Your guide to countries with corporate climate disclosure mandates
Companies will need to stay ahead of the curve to know where in the world they will be required to disclose climate information in coming years. Here's our playbook. Read More
As executives gear up for 2025, we thought it would be useful to highlight where in the world corporate climate disclosure mandates are in place, and where mandates are under consideration. The European Union, 10 other countries and California have requirements, with six countries considering enacting mandates.
Here’s our roundup to help you comply with the regulations on the books, including timelines, how a country defines “material” (whether it requires a country to disclose a single or double materiality assessment), and other requirements.
For simplicity’s sake, its important to define single vs. double materiality upfront.
- Single materiality: Measures how climate-related risks and/or opportunities impact a company’s financial performance or position.
- Double materiality: Measures the effect a company has on the climate and environment, in addition to measuring the impact these same factors have on its financial performance.
Countries with laws in effect
Brazil
CVM Resolution 193
Who does it affect: Publicly held companies, investment funds and securitization companies.
What must be reported: Affected companies follow the basic guidelines laid out by the IFRS Foundation’s International Sustainability Standards Board (ISSB), which includes data gathered from a company’s Scope 1, 2 and 3 emissions.
Materiality: Single materiality is required.
Timeline: Announced in 2023, companies were encouraged to begin reporting in 2024 on a voluntary basis, with mandatory reporting beginning in 2026. As of 2027, all sustainability reporting will be due within three months of the close of the financial year.
China
PRC Sustainability Reporting Guidelines
Who does it affect: Any company listed on the Shanghai Stock Exchange 180 (SSE) or the Star 50 Index, or listed simultaneously in Chinese Mainland and overseas markets.
What must be reported: A company must report its GHG emissions including Scope 1 and 2, with Scope 3 encouraged but not required. Also, any carbon credits used must be disclosed and the source requiring the initial purchase of the carbon credits.
Materiality: Double materiality.
Timeline: Reporting begins in 2025, with the first round of published findings due in 2026.
The European Union
Corporate Sustainability Reporting Directive (CSRD)
Who does it affect: Public and private companies operating within the EU, as well as non-EU based companies operating within an EU member-state with at least one subsidiary or branch and a net turnover greater than $157 million (150 million euro).
What must be reported: Scope 1, 2 and 3 emissions. If Scope 3 emissions are not deemed “material,” then the company must also submit an explanation as to how those emissions are not material.
Materiality: Double materiality.
Timeline: Large EU companies began reporting in 2024, with all companies, regardless of size, mandated to begin reporting in 2028 at the latest.
Hong Kong
Who does it affect: Any company list on the Hong Kong Exchanges and Clearing (HKEX).
What must be reported: Affected companies will follow the ISSB standards as much as possible in its reporting, submitting Scope 1 and 2 impacts, along with Scope 3 if its deemed financially material. Companies that are a part of the Hang Seng Composite LargeCap Index (HSCLI) must report Scope 3 emissions.
Materiality: Single materiality.
Timeline: Data gathering begins in 2025, and companies with HSCLI must begin reporting on Scope 3 beginning 2026.
Nigeria
Financial Reporting Council Act (FRC Act) of Nigeria, section 8(h)
Who does it affect: Public and private companies in Nigeria, including Small and Medium-sized Enterprises (SMEs).
What must be reported: Companies will follows the ISSB standards, reporting Scope 1, 2 and 3 emissions.
Materiality: Single materiality.
Timeline: Mandatory reporting begins in 2028, with companies that have chosen to disclose beginning as early as 2023.
New Zealand
Aotearoa New Zealand Climate Standards 1, 2 and 3
Who does it affect: Large companies listed on the New Zealand Stock Exchange (NZX) with a market capitalization of more than $60 million, large registered banks, licensed insurers, credit unions, building societies and managers of investment schemes.
What must be reported: Companies must report Scope 1, 2 and 3 emissions.
Materiality: Single materiality.
Timeline: Scope 1 and 2 reporting began in 2023, with Scope 3 reporting beginning for 2024.
Singapore
Mandatory Climate Reporting and Assurance Roadmap for Singapore
Who does it affect: All listed issuers, and all public and private listed companies with an annual revenue of $1 billion Singapore dollars and total assets of $500 million as of 2027.
What must be reported: Companies will follow the ISSB reporting standards and must report Scope 1, 2 and 3 emissions.
Materiality: Single materiality.
Timeline: Public companies must report Scope 1 and 2 emissions in 2025, and Scope 3 emission in 2026. Large private companies must report Scope 1 and 2 emission in 2027, with Scope 3 beginning in 2029.
Switzerland
Who does it affect: Public companies, banks, and insurance companies with at least 500 employees and at least $22.6 million (CHF 20 million) in total assets, or more than $45.3 million (CHF 40 million) in turnover.
What must be reported: Originally, companies were required to report on climate-related factors including Scope 1, 2 and 3 emissions and risks. The Swiss Federal Council recently proposed new guidance for corporate disclosure to align its law closer to the EU’s CSRD while also requiring companies to submit “net-zero roadmaps,” detailing plans to reach net zero emissions by 2050, in compliance with Switzerlands recently passed Climate and Innovation Act.
Materiality: Double materiality.
Timeline: The Climate Ordinance has been in effect as of 2024 for all companies.
Turkey
Turkish Sustainability Reporting Standards (TSRS)
Who does it affect: While a member of the EU, it has its own distinct requirements. All banks except those under the Saving Deposit Insurance Fund (SDIF) and companies that meet at least two of the following three criteria; total assets of $1.43 million (TRY 500 million), annual net sales revenue of $28.7 million (TRY 1 billion), and/or over 250 employees.
What must be reported: Affected companies must submit Scope 1, 2 and 3 emissions.
Materiality: Single materiality.
Timeline: Reporting for Scope 1 and 2 emissions began in 2024, with first reports due in 2025. Companies are not required to report Scope 3 in the first two years of reporting.
United Kingdom
Streamlined Energy and Carbon Reporting (SECR)
Who does it affect: Public and private companies with over $636 million (500 million pounds) in turnover and at least 500 employees. Smaller public and private companies that meet at least two of the following three criteria; turnover of $45.8 million (36 million pounds), gross assets of at least $22.9 million (18 million pounds), and/or at least 250 employees.
What must be reported: Scope 1 and 2 emissions must be reported, with Scope 3 only if deemed financially material.
Materiality: Single materiality.
Timeline: Implementation is expected to begin in 2026.
And one state …
California
Climate Accountability Acts SB 253 & SB 261
Who does it affect: SB 253 and SB 261 each affect specific groups, although both exclusively refer to companies that do business in California. SB 253 affects public and private companies with an annual revenue of at least $1 billion, while SB 261 affects public and private companies with an annual revenue of $500 million.
What must be reported: A company must report its Scope 1, 2 and 3 emissions, along with its related risk due to climate.
Materiality: Single materiality.
Timeline: Scope 1 and 2 emissions are due in 2026 on the fiscal year 2025, with Scope 3 emissions due in 2027. The first climate-related risk report is due in 2026, and then expected biennially moving forward.
Countries with corporate disclosure laws still in process
Australia
Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024
What you need to know: The Australian Senate passed the Treasury Laws Amendment in August, which would mandate organizations already required to prepare financial reports under Chapter 2M of the 2001 Corporates Act, submit climate-related financial disclosures beginning Jan.1. The bill passed the House and is waiting for formal assent.
Canada
Canada Business Corporations Act (CBCA) amendment
What you need to know: Canada’s Dept. of Finance announced intentions to mandate climate-related corporate disclosures in October in an effort to meet the country’s net-zero emissions goal by 2050. The rule will primarily apply to large federally incorporated companies at first, although Canada’s government is working on plans to incorporate SMEs in the future.
Chile
General Regulations (NCG) No. 461
What you need to know: In August, Chile’s Financial Market Commission proposed amendments to incorporate sustainability and corporate governance requirements into existing law, following ISSB standards. The law is still in the consultation phase and no timeline exists yet.
India
Draft Disclosure Framework on Climate-related Financial Risks
What you need to know: Introduced in February, the proposed law would impact all commercial banks and other financial institutions. If passed, reporting would begin for financial year 2025.
Japan
Sustainability Disclosure Standards
What you need to know: In March, the Sustainability Standards Board of Japan (SSBJ) announced drafts of proposed new rules for corporate climate disclosure mandates, which would ostensibly follow the ISSB standard in implementation. A timeline for finalization is still up in the air.
United States
The Enhancement and Standardization of Climate-Related Disclosures for Investors
What you need to know: The United State’s climate disclosure law, issued by the Securities and Exchange Commission in May, is officially paused as it was immediately challenged in courts upon implementation. If it successfully makes it through litigation, U.S. companies traded on the U.S. stock exchange will be required to disclose climate-related risks and Scope 1 and 2 emissions.
[Learn what’s next in decarbonization, disclosure, nature and more at GreenBiz 25 — our premier sustainability event, Feb. 10-12, Phoenix.]
