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China-ISSBBasic Standard (Trial) issued 20 November 2024; Application Guidance issued 3 September 2025; No. 1 – Climate (Trial) issued 19 December 2025; voluntary application until implementation scope and requirements are specified

Local adoption of IFRS S1 / S2 (ISSB Standards)

China · Ministry of Finance of the People's Republic of China

The Ministry of Finance, with other ministries, issued the Sustainability Disclosure Standards for Business Enterprises – Basic Standard (Trial) in November 2024 and No. 1 – Climate (Trial) in December 2025, as the first parts of a unified national system that converges with ISSB Standards. Companies may apply them voluntarily until authorities set the scope; the system is to be basically in place by 2030.

Category
ISSB-aligned sustainability disclosure
Enforcement
Voluntary or under development
Effective date
Not yet specified. The Basic Standard (20 November 2024) and Climate Standard (19 December 2025) may be applied voluntarily until the implementation scope and requirements are specified. MoF plans to issue the Basic Standard, Climate Standard and Application Guidance by 2027, with the unified national system basically established by 2030.
Covered entities
To be determined. Intended to apply first to listed companies and then expand gradually to non-listed companies, from large companies to SMEs, and from voluntary to mandatory disclosure
Notes
Verified against the IFRS Foundation jurisdictional snapshot updated 18 June 2026. The Climate Standard does not require reference to SASB Standards or IFRS S2 industry-based guidance; industry application guidance is in development. Stock exchange sustainability reporting guidelines run separately.

Sources

Related regulations

In force; sectoral pilots ongoing

China's EPR Implementation Plan tasks manufacturers in four sectors (electronics, automobiles, lead-acid batteries and packaging) with eco-design, recycled-content use, take-back networks and information disclosure, coordinated nationally by NDRC. WEEE recycling runs through a separate treatment fund under State Council Decree 551. Since 1 April 2026, NEV power battery makers and vehicle manufacturers carry take-back, coding and reporting duties under Order No. 73.

Enforcement
Mandatory for listed sectors
Effective date
EPR Implementation Plan published 3 January 2017; WEEE Regulations effective 1 January 2011; NEV power battery Interim Measures (Order No. 73) in force 1 April 2026, replacing the 2018 interim measures; Ecological Environment Code in force 15 August 2026
Covered entities
Manufacturers of four product categories under the 2017 Plan: electrical and electronic equipment, automobiles, lead-acid batteries and packaging (mainly e-commerce and express delivery packaging); under Order No. 73, power battery makers and importers and NEV manufacturers, which must code batteries, run collection service points, report through the national traceability platform and hand waste batteries to qualified recyclers
Primary source ↗Verified 2026-09-23
Effective. Group 1 has reported since financial years beginning 1 January 2025 and Group 2 since financial years beginning 1 July 2026. Treasury is consulting on changes to reduce reporting costs (closes 2 October 2026).

Australia has adopted ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory for entities within Chapter 2M of the Corporations Act and is phased in across three groups from 2025 to 2027. AASB S1 (general sustainability) is voluntary. ASIC administers the regime and has published guidance in RG 280.

Enforcement
AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.
Effective date
Financial years beginning on or after 1 January 2025 (Group 1), 1 July 2026 (Group 2) and 1 July 2027 (Group 3). AASB S2025-1 amendments apply to annual periods beginning on or after 1 January 2027, with early application permitted.
Covered entities
Entities that must prepare annual financial reports under Chapter 2M of the Corporations Act and meet a s292A threshold. Group 1: at least two of consolidated revenue of AUD 500m or more, consolidated gross assets of AUD 1bn or more, and 500 or more employees; or NGER registered corporations in groups that meet the s13(1)(a) NGER threshold. Group 2: at least two of revenue of AUD 200m or more, assets of AUD 500m or more, and 250 or more employees; all other NGER registered corporations; and registered schemes, RSEs and retail CCIVs with assets of AUD 5bn or more. Group 3: at least two of revenue of AUD 50m or more, assets of AUD 25m or more, and 100 or more employees.
UK-SRS

UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2)

United Kingdom · UK Government (Department for Business, Innovation, Science and Trade, renamed from DBT in July 2026) / FRC; FCA for listed-entity application
Final standards published 25 February 2026 for voluntary use; FCA consultation CP26/5 closed 20 March 2026; FCA policy statement expected autumn 2026 (not published as of 23 September 2026)

UK SRS S1 and S2 are the UK government's endorsed versions of IFRS S1 and S2, published on 25 February 2026 for voluntary use. Voluntary users can apply the Scope 3 and non-climate reliefs with no time limit. The FCA has consulted on listing rules that would make UK SRS S2 climate reporting mandatory for listed companies, with Scope 3 emissions and UK SRS S1 non-climate reporting on a comply-or-explain basis.

Enforcement
Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).
Effective date
Voluntary use: no effective date (entities apply the standards when they choose). FCA proposal, subject to the final policy statement: rules in force 1 January 2027 for accounting periods beginning on or after 1 January 2027; using the transitional reliefs, Scope 3 reporting from periods beginning on or after 1 January 2028 and UK SRS S1 non-climate reporting from periods beginning on or after 1 January 2029.
Covered entities
Any entity (voluntary). The FCA proposal covers issuers in the commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16), transition (UKLR 22), secondary listing (UKLR 14) and depositary receipts (UKLR 15) categories. No mandate yet for unlisted companies.
Canada-CSDS

CSDS 1 and CSDS 2 – Canadian Sustainability Disclosure Standards

Canada · Canadian Sustainability Standards Board (CSSB), under FRAS Canada
Final standards published (voluntary); CSA mandatory rule paused since April 2025 (no resumption found); CSDS 2 GHG emissions amendments proposed April 2026

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. The standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025. In April 2026 the CSSB proposed CSDS 2 amendments matching the ISSB's IFRS S2 amendments: limiting Scope 3 Category 15 to financed emissions, allowing an industry classification other than GICS, and allowing other GHG measurement methods or GWP values where a jurisdictional authority or exchange requires them.

Enforcement
Voluntary
Effective date
Standards effective for annual reporting periods beginning on or after 1 January 2025, for entities that choose to apply them (with transition reliefs). Voluntary; no mandatory reporting date exists.
Covered entities
Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.
Japan-SSBJ

SSBJ Sustainability Disclosure Standards (Application, General, Climate)

Japan · Sustainability Standards Board of Japan (SSBJ)
Final standards published 5 March 2025; mandatory under the FSA's Cabinet Office Order amendment promulgated 20 February 2026, first cohort from the fiscal year ending March 2027

SSBJ published its Application, General and Climate Standards on 5 March 2025, and the SSBJ and ISSB confirm they are functionally aligned with IFRS S1 and S2. The FSA amended the Cabinet Office Order on Disclosure of Corporate Affairs on 20 February 2026 to require SSBJ-based disclosures in Annual Securities Reports for large Prime Market companies from the fiscal year ending March 2027, with third-party assurance one year later.

Enforcement
Mandatory for Tokyo Stock Exchange Prime Market companies, phased by market cap, through Annual Securities Reports under the Cabinet Office Order on Disclosure of Corporate Affairs. Voluntary for other entities.
Effective date
Voluntary for annual periods ending on or after 5 March 2025. Mandatory for Prime Market companies by average market cap (average of the last five fiscal year-ends): ¥3 trillion or more from the fiscal year ending March 2027; ¥1 trillion or more from the fiscal year ending March 2028; ¥500 billion or more from the fiscal year ending March 2029. Timing for other Prime Market companies to be decided later. Mandatory assurance starts one year after each cohort's first mandatory year.
Covered entities
Tokyo Stock Exchange Prime Market companies with average market capitalization of ¥500 billion or more, in three cohorts (¥3 trillion, ¥1 trillion, ¥500 billion). Timing for other Prime Market companies not yet set.
HongKong-HKFRS

HKFRS S1 and HKFRS S2 – Hong Kong Sustainability Disclosure Standards

Hong Kong · Hong Kong Institute of Certified Public Accountants (HKICPA)
Adopted (effective 1 August 2025; voluntary use until mandated by relevant authority)

HKICPA published HKFRS S1 and HKFRS S2 on 12 December 2024, fully aligned with IFRS S1 and S2. The Hong Kong SAR Government's December 2024 Roadmap sets out the phased path to mandatory adoption for publicly accountable entities.

Enforcement
Voluntary at HKICPA level. The Hong Kong SAR Government's roadmap (10 December 2024) sets out phased mandatory adoption for publicly accountable entities.
Effective date
Annual reporting periods beginning on or after 1 August 2025
Covered entities
Any Hong Kong entity (voluntary). Mandatory phased rollout per government roadmap.