timing than Scope 1 and 2 Phased assurance for emissions reporting | California Air Resources BoardRead the California guide |
| BrazilISSB-based option | Voluntary, comply or explain | Public companies may use the CBPS and ISSB standards; companies that do not adopt disclose that choice to the market. | Voluntary framework retained after CVM Resolution 244 in May 2026CVM Resolutions 193 and 244, CBPS and ISSB standards | Follows the adopted standards and applicable reliefs when a company opts in Applies within the voluntary reporting framework where required | Comissao de Valores Mobiliarios |
8 jurisdictions
Asia-Pacific
Several jurisdictions use ISSB standards as a baseline, but company thresholds, start dates and transition reliefs differ.
| Jurisdiction | Status | Who is in scope | Timing and basis | Scope 3 and assurance | Source and guide |
|---|---|---|---|---|---|
| AustraliaClimate reporting | Mandatory, phased | Entities meeting the Corporations Act thresholds enter in three groups, beginning with the largest reporters. | Financial years beginning on or after 1 January 20251 July 2026 or 1 July 2027 by cohort | Required under AASB S2, subject to transition relief Phased assurance under the Australian framework | AASB, ASIC and the Australian governmentRead the Australia guide |
| Hong KongListing rules | Listing rules, phased | Main Board issuers, with earlier mandatory treatment for LargeCap issuers and comply-or-explain phases for others. | Financial years beginning on or after 1 January 2025with later mandatory phases | Phased and subject to the HKEX implementation reliefs No single mandatory assurance timetable across all issuers | Hong Kong Exchanges and ClearingRead the Hong Kong guide |
| IndiaBRSR and BRSR Core | Mandatory and phased | BRSR applies to the top 1,000 listed entities by market capitalisation; BRSR Core phases across smaller cohorts. | BRSR mandatory from FY 2022-23; BRSR Core phased from FY 2023-24SEBI BRSR and BRSR Core | Value-chain treatment has been eased and should be checked against the current SEBI circular Assessment or assurance treatment varies by cohort and current SEBI reliefs | Securities and Exchange Board of IndiaRead the India guide |
| JapanSSBJ standards | Mandatory timetable, phased | Prime Market companies enter by market-cap cohort, with the largest groups first. | Phased under the FSA roadmapbeginning with the largest Prime Market companies | Follows SSBJ climate disclosure requirements and transition reliefs Assurance is planned on a phased path | Financial Services Agency and Sustainability Standards Board of JapanRead the Japan guide |
| MalaysiaNSRF | Mandatory, phased | Large Main Market issuers enter first, followed by other listed issuers and qualifying non-listed companies. | Phased from annual reporting periods beginning on or after 1 January 2025National Sustainability Reporting Framework using IFRS S1 and IFRS S2 | Subject to cohort timing and transitional reliefs Phased assurance pathway under the national framework | Securities Commission Malaysia and Bursa MalaysiaRead the Malaysia guide |
| New ZealandClimate reporting entities | Mandatory climate reporting | Large listed issuers, banks, insurers, credit unions and investment managers meeting statutory thresholds. | Accounting periods beginning on or after 1 January 2023Aotearoa New Zealand Climate Standards | Required within greenhouse-gas disclosure, with applicable reliefs Assurance over greenhouse-gas emissions disclosures | External Reporting Board and Financial Markets Authority |
| SingaporeISSB-aligned climate rules | Mandatory, phased by company type | Timetables differ for STI constituents, other listed issuers and large non-listed companies. | Climate reporting phases from FY 2025with later cohorts through 2030 | Deferred or voluntary for several cohorts until further notice External limited assurance phases separately from initial reporting | ACRA, SGX RegCo and Ministry of FinanceRead the Singapore guide |
| South KoreaKSSB roadmap | Mandatory, phased from 2028 | KOSPI companies enter by consolidated-asset cohort, starting with companies at or above KRW10 trillion. | Financial year 2027reported in 2028 for the first cohort | Delayed three years for each reporting cohort Planned from 2030 | South Korean financial authorities and KSSBRead the South Korea guide |
Comparison notes
Where the rules differ
The same standard name can lead to different reporting work once local thresholds, filing locations and transition reliefs are applied.
Law, listing rule or voluntary standard
A standard can be available without being mandatory. The UK and Brazil currently illustrate why availability and filing duty need separate checks.
Climate-only or sustainability-wide
Australia and New Zealand focus on climate disclosure. EU reporting reaches across environmental, social and governance topics through double materiality.
Reporting period or filing date
A rule often applies to a financial year before the report appears. Map the first period in scope separately from the first publication deadline.
Scope 3 relief
Scope 3 can be mandatory, deferred, voluntary or tied to materiality. ISSB alignment alone does not identify the first year for value-chain emissions.
Assurance
Some frameworks phase limited assurance after reporting begins. Others cover only emissions or have not settled an economy-wide timetable.
Group and foreign-issuer scope
Revenue, assets, listing status and local activity can bring an overseas group into scope. The current local rule remains decisive.
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Standards, dates and evidence
The directory compares jurisdictions. These guides cover standards, filing calendars and the controls behind the disclosures.
Sources and directory data
Records checked 24 July 2026 against the regulator or standard-setter source linked in each row. The directory is updated when a final rule, timetable, threshold, transition relief or assurance requirement changes.
Information only. This comparison is not legal, accounting or assurance advice. Reporting scope can depend on group structure, listing status, revenue, assets, local activity and reporting period. Check the current rule and qualified advice before making a filing decision.