What applies to us?

The TNFD Recommendations set out 14 disclosure recommendations covering governance, strategy, risk and impact management, and metrics and targets for nature-related risks and opportunities, structured to align with the TCFD and ISSB. Adoption is voluntary, with the LEAP approach offered as the assessment method.

Enforcement

Voluntary

Effective date

18 September 2023

Covered entities

Any organisation, financial or non-financial, that chooses to adopt the framework. Over 500 organisations have committed as TNFD Adopters

The ISSB is developing incremental nature-related disclosure requirements that will supplement IFRS S1 and IFRS S2, drawing on the TNFD Recommendations. The Board is targeting an Exposure Draft before CBD COP17 in October 2026.

Enforcement

Voluntary until adopted by jurisdictions

Effective date

Exposure Draft expected 2026; final standard to follow

Covered entities

Companies applying IFRS Sustainability Disclosure Standards; scope to be defined in the Exposure Draft

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. Standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025.

Enforcement

Voluntary

Effective date

Annual reporting periods beginning on or after 1 January 2025 (with transition reliefs)

Covered entities

Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.

Brazil adopted Portuguese-language versions of IFRS S1 and S2 (CBPS 01 and CBPS 02) developed by the Brazilian Sustainability Pronouncements Committee, with CVM, CMN and BCB resolutions phasing in voluntary use from 2024 to 2025 and mandatory application from 2026 to 2028 depending on the entity.

Enforcement

Mandatory

Effective date

Voluntary: FY beginning on or after 1 January 2024 (ISSB) or 1 January 2025 (CBPS). Mandatory: 1 January 2026 for publicly held companies and S1/S2 financial institutions; 1 January 2028 for other financial institutions reporting consolidated statements under international standards

Covered entities

Publicly held companies, investment funds, securitisation companies (CVM scope), and financial institutions and other institutions authorised to operate by BCB; mandatory application sequenced by prudential segment (S1/S2 first, others by 2028)

Chile's Financial Market Commission published General Rule No. 519 in October 2024 requiring CMF-regulated entities to apply IFRS S1 and S2 from reporting periods starting in 2026, replacing the existing TCFD and SASB-based regime under Rule 461.

Enforcement

Mandatory

Effective date

Annual reporting periods beginning in 2026, first reported in 2027 (CMF General Rule No. 519). TCFD/SASB disclosures under Rule 461 currently apply, with effective dates from 2022 to 2025 depending on size and sector

Covered entities

All listed entities supervised by CMF and non-listed publicly accountable entities under CMF supervision, except entities with consolidated assets at or below 1 million Chilean Units of Account (about USD 40 million) and certain financial market infrastructure firms

Mexico's CNBV amended the Circular Unica de Emisoras in January 2025 to require non-financial securities issuers to disclose IFRS S1 and S2 information, with the first reports due in 2026 for fiscal year 2025; rules for financial institutions are being developed separately.

Enforcement

Mandatory

Effective date

CUE modifications took effect 29 January 2025; first sustainability-related disclosures due in 2026 for the 2025 fiscal year

Covered entities

Issuers of equity, debt and other securities supervised by CNBV, excluding listed financial institutions, states and municipalities. Non-financial entities currently in scope represented around 86% of the main equity index market capitalisation at the end of Q1 2025

In April 2024, Bolivia's CTNAC approved Resolution 01/2024 adopting all current and future ISSB Standards for entities operating in Bolivia, effective for fiscal years starting on or after 1 January 2027 and pending legal endorsement by AEMP.

Enforcement

Voluntary or under development

Effective date

Resolution CTNAC 01/2024 set to take effect for fiscal years starting on or after 1 January 2027; early voluntary application is permitted

Covered entities

To be determined pending regulatory approval; CTNAC Resolution 01/2024 contemplates application by all entities that carry out economic activities throughout Bolivia

In January 2024 the Institute of Public Accountants of Costa Rica adopted IFRS S1 and S2 through Circular 33 (amended January 2025), with voluntary application from 2024 and mandatory application from 2027 for CONASSIF-supervised entities and large taxpayers.

Enforcement

Voluntary or under development

Effective date

Voluntary: fiscal years beginning on or after 1 January 2024. Mandatory: fiscal years beginning on or after 1 January 2027, first reported in 2028

Covered entities

Mandatory application limited to publicly accountable entities supervised by CONASSIF (covering SUGEVAL, SUGEF, SUPEN and SUGESE) and entities classified as 'large taxpayers' by the tax authority. Other entities applying IFRS Accounting Standards may apply voluntarily; IFRS for SMEs reporters and government entities supervised by the National Accounting Authority are excluded

In August 2024 El Salvador's Supervisory Board for Public Accounting (CVPCPA) issued Resolution 82 permitting voluntary application of IFRS S1 and S2 from 1 January 2025, with mandatory rules for publicly accountable entities pending from the Central Reserve Bank.

Enforcement

Voluntary or under development

Effective date

Voluntary application permitted from 1 January 2025; mandatory effective date not yet specified

Covered entities

Resolution 82 applies to non-publicly accountable entities preparing financial statements under IFRS Accounting Standards or other generally accepted principles; IFRS for SMEs reporters are excluded. Rules for publicly accountable entities are pending from the Central Reserve Bank (BCR)

California law requiring large companies doing business in the state to disclose Scope 1, 2, and 3 emissions on a phased schedule. CARB is finalizing implementation rules.

Enforcement

Mandatory

Effective date

First Scope 1 & 2 reports due 2026; Scope 3 from 2027

Covered entities

US companies doing business in California with revenue >$1bn

California law requiring in-scope companies to publish a biennial climate-related financial risk report aligned with the TCFD framework or an equivalent.

Enforcement

Mandatory

Effective date

First report due 1 January 2026

Covered entities

US companies doing business in California with revenue >$500m

OSFI guideline setting expectations for climate risk governance, strategy, risk management, scenario analysis, and capital and liquidity adequacy at federally regulated financial institutions. Includes financial disclosure expectations being aligned with CSSB's CSDS standards.

Enforcement

Mandatory for federally regulated financial institutions

Effective date

Fiscal year-end 2024 for D-SIBs and IAIGs headquartered in Canada. Fiscal year-end 2025 for all other in-scope FRFIs.

Covered entities

All federally regulated financial institutions (FRFIs)

New York legislation modeled on California SB 253 requiring large companies doing business in the state to disclose Scope 1, 2, and 3 emissions on a phased schedule with independent verification. Passed the NY Senate in February 2026 and is before the Assembly.

Enforcement

Mandatory if enacted

Effective date

If enacted: regulations by 31 December 2026; Scope 1+2 reporting from 2027; Scope 3 from 2028

Covered entities

US public and private companies with annual revenues >$1bn doing business in New York

The Green Guides set out how the FTC will interpret Section 5 of the FTC Act when reviewing environmental marketing claims, covering general principles such as substantiation and qualification, plus specific claim types including recyclable, compostable, degradable, carbon offsets and renewable energy. Marketers who do not follow the Guides risk deception findings.

Enforcement

Guidance (interpreting Section 5 of the FTC Act)

Effective date

Current text issued October 2012; revision date TBD

Covered entities

Any marketer making environmental claims about a product, package or service in US commerce

The amendments add two new deceptive marketing provisions targeting environmental claims: product-level claims about benefits for protecting or restoring the environment must be backed by adequate and proper testing, and business-level claims about environmental performance must be based on adequate and proper substantiation in line with internationally recognised methodology. Penalties reach the greater of CAD 10 million for a first offence or 3 percent of worldwide gross revenues.

Enforcement

Mandatory

Effective date

20 June 2024

Covered entities

Any person making representations to the public in Canada about a product, business or business activity that relate to environmental or social benefits or effects

Importers must rebut the presumption by clear and convincing evidence that goods were not made wholly or in part with forced labour, including full supply chain tracing, due diligence, and responses to CBP requests for information. CBP detains, excludes, or seizes non-compliant shipments and publishes operational guidance and the FLETF strategy.

Enforcement

Mandatory

Effective date

23 December 2021 (enacted); 21 June 2022 (rebuttable presumption); UFLPA Entity List updated periodically (most recent listed update in DHS records: 15 January 2025; 144 entities)

Covered entities

Any importer of record bringing goods into the United States. Goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by entities on the UFLPA Entity List, are presumed to be made with forced labour and barred under 19 U.S.C. § 1307.

Issuers must conduct a reasonable country of origin inquiry, file an annual Form SD, and where minerals may originate in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources, conduct supply chain due diligence under the OECD Guidance and file a Conflict Minerals Report. Since 2017 SEC staff has not recommended enforcement of the independent private sector audit or DRC-conflict status conclusions.

Enforcement

Mandatory

Effective date

First reports required for calendar year 2013 (Form SD filed by 31 May 2014); annual filings continue. 2017 staff guidance partially limits enforcement.

Covered entities

SEC-registered issuers (domestic and foreign private issuers) for which conflict minerals (tantalum, tin, tungsten, gold) are necessary to the functionality or production of a product they manufacture or contract to manufacture.

In-scope entities and government institutions must file an annual report to the Minister of Public Safety by 31 May describing the steps taken in the prior financial year to prevent and reduce forced labour and child labour risks in their activities and supply chains, and publish the report on their website. The Act amends the Customs Tariff to prohibit imports of goods made with forced or child labour. Offences carry fines up to CAD 250,000 and director/officer liability.

Enforcement

Mandatory

Effective date

1 January 2024; first annual reports due by 31 May 2024 and each 31 May thereafter

Covered entities

Government institutions producing, purchasing, or distributing goods, plus 'entities' (corporations, trusts, partnerships, or other unincorporated organisations) that are listed on a Canadian stock exchange, or have a place of business in Canada, do business in Canada, or have assets in Canada and meet at least two of: CAD 20 million in assets, CAD 40 million in revenue, or 250 employees on average (worldwide, in at least one of the two most recent financial years), and are involved in producing, importing, or distributing goods.

The UK government has endorsed IFRS S1 and S2 as UK SRS S1 and S2 for voluntary use. The FCA is consulting on listing rules that would make UK SRS S2 mandatory for listed issuers, with Scope 3 and non-climate sustainability 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

TBD pending FCA listing-rule outcome

Covered entities

Any UK entity (voluntary). FCA proposal targets in-scope listed issuers.

Türkiye incorporated IFRS S1 and S2 fully into Turkish law as TSRS 1 and TSRS 2 on 29 December 2023, with mandatory application starting fiscal year 2024 for listed entities, banks and other entities exceeding specified size thresholds.

Enforcement

Mandatory

Effective date

Fiscal periods starting on or after 1 January 2024

Covered entities

All listed entities, banks (regardless of size, except banks within the Savings Deposit Insurance Fund and small unlisted banks with one branch or fewer than 250 employees), and other entities exceeding two of three thresholds in two consecutive periods (total assets TRY 500m, total revenue TRY 1bn, 250 employees), including CMB-regulated investment firms and BRSA-regulated financial institutions

Switzerland is consulting on amendments to the Code of Obligations and the Ordinance on Climate Disclosures that would replace the current TCFD comply-or-explain regime with mandatory disclosures using either ISSB Standards (with additional GRI-style information) or ESRS, broaden the scope to more companies and require assurance from year one.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Proposed Code amendments would apply two years after the legislative process concludes

Covered entities

Current rules apply to listed entities (other than those below CHF 450,000 balance sheet, CHF 900,000 revenue and 10 full-time positions) and non-listed companies above 500 employees, CHF 20m balance sheet and CHF 40m turnover. Proposed amendments would extend to entities exceeding two of: CHF 25m balance sheet, CHF 50m turnover, 250 average annual full-time employees over two consecutive years. Subsidiaries can be exempt where covered by an equivalent parent report

EU directive requiring in-scope companies to report sustainability information using the European Sustainability Reporting Standards (ESRS). The 2025 Omnibus package narrowed scope and pushed timelines.

Enforcement

Mandatory

Effective date

2024 FY (wave 1) onwards; revised by Omnibus 2025

Covered entities

Large EU companies, listed SMEs, certain non-EU parents (thresholds revised by 2025 Omnibus)

Classification system defining environmentally sustainable economic activities. Article 8 requires in-scope undertakings to disclose the proportion of turnover, CapEx, and OpEx aligned with the taxonomy. The 2025 Omnibus package narrowed scope and simplified reporting templates.

Enforcement

Mandatory

Effective date

Disclosure obligations apply from 1 January 2022 (phased by environmental objective)

Covered entities

Non-financial and financial undertakings subject to NFRD/CSRD reporting (Article 19a or 29a of Directive 2013/34/EU). Scope narrowed by 2025 Omnibus.

Fund-level and entity-level sustainability disclosure rules for EU financial market participants and advisers. The Commission published a review proposal in November 2025 introducing formal product categories with minimum criteria and reducing disclosure volume. Negotiations ongoing.

Enforcement

Mandatory

Effective date

In application since 10 March 2021

Covered entities

Financial market participants and financial advisers in the EU (asset managers, insurers offering IBIPs, pension providers, investment advisers)

Directive requiring large EU and non-EU companies to identify, prevent, and remedy adverse human rights and environmental impacts in their operations and value chains, and to adopt a climate transition plan. Scope and timelines were revised by the 2025 Omnibus package and Directive (EU) 2026/470.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2027. First wave of in-scope companies covered from 2028.

Covered entities

Large EU and non-EU companies meeting employee and turnover thresholds (revised by 2025 Omnibus and Directive (EU) 2026/470).

UK regulations requiring around 1,300 of the largest UK companies and LLPs to make TCFD-aligned climate disclosures in their strategic report covering governance, strategy, risk management, and metrics and targets. The first G20 mandatory TCFD-aligned regime.

Enforcement

Mandatory

Effective date

Financial years beginning on or after 6 April 2022

Covered entities

Traded companies, banking companies, authorised insurers, AIM-listed companies with >500 employees, and other large companies/LLPs with >500 employees and >£500m turnover

FCA regime for sustainability disclosure and fund labelling, with four investment labels (Focus, Improvers, Impact, Mixed Goals), anti-greenwashing requirements for all FCA-authorised firms, and naming/marketing rules for funds making sustainability claims.

Enforcement

Mandatory

Effective date

Anti-greenwashing rule from 31 May 2024. Investment labels available from 31 July 2024. Naming and marketing rules from 2 December 2024.

Covered entities

FCA-authorised firms (anti-greenwashing); UK asset managers and distributors of investment funds (labels, naming and marketing, disclosures)

UK regime requiring quoted companies, large unquoted companies, and large LLPs to disclose UK energy use, GHG emissions, and at least one intensity metric in their annual reports. Quoted companies report global Scope 1+2 emissions plus underlying global energy use.

Enforcement

Mandatory

Effective date

Financial years starting on or after 1 April 2019

Covered entities

Quoted companies; large unquoted companies and large LLPs (meeting two of: >250 employees, >£36m turnover, >£18m balance sheet). Low energy users (<40 MWh) exempt.

Article 29 requires French financial institutions to publish annual reports on how they integrate environmental, social and governance criteria, including a dedicated section on biodiversity-related risks and impacts under a double-materiality approach. Reports must be filed with ADEME and the AMF within six months of year-end.

Enforcement

Mandatory

Effective date

Decree published 27 May 2021; first reports due 30 June 2022 covering FY2021

Covered entities

French banks, insurers, asset managers and other financial market participants. Full disclosure obligations apply to entities and funds with assets or assets under management above EUR 500 million; lighter regime below the threshold

The Directive amends the Unfair Commercial Practices Directive and the Consumer Rights Directive to ban generic environmental claims (such as eco-friendly or climate neutral) that are not backed by recognised excellent environmental performance, and to prohibit offset-based neutrality claims and unverified future commitments. Sustainability labels must be based on certification schemes or set by public authorities.

Enforcement

Mandatory

Effective date

Transposition deadline 27 March 2026; application from 27 September 2026

Covered entities

Traders selling goods or services to consumers in the EU internal market

The proposed Directive would require companies to substantiate voluntary environmental claims with scientific evidence and have them verified by an accredited third party before use. The file has been suspended since June 2025 following the Commission's stated intention to withdraw the proposal, though it remains formally on the legislative agenda.

Enforcement

Mandatory (if adopted)

Effective date

Not yet adopted; no application date

Covered entities

Traders making voluntary explicit environmental claims about products or services in the EU; micro-enterprise scope is contested

The rule requires that any reference an authorised firm makes to the sustainability characteristics of its products or services is consistent with those characteristics and is fair, clear and not misleading. FG24/3 sets out the FCA's expectations on substantiation, evidence and ongoing review.

Enforcement

Mandatory

Effective date

31 May 2024

Covered entities

All FCA-authorised firms making references to the sustainability characteristics of a product or service to UK clients (retail or professional)

The Green Claims Code sets six principles for environmental claims: claims must be truthful and accurate, clear and unambiguous, must not omit material information, comparisons must be fair, the full life cycle must be considered, and claims must be substantiated. Breaches are pursued under consumer protection law; the CMA can now impose civil fines of up to 10 percent of global turnover.

Enforcement

Guidance (interpreting binding consumer protection law)

Effective date

20 September 2021

Covered entities

Any business selling or promoting goods or services to UK consumers, including non-UK businesses marketing into the UK

Article 12 prohibits advertisers from claiming that a product or service is carbon neutral, or any equivalent term, unless they publish a full life-cycle GHG emissions report, an emissions reduction trajectory and the offsetting methodology used. Breaches carry fines of up to EUR 100,000, raisable to the full cost of the advertising campaign.

Enforcement

Mandatory

Effective date

Law: 24 August 2021; carbon-neutrality rules: 1 January 2023

Covered entities

Any advertiser making carbon neutrality or equivalent claims (zero carbon, climate neutral, fully offset) for products or services in France

Companies in scope must identify, prevent, and remediate human rights and environmental risks in their own operations and direct suppliers, with risk-based duties extending to indirect suppliers when substantiated knowledge arises. BAFA monitors compliance, can issue orders, and impose fines up to EUR 8 million or 2 percent of average annual turnover (where turnover exceeds EUR 400 million).

Enforcement

Mandatory

Effective date

1 January 2023 (companies with 3,000+ employees in Germany); 1 January 2024 (1,000+ employees in Germany)

Covered entities

Companies with their head office, principal place of business, administrative seat, or registered branch in Germany and at least 1,000 employees in Germany (3,000+ in 2023). Includes German branches of foreign companies.

Covered enterprises must conduct human rights and decent working conditions due diligence aligned with the OECD Guidelines, publish an annual account of their efforts by 30 June, and respond in writing within three weeks to public information requests. The Consumer Authority supervises through guidance, decisions, and enforcement penalties.

Enforcement

Mandatory

Effective date

1 July 2022; first annual due diligence accounts due by 30 June 2023

Covered entities

Larger Norwegian enterprises and foreign enterprises selling goods or services in Norway that are tax-liable in Norway. Companies must meet two of three thresholds: NOK 70 million sales revenue, NOK 35 million balance sheet total, 50 FTE employees.

In-scope parent and ordering companies must establish, publish, and effectively implement a vigilance plan covering risk mapping, supplier and subcontractor assessment, mitigation actions, an alert mechanism, and a monitoring scheme addressing human rights, health and safety, and environmental harm across the group and established business relationships. Any party with standing can give formal notice and, after three months of non-compliance, seek a court injunction and damages.

Enforcement

Mandatory

Effective date

27 March 2017; first vigilance plans required for FY2017

Covered entities

French-headquartered companies that, for two consecutive years, employ at least 5,000 employees in France (parent and direct/indirect subsidiaries) or at least 10,000 employees worldwide.

Covered companies would have to investigate whether child labour exists in their supply chains, adopt a plan of action where reasonable suspicion arises, and submit a one-time declaration of due diligence. Sanctions would include administrative fines and, on repeat offences, criminal liability for directors.

Enforcement

Mandatory

Effective date

Not yet in force as of 1 May 2026; original target of 1 January 2022 lapsed

Covered entities

Companies that sell goods or services to Dutch end-users, regardless of where they are established. Implementing decree was to set thresholds and exemptions.

In-scope Swiss companies must operate a supply chain management system, traceability and risk management aligned with the OECD Due Diligence Guidance for minerals and the ILO-IOE child labour due diligence guidance, and publish an annual report. False or missing reports can trigger fines up to CHF 100,000 under Art. 325ter of the Swiss Criminal Code.

Enforcement

Mandatory

Effective date

1 January 2022; one-year transition meant first reporting period was FY2023

Covered entities

Companies with registered office, head office, or principal place of business in Switzerland that import or process tin, tantalum, tungsten, gold (3TG) above annual volume thresholds set in the DDTrO annex, and companies that offer products or services where there is reasonable suspicion of child labour. SMEs and low-risk companies are exempt under defined conditions.

Covered organisations must publish an annual modern slavery and human trafficking statement, approved by the board (or equivalent) and signed by a director, setting out the steps taken (or stating that no steps were taken) to ensure slavery and human trafficking are not occurring in their business or supply chains. The Home Office maintains a central registry and the Secretary of State may seek civil injunctions for non-compliance.

Enforcement

Mandatory

Effective date

29 October 2015; first statements required for financial years ending on or after 31 March 2016

Covered entities

Commercial organisations (any body corporate or partnership, wherever incorporated) carrying on any part of a business in the UK and supplying goods or services with a total annual turnover of GBP 36 million or more (group turnover where applicable).

Operators and non-SME traders must collect geolocation data for each plot of production, conduct a due diligence exercise to demonstrate that products are deforestation-free (cut-off 31 December 2020) and produced in accordance with the laws of the country of production, and submit a due diligence statement before placing products on the market or exporting them. Member States must impose dissuasive penalties including fines of at least 4 percent of EU turnover and confiscation of products and revenues.

Enforcement

Mandatory

Effective date

Application from 30 December 2026 (large operators and traders) and 30 June 2027 (micro and small enterprises and natural persons)

Covered entities

Operators and traders that place on, make available on, or export from the EU market relevant commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) and listed derived products. Simplified obligations for micro and small enterprises and primary operators.

The regulation prohibits placing on the EU market, making available, or exporting products made wholly or in part with forced labour, including child forced labour. Competent authorities investigate based on a risk-based approach, can order withdrawal, recall, and disposal of non-compliant products, and decisions are mutually recognised across Member States.

Enforcement

Mandatory

Effective date

Applies from 14 December 2027. Commission guidelines due 14 June 2026; Forced Labour Single Portal and database to be operational ahead of application.

Covered entities

All economic operators (natural or legal persons) that place or make available products on the EU market or export products from the EU, regardless of size, sector, or origin. Applies to products and product components.

Australia has issued ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory under the Corporations Act for in-scope entities; AASB S1 (broader sustainability) is voluntary.

Enforcement

AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.

Effective date

Annual reporting periods beginning on or after 1 January 2025 (phased by entity size)

Covered entities

Group 1, 2, 3 entities under AASB thresholds (large entities first; phased rollout to mid-size and smaller large entities)

SSBJ published final sustainability disclosure standards on 5 March 2025: an Application Standard, a General Standard, and a Climate Standard. The standards are essentially equivalent to IFRS S1 and S2. Mandatory application phases in by market capitalization.

Enforcement

Voluntary now. Mandatory under FSA disclosure framework on phased basis by market cap.

Effective date

Voluntary for periods ending on or after 5 March 2025. Mandatory phased: FY ending March 2027 for issuers with market cap >¥3T, expanding through FY ending March 2029.

Covered entities

Listed issuers in Prime Market (phased by market cap)

Singapore is phasing in mandatory ISSB-aligned climate disclosure for SGX-listed issuers from FY2025. Large non-listed companies become subject from FY2030. SGX extended several timelines on 25 August 2025.

Enforcement

Mandatory

Effective date

SGX listed: Scope 1+2 from FY2025; Scope 3 mandatory for STI constituents from FY2026. Large non-listed: Scope 1+2 from FY2030.

Covered entities

All SGX-listed issuers (phased by market cap and STI status); large non-listed companies meeting ACRA thresholds.

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.

HKEX listing rules require all Main Board issuers to disclose climate information aligned with IFRS S2 on a comply-or-explain basis from 1 January 2025, with mandatory application for Hang Seng Composite LargeCap constituents from 1 January 2026. Some elements differ from IFRS S2 (e.g., scope of consolidation, industry-based metrics).

Enforcement

Comply-or-explain for all Main Board issuers from 1 January 2025. Mandatory for Hang Seng Composite LargeCap Index constituents from 1 January 2026.

Effective date

1 January 2025 (comply-or-explain); 1 January 2026 (mandatory for HSCI LargeCap)

Covered entities

All HKEX Main Board issuers (comply-or-explain); HSCI LargeCap constituents (mandatory)

In December 2023, Bangladesh Bank issued a circular mandating IFRS S1 and S2 disclosures by all banks and financial institutions it regulates, with limited assurance required from the second year of reporting.

Enforcement

Mandatory

Effective date

Annual reports for financial years beginning on or after 1 January 2024

Covered entities

Listed and non-listed banks and finance companies regulated by Bangladesh Bank, including foreign banks and finance companies operating in Bangladesh

The Advisory Committee on Sustainability Reporting released the National Sustainability Reporting Framework in September 2024, and Bursa Malaysia amended its listing rules in December 2024 to require IFRS S1 and S2 reporting on a climate-first phased basis starting FY2025.

Enforcement

Mandatory

Effective date

Group 1 (Main Market issuers with market cap MYR 2bn and above): climate-first reporting from 1 January 2025, full S1/S2 from 1 January 2027. Group 2 (other Main Market issuers): climate-first from 1 January 2026, full S1/S2 from 1 January 2028. Group 3 (ACE Market issuers and large non-listed companies with annual revenue MYR 2bn and above): climate-first from 1 January 2027, full S1/S2 from 1 January 2030

Covered entities

Bursa Malaysia Main Market and ACE Market listed issuers (including REITs and business trusts) and large non-listed companies with annual revenue of MYR 2 billion and above, classified into three groups by size and listing venue

On 31 December 2024 SECP issued an order under the Companies Act 2017 requiring listed companies and SECP-licensed Public Interest Companies to apply IFRS S1 and S2, phased over three reporting cohorts from FY beginning 1 July 2025 to 1 July 2027.

Enforcement

Mandatory

Effective date

Phase I: annual reporting periods beginning on or after 1 July 2025 (large listed companies meeting two of: turnover above PKR 25bn, over 1,000 employees, assets above PKR 12.5bn). Phase II: 1 July 2026 (mid-sized listed companies meeting two of: turnover above PKR 12.5bn, over 500 employees, assets above PKR 6.25bn). Phase III: 1 July 2027 (all remaining listed companies and SECP-licensed non-listed Public Interest Companies)

Covered entities

Listed companies on Pakistan Stock Exchange and SECP-licensed non-listed Public Interest Companies (including non-banking finance companies, modaraba companies, insurers, exchanges, central depositories), phased by size thresholds

CA Sri Lanka issued local SLFRS S1 and S2 standards incorporating IFRS S1 and S2, with mandatory application from 1 January 2025 starting with the top 100 Colombo Stock Exchange entities and phased through 2030 for other listed and SLAASMB-supervised non-listed entities.

Enforcement

Mandatory

Effective date

Voluntary: annual reporting periods beginning on or after 1 January 2024. Mandatory phased dates: 1 January 2025 (top 100 Colombo Stock Exchange listed entities by market cap); 1 January 2026 (Main Board entities); 1 January 2027 (other listed entities except Empower Board); 1 January 2028 (non-listed SLAASMB-supervised entities with turnover above LKR 10bn); 1 January 2029 (those above LKR 5bn); 1 January 2030 (Empower Board entities listed before 1 January 2024 and all other SLAASMB-supervised non-listed entities); fifth anniversary of listing for Empower Board entities listed after 1 January 2024

Covered entities

All Colombo Stock Exchange listed entities (phased by board and market cap) and non-listed entities subject to SLAASMB oversight (phased by turnover thresholds)

Taiwan's Financial Supervisory Commission published a roadmap in August 2023 to require Taiwan Stock Exchange and Taipei Exchange listed companies to apply IFRS S1 and S2 in three phases from FY2026, contingent on further FSC rulemaking.

Enforcement

Mandatory

Effective date

Phase I: FY2026, reported in 2027 (listed companies with paid-in capital above TWD 10bn). Phase II: FY2027, reported in 2028 (listed companies with paid-in capital between TWD 5bn and TWD 10bn). Phase III: FY2028, reported in 2029 (all other listed companies)

Covered entities

All companies listed on the Taiwan Stock Exchange and Taipei Exchange, phased by paid-in capital. Application may later be extended to certain unlisted financial institutions including banks, insurers, securities companies, securities investment trust funds and futures commission merchants

In November 2024, the Ministry of Finance and eight other ministries issued the Sustainability Disclosure Standards for Business Enterprises – Basic Standard (Trial) and, in April 2025, an exposure draft of the climate-specific standard, building a unified national system convergent with ISSB Standards and targeted for completion by 2030.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Basic Standard issued 20 November 2024 may be applied voluntarily until implementation scope and requirements are specified; the basic architecture of the unified national system is targeted for 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

In December 2024 Indonesia's IAI published a roadmap and exposure drafts of national Sustainability Disclosure Standards (PSPK 1 and PSPK 2) based on IFRS S1 and S2, with final standards expected in Q2 2025 and a proposed effective date of 1 January 2027 pending OJK rules.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Roadmap proposes PSPK 1 and PSPK 2 effective 1 January 2027, with earlier application permitted

Covered entities

To be determined by OJK. Proposed for publicly accountable entities, including listed entities and financial services industries; climate-related disclosures expected to be required first, with broader sustainability disclosures voluntary in the initial three-year window

The Philippine Sustainability Reporting Committee published an adoption roadmap in December 2023, and the Board of Accountancy adopted PFRS S1 and S2 in March 2024; SEC and PSE are running readiness work, with a regulator memorandum circular pending to confirm mandatory dates phased from FY2026 to FY2028.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Proposed mandatory implementation for SEC-regulated companies: Tier 1 (large cap, market cap above PHP 50bn) from FY beginning on or after 1 January 2026; Tier 2 (mid cap, PHP 3bn to PHP 50bn) from 1 January 2027; Tier 3 (small cap and large non-listed companies with annual revenue above PHP 15bn) from 1 January 2028. Government corporations classified as Commercial Public Sector Entities and IC-regulated entities to follow separate guidelines. Early application permitted

Covered entities

Proposed: all publicly listed entities and large non-listed entities regulated by SEC (including banks and entities primarily regulated by Bangko Sentral ng Pilipinas or the Insurance Commission), Commercial Public Sector government corporations, and other entities as later determined. Large non-listed subsidiaries may be exempted if their parent already files in the Philippines

Korea's KSSB published exposure drafts of three Korean Sustainability Disclosure Standards (KSSB 1, KSSB 2 and the non-mandatory KSSB 101) with consultation closing 31 August 2024; the Financial Services Commission is considering disclosure requirements for listed entities, indicating adoption from after 2026.

Enforcement

Voluntary or under development

Effective date

Not yet specified

Covered entities

To be determined. FSC will consider application of KSDS by listed entities once final standards are issued

Thailand's SEC consulted on a roadmap to require listed entities to apply IFRS S1 and S2 with extended transition reliefs, including a five-year climate-first phase; the consultation closed 19 December 2024 and SEC is assessing feedback before a second consultation.

Enforcement

Voluntary or under development

Effective date

Not yet specified. SEC proposed a phased-in approach: SET50 entities to start disclosing in 2027 for FY2026; SET100 entities in 2028 for FY2027; other SET-listed companies (including IPOs) in 2030 for FY2029; MAI-listed companies and certain SET-listed REITs, IFFs, Infrastructure Trusts and Property Funds in 2031 for FY2030

Covered entities

Proposed at the consolidated entity level: listed companies (Thai or foreign incorporated, including those intending an IPO), Real Estate Investment Trusts, Infrastructure Trusts, Property Funds and Infrastructure Funds

New Zealand's mandatory climate-related disclosure regime, issued by the XRB and modelled on TCFD. New Zealand was the first country in the world to legislate this kind of regime.

Enforcement

Mandatory

Effective date

Reporting periods beginning on or after 1 January 2023

Covered entities

Climate Reporting Entities (CREs): large listed issuers, large registered banks, insurers, NBDTs, investment scheme managers

Australia's mandatory national reporting framework for greenhouse gas emissions and energy production/consumption by large emitters. Underpins Australia's National Greenhouse Accounts and UNFCCC reporting.

Enforcement

Mandatory

Effective date

In effect since 2008. Annual reports due 31 October each year.

Covered entities

Australian corporations meeting facility or corporate-group emissions/energy thresholds. ~900 entities currently report.

The Act sets up a national voluntary market for biodiversity certificates, with each certificate carrying standardised information on the area, project type, threatened species and duration of the work. Participants must follow biodiversity integrity standards and notify the regulator of significant reversals.

Enforcement

Voluntary participation, mandatory rules for participants

Effective date

15 December 2023

Covered entities

Landholders, Indigenous land managers and proponents who choose to register biodiversity projects and issue Biodiversity Certificates; buyers in the voluntary market

The Guidelines set MAS' supervisory expectations for identifying, assessing, monitoring and disclosing environmental risks, expressly covering climate, pollution, land-use change and biodiversity loss. Boards and senior management must integrate these risks into governance, strategy and risk management.

Enforcement

Guidance (supervisory expectations, comply-or-explain in practice)

Effective date

8 December 2020 (issued); 18-month transition to June 2022

Covered entities

All banks, merchant banks and finance companies; insurers; asset managers regulated by MAS

INFO 271 sets out nine questions issuers should ask before making sustainability claims, covering labelling, terminology, investment screens and ongoing monitoring. ASIC enforces against breaches under the existing prohibitions on misleading or deceptive conduct in the Corporations Act and ASIC Act.

Enforcement

Guidance (interpreting binding misleading-conduct rules in the Corporations Act 2001 and ASIC Act 2001)

Effective date

June 2022

Covered entities

Responsible entities of managed funds, corporate directors of CCIVs, and trustees of registrable superannuation entities offering or promoting sustainability-related products; principles also relevant to other issuers

The guide sets out eight principles for trustworthy environmental claims, including accuracy, evidence, life-cycle thinking, fair comparisons, plain language and transparency about transition plans. Breaches are pursued under the Australian Consumer Law's prohibitions on misleading and deceptive conduct.

Enforcement

Guidance (interpreting the binding Australian Consumer Law)

Effective date

12 December 2023

Covered entities

All businesses making environmental or sustainability claims about goods and services to Australian consumers

Reporting entities must submit an annual modern slavery statement covering seven mandatory criteria (structure, operations, supply chains, risks, actions, effectiveness, and consultation), approved by the principal governing body and signed by a responsible member, within six months of financial year end. Statements are published on the Modern Slavery Statements Register administered by Home Affairs (now Attorney-General's Department).

Enforcement

Mandatory

Effective date

1 January 2019

Covered entities

Entities based or operating in Australia with consolidated annual revenue of at least AUD 100 million, plus the Commonwealth of Australia and Commonwealth corporate entities meeting the threshold. Other entities may report voluntarily.

The Institute of Chartered Accountants, Ghana issued a roadmap adopting IFRS S1 and S2 with voluntary use from 2024 and mandatory application phased from 2027 for public interest and high-impact sector entities, and from 2028 for other companies.

Enforcement

Mandatory

Effective date

Voluntary: annual reporting periods beginning on or after 1 January 2024. Mandatory: 1 January 2027 for Significant Public Interest Entities and listed-sector heavy emitters (oil and gas, mining, cement, automotive, non-renewable power); 1 January 2028 for Other Mandatory Adopters

Covered entities

Significant Public Interest Entities (listed entities, regulated banks, insurers, corporate trustees, registered pension schemes, public limited companies and their holding companies), specified high-impact sector companies (oil and gas, mining, cement, automotive, non-renewable power), and other companies under the Companies Act 2019. Non-Mandatory Companies (private, not in public markets, below GHS 50m revenue / GHS 40m assets) may apply voluntarily

On 31 December 2024 the Amman Stock Exchange launched a Climate-related Disclosures Regulatory Framework permitting all listed companies to apply ISSB Standards and requiring ASE20 Index companies to apply the climate-related requirements from FY2026.

Enforcement

Mandatory

Effective date

Voluntary use of IFRS S1 and S2 from annual reporting periods beginning on or after 1 January 2025 (disclosures published in 2026). Mandatory climate disclosures (IFRS S2 and climate-relevant portions of S1) for ASE20 Index companies from annual reporting periods beginning on or after 1 January 2026 (disclosures published in 2027)

Covered entities

All ASE-listed companies permitted to apply IFRS S1 and S2; ASE20 Index companies required to apply the climate-related requirements; ASE has indicated future phases may extend the framework to additional listed companies

ICPAK issued a November 2024 roadmap adopting IFRS S1 and S2, with voluntary application open from 2024 and mandatory application phased from 2027 for public interest entities, 2028 for other large entities, and 2029 for SMEs.

Enforcement

Mandatory

Effective date

Voluntary: annual reporting periods beginning on or after 1 January 2024. Mandatory: 1 January 2027 for public interest entities; 1 January 2028 for non-public interest large entities; 1 January 2029 for SMEs

Covered entities

Public interest entities (publicly traded entities, deposit-taking institutions, insurers, and other entities specified by law as having significant public interest), non-public-interest large entities, and SMEs (phased)

The Financial Reporting Council of Nigeria issued a March 2024 roadmap adopting IFRS S1 and S2, with voluntary application open from 2024 and mandatory application phased from 2028 for public interest entities and from 2030 for SMEs.

Enforcement

Mandatory

Effective date

Voluntary: annual reporting periods beginning on or after 1 January 2024. Mandatory: 1 January 2028 for public interest entities; 1 January 2030 for SMEs

Covered entities

Public interest entities as defined in the Financial Reporting Act 2011 (governments and government organisations, listed entities, regulated non-listed entities, public limited companies, holding companies of public or regulated entities, concession entities, privatised entities with government interest, government contractors above N1 billion, government licensees, and entities with annual turnover of N30 billion or more), and SMEs in a later phase

The Institute of Certified Public Accountants Rwanda issued a roadmap adopting IFRS S1 and S2 across four entity groups, beginning with simplified climate-only reporting in 2025 for Group 1 and progressing to full ISSB application by 2027 for listed entities and Tier I financial institutions.

Enforcement

Mandatory

Effective date

Group 1 (listed entities and Tier I financial institutions): Initial Phase from FY2025, Intermediate Phase from FY2026, Full ISSB Standards from FY2027. Group 2 (public utilities and Tier II/III financial institutions): 2026, 2027, 2028. Group 3 (other IFRS reporters and Tier IV financial institutions): 2027, 2028, 2029. Group 4 (IFRS for SMEs reporters): begins reporting under a simplified framework from FY2028

Covered entities

Group 1: listed entities and Tier I financial institutions (banks, insurers). Group 2: public utilities, Tier II (deposit-taking microfinance, micro insurers) and Tier III (non-deposit-taking financial service providers, mutual insurers). Group 3: other IFRS reporters and Tier IV (financial cooperatives). Group 4: IFRS for SMEs reporters

In July 2024, Tanzania's National Board of Accountants and Auditors issued Technical Pronouncement No. 1 of 2024 adopting IFRS S1 and S2 for public interest and public sector entities from financial years beginning on or after 1 January 2025, supported by Bank of Tanzania guidelines for financial institutions.

Enforcement

Mandatory

Effective date

Financial years commencing on or after 1 January 2025

Covered entities

Public interest entities (entities with debt or equity in public markets, fiduciary entities such as banks, insurers and brokers, and commercial entities with total gross capital of at least TZS 50 billion in strategic sectors including energy, water, telecoms, transport, extractives, food processing and entertainment) plus public sector entities; voluntary application permitted for all other entities

ZICA issued a pronouncement adopting IFRS S1 and S2, with mandatory application by all publicly accountable entities for annual reporting periods beginning on or after 1 January 2025 and voluntary application permitted for all other organisations.

Enforcement

Mandatory

Effective date

Annual reporting periods beginning on or after 1 January 2025

Covered entities

All publicly accountable entities (entities whose securities are traded in public markets or that are in the process of issuing such securities); all other organisations permitted to apply voluntarily

ICPAU issued a proposed roadmap for adopting IFRS S1 and S2 in Uganda; consultation closed on 31 July 2024 and the final roadmap is pending, with proposed voluntary reporting from FY2026 and mandatory application phased from FY2028 to FY2030.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Proposed roadmap: voluntary reporting for all entities from FY beginning on or after 1 January 2026; mandatory reporting from 1 January 2028 for listed entities, financial institutions, MDIs, insurers and reinsurers, qualifying SACCOs and IFRS-using public utilities; from 1 January 2029 for retirement benefit schemes, large companies and other public interest entities; from 1 January 2030 for SMEs

Covered entities

Proposed: listed entities, financial institutions and micro-finance deposit-taking institutions, insurers and reinsurers, qualifying savings and credit cooperative organisations (with voluntary savings of at least UGX 3bn, institutional capital of at least UGX 1bn, or 500+ members), IFRS-using public utilities, retirement benefit schemes, large companies (meeting two of: balance sheet UGX 100bn, turnover UGX 50bn, 500 employees), other public interest companies, and SMEs (phased)

In November 2022 the Public Accountants and Auditors Board, through the Minister of Finance and Economic Development, issued a resolution endorsing early adoption of IFRS S1 and S2, with proposed application from financial periods beginning on or after 1 January 2026; a full adoption roadmap is pending.

Enforcement

Voluntary or under development

Effective date

Not yet specified. Proposed application for financial periods beginning on or after 1 January 2026

Covered entities

To be determined. Listing rules currently require listed entities to report under GRI Standards; the interaction between GRI listing-rule reporting and proposed ISSB-based reporting has not been resolved