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 organization, financial or non-financial, that chooses to adopt the framework. 802 organizations, including financial institutions with USD 26.6 trillion in AUM, had committed as TNFD Adopters, and more than 1,000 organizations across 56 countries or areas had published TNFD-aligned disclosures (TNFD 2026 Status Report, 21 September 2026)

The ISSB is proposing nature-related disclosure requirements as an IFRS Practice Statement that would sit alongside IFRS S1 and IFRS S2 and draw on the TNFD framework. Application would be optional unless a jurisdiction requires it, and an entity that applies it would state compliance with it. The Board cleared the Exposure Draft for balloting in July 2026 with a 120-day comment period and is targeting publication in October 2026.

Enforcement

Voluntary (non-mandatory Practice Statement) unless a jurisdiction requires it

Effective date

Exposure Draft targeted for October 2026 with a 120-day comment period (deadline set on publication); the final Practice Statement would be available for application from its date of issuance, with no comparative information required in the first reporting period

Covered entities

Entities applying IFRS S1 and IFRS S2 that choose to apply the Practice Statement or are required to by their jurisdiction

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.

Brazil adopted Portuguese-language versions of IFRS S1 and S2 (CBPS 01 and CBPS 02). In May 2026, CVM Resolution 244 removed the mandatory requirement for publicly held companies from 2026: reporting is voluntary, companies that opt in must report for at least three years, and from 2027 companies that do not file must explain why. CMN and BCB resolutions still require financial institutions to report under CBPS standards from 2026 or 2028, depending on segment.

Enforcement

Mandatory for CMN/BCB-regulated financial institutions; voluntary with comply-or-explain for CVM-regulated publicly held companies

Effective date

CVM: voluntary from fiscal years beginning on or after 1 January 2024 (ISSB) or 1 January 2025 (CBPS); Resolution CVM 244 in force 29 May 2026 and applies to fiscal years beginning on or after 1 January 2026; from 1 January 2027, a publicly held company that opts not to file must publish a market announcement explaining why by its annual financial statements filing date. CMN/BCB: mandatory for fiscal years beginning on or after 1 January 2026 for publicly held companies and S1/S2 prudential conglomerate leaders, and 1 January 2028 for other financial institutions publishing consolidated statements under international standards

Covered entities

CVM scope (voluntary): publicly held companies, investment funds and securitization companies; voluntary adopters must report for at least three consecutive fiscal years and must announce a decision to stop by the annual financial statements filing date of the preceding fiscal year. CMN/BCB scope (mandatory): financial institutions and other institutions authorized to operate by BCB, sequenced by prudential segment (publicly held and S1/S2 from 2026, 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, replacing the TCFD and SASB-based regime under Rule 461. In July 2026, General Rule No. 572 pushed the start back one year, so mandatory reporting now covers annual periods starting in 2027, reported in 2028.

Enforcement

Mandatory

Effective date

Annual reporting periods beginning in 2027, first reported in 2028 (CMF General Rule No. 519 as amended by General Rule No. 572 of 27 July 2026, which moved the Rule 519 section III effective date from 31 December 2026 to 31 December 2027). Voluntary IFRS S1/S2 reporting in 2027 on fiscal year 2026 is invited. TCFD/SASB disclosures under Rule 461 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 published DOF 28 January 2025 and in force 29 January 2025; first sustainability reports due in 2026 for FY2025 (assurance not required), limited assurance for reports filed in 2027 on FY2026, reasonable assurance for reports filed from 2028

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

Costa Rica's Colegio de Contadores Públicos adopted IFRS S1 and S2 through Circular 33-2023, with voluntary use from 2024 and mandatory reporting in 2028 on fiscal year 2027 for publicly accountable IFRS reporters, including CONASSIF-supervised entities, and for large taxpayers required to use full IFRS Accounting Standards.

Enforcement

Voluntary today, becoming Mandatory

Effective date

Voluntary: periods beginning on or after 1 January 2024. Mandatory: sustainability-related financial information for the annual period ending 31 December 2027, reported in 2028

Covered entities

Mandatory for publicly accountable entities applying IFRS Accounting Standards, including those fully supervised by the superintendencies under CONASSIF, and for entities classified as large taxpayers that must use IFRS Accounting Standards. Large taxpayers permitted to use IFRS for SMEs are not required to apply IFRS S1 and S2 solely because of that status. Other IFRS Accounting Standards reporters may apply voluntarily; other IFRS for SMEs reporters are not required until further rules; public entities under the Contabilidad Nacional follow its rules

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 US-based companies with more than $1 billion in annual revenue that do business in the state to report Scope 1 and 2 emissions each year from 2026 and Scope 3 from 2027, with third-party assurance phased in. CARB adopted an initial regulation covering applicability, fees and the first deadline in February 2026 and is drafting a second rule for 2027 reporting onward. For 2026 only, CARB guidance issued 1 September 2026 lets companies submit existing Scope 1 and 2 data or a statement that data were not collected, and CARB will use enforcement discretion for good-faith first-year filings.

Enforcement

Mandatory

Effective date

First Scope 1 and 2 reports due 10 November 2026 (CARB's proposed deferral from 10 August 2026, pending OAL approval); Scope 3 reporting from 2027; CARB proposes limited assurance of Scope 1 and 2 starting with 2027 reports

Covered entities

US-based business entities with total annual revenue above $1 billion that do business in California. CARB's proposed 15-day changes assess coverage entity by entity and let a parent file consolidated reports and pay fees for covered subsidiaries.

California law requiring US-based companies with more than $500 million in annual revenue that do business in the state to publish a climate-related financial risk report every two years, following the TCFD framework or an equivalent. The Ninth Circuit enjoined enforcement while the Chamber of Commerce appeal is pending, so CARB has not enforced the 1 January 2026 deadline. Companies may post reports voluntarily to a CARB docket opened 1 December 2025.

Enforcement

Mandatory by statute; enforcement suspended by court injunction

Effective date

Statutory first report due 1 January 2026 and every two years after; CARB is not enforcing that date and will announce an alternate reporting date after the appeal is resolved

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. Chapter 2 sets public climate disclosure expectations; the March 2025 version aligned Scope 3 timing with the CSSB's CSDS 2 (fiscal 2028).

Enforcement

Mandatory for federally regulated financial institutions

Effective date

Chapter 2 disclosures apply to fiscal periods ending on or after 1 October 2024 (D-SIBs and IAIGs headquartered in Canada) and 2025 (other in-scope FRFIs), with cross-industry metrics one year later; Scope 3 financed and insurance-associated emissions and industry-based metrics from fiscal year-end 2028; AUM emissions, transition plan and scenario resilience disclosures TBD

Covered entities

All FRFIs except foreign bank branches; applies to Canadian branches of foreign insurers only for risks insured in Canada. Chapter 2 disclosures exclude FRFI subsidiaries that report consolidated results to OSFI.

New York bill modeled on California SB 253 that would require large companies doing business in the state to disclose Scope 1, 2 and 3 emissions each year, with limited assurance from 2028 and reasonable assurance from 2032. Civil penalties would reach $100,000 per day, capped at $500,000 per reporting year. The Senate passed S9072A in February 2026; the Assembly has not acted.

Enforcement

Mandatory if enacted

Effective date

If enacted as passed by the Senate: DEC regulations by 31 December 2027; Scope 1 and 2 reporting from 2028; Scope 3 from 2029; act takes effect 180 days after it becomes law

Covered entities

Partnerships, corporations, LLCs and other business entities with total revenues above $1 billion that do 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

Two deceptive marketing provisions target environmental claims. Product claims about benefits for protecting or restoring the environment or mitigating the causes or effects of climate change must be based on an adequate and proper test (paragraph 74.01(1)(b.1)). Claims about the environmental benefits of a business or business activity must be based on adequate and proper substantiation (paragraph 74.01(1)(b.2)); since 26 March 2026 that substantiation no longer has to follow an internationally recognized methodology, and private parties cannot seek leave to bring (b.2) cases. For corporations, administrative monetary penalties can reach the greater of CAD 10 million (CAD 15 million for later orders) and three times the benefit derived or, if that cannot be determined, 3 percent of annual 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 (latest: 43 entities added effective 3 August 2026, 187 entities listed)

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 run a reasonable country of origin inquiry and file an annual Form SD. Where minerals may come from the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources, the rule also calls for OECD-based supply chain due diligence and a Conflict Minerals Report under Item 1.01(c). Since April 2017, SEC staff has said it will not recommend enforcement against companies that file only the Item 1.01(a) and (b) disclosure.

Enforcement

Mandatory

Effective date

First reports for calendar year 2013 (Form SD filed by 31 May 2014); Form SD due 31 May each year (1 June 2026 for calendar year 2025 because 31 May fell on a Sunday)

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.

EPR in Canada is set province by province under the CCME action plan, with British Columbia, Ontario and Quebec running the most developed full producer-funded systems for packaging, paper, electronics, batteries and other product streams. Ottawa has no overarching federal EPR statute; CEPA underpins toxic-substances rules and federal coordination, while provinces operate the schemes through PROs such as Recycle BC, Circular Materials and Éco Entreprises Québec.

Enforcement

Mandatory

Effective date

BC packaging EPR since 19 May 2014; Ontario Blue Box transition to full producer responsibility ran 1 July 2023 to 31 December 2025; Quebec modernized packaging EPR effective 1 January 2025; Alberta packaging, paper and hazardous and special products EPR launched 1 April 2025 (remaining communities 1 October 2026); EEE, batteries, tires and paint schemes since the 2000s

Covered entities

Producers (brand owners, first importers, distributors) of packaging, printed paper, EEE, batteries, tyres, paint, lamps, used oil and other regulated products in each province; thresholds vary (e.g., Ontario small-producer exemption below CAD 2 million revenue or 1 tonne supplied)

Mexico's Ley General de Economía Circular (2026) requires producers and importers to organize and, where applicable, finance circular-economy schemes for the products they make or import, and to register a Gestión Circular with SEMARNAT, under an REP model that complements the LGPGIR's shared-responsibility rules. Detailed obligations and targets will come from the LGEC Reglamento and SEMARNAT's general REP implementation agreements. Until then, the LGPGIR's Waste Management Plans (Planes de Manejo) and NOMs such as NOM-161 set the operative duties, and several states add their own packaging and plastics rules.

Enforcement

Mandatory

Effective date

LGEC published DOF 19 January 2026 and in force 20 January 2026; LGEC Reglamento due within 180 calendar days of entry into force (about 19 July 2026) and not listed in the Chamber of Deputies' federal regulations index as of 23 September 2026; LGPGIR in force 6 January 2004, last reformed DOF 19 January 2026; LGPGIR Reglamento in force 2007; NOM-161 published 1 February 2013

Covered entities

Under the LGEC, productive sectors and importers must organize, promote and, where applicable, finance circular-economy schemes for the products they make or import, and producers, importers or their coordinating body must register a Gestión Circular on the Plataforma Nacional. Under the LGPGIR, producers, importers, distributors and traders of products on the national list of priority waste streams must run Planes de Manejo; large generators of hazardous and special-handling waste are also covered

Brazil's PNRS makes manufacturers, importers, distributors and retailers responsible for reverse logistics of listed products, including packaging, e-waste, batteries, tyres and lubricant containers. Decreto 10.936/2022 consolidated the general rules and reporting through SINIR. Decreto 12.688/2025 created a plastic packaging system with national recovery targets of 32% in 2026 rising to 50% in 2040, plus recycled-content targets of 22% in 2026 rising to 40% in 2040 for manufacturers and importers.

Enforcement

Mandatory

Effective date

Lei 12.305 enacted 2 August 2010, in force from 3 August 2010; Decreto 10.936 enacted 12 January 2022; Decreto 12.688 in force 21 October 2025, with plastic packaging recovery targets from 2026 and recycled-content targets mandatory from January 2026 for large companies and July 2026 for small and medium companies

Covered entities

Manufacturers, importers, distributors and retailers of products subject to mandatory reverse logistics, including pesticides, lubricant oils and packaging, tyres, batteries, fluorescent lamps, household electrical and electronic equipment (Decreto 10.240/2020), household medicines (Decreto 10.388/2020), plastic packaging and comparable plastic products (Decreto 12.688/2025), and general packaging covered by sectoral agreements. Plastic packaging recycled-content targets apply to manufacturers and importers

Chile's Ley REP requires producers of priority products to organize and finance collection and recycling of their post-consumer waste, individually or through collective management systems. Targets are in force for tyres (DS 8/2019, from January 2023) and packaging (DS 12/2020, from September 2023). The portable battery and EEE decree (DS 22/2025) was published in May 2026; its general collection and recovery target starts at 3% in the first year and rises to 45% from the tenth year, applying from May 2028. The lubricant oils decree was annulled by the courts in August 2026, and decrees for batteries and textiles are still being drafted.

Enforcement

Mandatory

Effective date

Ley REP published 1 June 2016; DS 8/2019 (tyres) published 20 January 2021, obligations from 20 January 2023; DS 12/2020 (packaging) published 16 March 2021, obligations from 16 September 2023; DS 22/2025 (portable batteries and EEE) published 7 May 2026 and in force on publication, except its targets and associated obligations, which apply 24 months after publication (7 May 2028)

Covered entities

Producers (first sellers on the Chilean market, own-brand sellers of products bought from third parties, and importers for own professional use) of priority products, above thresholds set in each supreme decree. Ley 20.920 Art. 10 lists lubricant oils, EEE, batteries, packaging, tyres and portable batteries (pilas); MMA declared textiles a priority product in 2025. Newspapers, periodicals and magazines fall under a reporting-only regime without targets

Colombia regulates EPR product by product through ministerial resolutions, requiring producers and importers of packaging, batteries, e-waste and tyres to file environmental management plans (planes posconsumo) with ANLA. The packaging resolution sets a recovery target that rises to 30% of packaging placed on the market by 2030. Since 1 January 2026, Resolución 0799/2025 requires producers of lead-acid vehicle and motorcycle batteries to run collection systems and meet minimum management targets of 90% and 60%.

Enforcement

Mandatory

Effective date

Resolución 1407 effective 26 July 2018; battery and WEEE resolutions effective from 2010; tyre resolution effective 2017; Resolución 0799/2025 on lead-acid batteries effective 1 January 2026

Covered entities

Producers and importers of primary, secondary and tertiary packaging in paper, cardboard, plastic, glass and metal above thresholds in Resolución 1407; producers of batteries, EEE and tyres; manufacturers and importers of more than 300 lead-acid batteries a year, plus retailers, users and waste managers (Resolución 0799/2025)

Argentina does not yet have a national EPR statute for packaging, e-waste or batteries; the framework relies on Ley 25.916 plus a patchwork of provincial laws, with Buenos Aires, Santa Fe and Chaco leading on WEEE. A national RAEE bill and a separate batteries and accumulators bill have been debated in Congress for years without final approval.

Enforcement

Mandatory at provincial level; voluntary nationally pending federal law

Effective date

Ley 25.916 sanctioned 4 August 2004 and published 7 September 2004; Buenos Aires Ley 14.321 since December 2011; national RAEE bill not enacted as of September 2026 [uncertain: no national law found on argentina.gob.ar; Congress records not checked]

Covered entities

Producers and importers of electrical and electronic equipment, batteries and packaging in provinces with their own EPR laws; obligations vary by province

Peru's solid waste law sets EPR as a general principle (Articles 12 to 14) and authorises MINAM to designate priority products that producers must collect and recycle. The WEEE regulation (DS 009-2019) is the most developed product-specific scheme, with tyre, battery and packaging regulations following.

Enforcement

Mandatory

Effective date

DL 1278 published 23 December 2016; Reglamento effective 22 December 2017; RAEE regulation DS 009-2019 effective 2019

Covered entities

Manufacturers, importers, distributors and retailers of products defined as priority by MINAM, in particular EEE, tyres, batteries, lubricants and packaging in scope of future reglamentos

Uruguay's Ley 19.829 (2019) sets extended producer responsibility for manufacturers and importers of special waste, alongside Ley 17.849 on non-returnable packaging and Decreto 260/007, which set up the Plan de Envases run by the Cámara de Industrias. Decreto 227/025 replaced the 2003 battery decree and requires manufacturers and importers of batteries over 1 kW to register and implement a master management plan approved by the Ministerio de Ambiente. Separate decrees cover tyres and lubricant containers.

Enforcement

Mandatory

Effective date

Ley 17.283 in force 2000; Ley 17.849 in force 2004; Decreto 260/007 in force 2007; Ley 19.829 published 30 September 2019; Decreto 358/015 published 8 January 2016; Decreto 227/025 published 5 November 2025 and in force the next day

Covered entities

Manufacturers and importers of products that become special waste under Ley 19.829 (except products taxed under the specific internal tax); brand owners and importers of non-returnable packaging (Ley 17.849, Decreto 260/007); manufacturers, importers and special users of batteries over 1 kW used in land, sea or air vehicles and agricultural machinery (Decreto 227/025); tyre producers and importers (Decreto 358/015); lubricant producers and importers

California runs the most extensive set of state EPR laws in the US, anchored by SB 54, which makes producers of single-use packaging and plastic food service ware fund collection, recycling and source reduction through Circular Action Alliance as the state's PRO. CAA filed its program plan in June 2026 and CalRecycle must act on it by 1 January 2027. Separate laws cover paint, mattresses, carpet, batteries, pharmaceuticals and sharps, and textiles (SB 707, with Landbell USA approved as the PRO in March 2026).

Enforcement

Mandatory

Effective date

SB 54 signed 30 June 2022; permanent regulations effective 1 May 2026; Circular Action Alliance submitted the program plan 15 June 2026, with CalRecycle approval and program start due on or before 1 January 2027; first Plastic Pollution Mitigation Fund payment due 1 March 2027; full recyclability and 65% recycling rate by 1 January 2032; textiles (SB 707): producers had to join the PRO by 1 July 2026, PRO needs assessment due March 2027, approved plan required by July 2030 and full implementation in 2031

Covered entities

Producers of single-use packaging and plastic food service ware sold in California; paint, mattress, carpet, battery and battery-embedded product, pharmaceutical and sharps, and textile producers under each product-specific stewardship law

Oregon's Recycling Modernization Act makes producers of packaging, food service ware and printing paper join Circular Action Alliance as the state PRO and pay fees that fund expanded curbside service, processor upgrades and contamination reduction. In August 2026 a federal court upheld the law against a constitutional challenge. Paint, electronics and mattresses run under separate stewardship statutes administered by DEQ, and a 2026 battery law requires battery producer programs to operate by 1 July 2029.

Enforcement

Mandatory

Effective date

SB 582 effective 1 January 2022; RMA producer obligations operational from 1 July 2025; mattress program plan approved 25 July 2024 and collection began 1 January 2025; battery PRO plans due 1 September 2028 and programs operational by 1 July 2029; paint and e-cycles since the 2010s

Covered entities

Producers of packaging, food service ware and paper products sold in Oregon (over 1,700 registered); paint, mattress and electronics producers under separate stewardship laws; battery and battery-containing product producers from 2029

Washington became the seventh US state with packaging EPR when Governor Ferguson signed the Recycling Reform Act in May 2025, shifting recycling costs from local governments to producers through a producer responsibility organization. Ecology named Circular Action Alliance as the PRO in March 2026, and statewide curbside service under the program begins in 2030. Existing stewardship programs for electronics (E-Cycle) and paint (PaintCare) continue, and a battery stewardship program starts collection in July 2027.

Enforcement

Mandatory

Effective date

SB 5284 signed 17 May 2025; producers had to appoint a PRO by 1 January 2026; Ecology announced Circular Action Alliance as the PRO on 4 March 2026; producers had to be members of a registered PRO by 1 July 2026; statewide collection lists due October 2026; preliminary needs assessment January 2027 and full needs assessment December 2027; PRO draft program plan due 1 October 2028; program implementation from 2030; E-Cycle since 1 January 2009; battery program collects portable batteries from 1 July 2027 and medium-format batteries from 1 January 2029

Covered entities

Producers of glass, plastic, paper and metal packaging and paper products sold in Washington; covered electronic device manufacturers; paint and battery producers

Maine was the first US state to enact packaging EPR, with LD 1541 putting municipal recycling costs onto producers through a single stewardship organization that Maine DEP selects by competitive bidding. The 2025 amendment (LD 1423) changed scope and exemptions. DEP's 2026 RFP for the stewardship organization received no proposals, so producer registration, reporting and payments wait until DEP contracts an SO and sets a revised schedule.

Enforcement

Mandatory

Effective date

LD 1541 enacted 13 July 2021; LD 1423 amendments signed 20 June 2025; Chapter 428 rule adopted December 2024 and amended March 2026; stewardship organization RFP-202605094 closed with no proposals (DEP announcement 20 August 2026); DEP announced a revised RFP on 11 September 2026; producers must register within 90 days of the SO making a registration mechanism available; DEP is reassessing the reporting and payment schedule

Covered entities

Producers of packaging material sold in Maine, with exemptions for producers under USD 2 million gross annual revenue for the first three years after the SO contract (USD 5 million from program year four), producers using less than one ton of packaging in Maine, and the first 15 tons of perishable-food packaging; low-volume producers (under 15 tons a year) may use simplified reporting and a flat fee of USD 500 per ton; e-waste, paint and mattress producers under each stewardship law

Colorado's Producer Responsibility Program for Statewide Recycling Act requires producers of packaging and paper products to fund a uniform statewide recycling system through Circular Action Alliance as the designated PRO. Local governments and haulers receive reimbursement from PRO-collected dues, with the goal of raising the state recycling rate from 25% to 58% by 2035.

Enforcement

Mandatory

Effective date

HB22-1355 signed 3 June 2022; CDPHE designated Circular Action Alliance as PRO in May 2023; producers must participate in the program to sell covered materials since July 2025; first producer dues paid January 2026; CDPHE approved the CAA program plan in December 2025 and CAA had to begin implementing it by summer 2026; Interchange 360 automotive lubricant packaging program began March 2026; full statewide free residential service required by 1 January 2030

Covered entities

Producers of packaging materials and paper products sold or distributed to residences, public spaces, small businesses, schools, hospitality and government buildings in Colorado, above small-producer thresholds

Vermont was the first US state to require producer-funded recycling of single-use batteries (Act 139), alongside earlier producer stewardship laws for electronics (Act 79) and paint (Act 58 of 2013). A household hazardous products EPR law took effect in 2025; the Agency of Natural Resources received no valid stewardship organization registration and is pursuing an Agency-led program. Act 158 of 2026 converts the beverage container deposit system to a producer responsibility organization model and, from 1 July 2027, lets manufacturers register one stewardship organization per class of household hazardous products.

Enforcement

Mandatory

Effective date

Act 79 effective 1 July 2010 (collection 2011); Act 58 paint program effective 2013; Act 139 primary batteries effective 1 January 2016; household hazardous products EPR manufacturer registration due 1 November 2025, full implementation after 1 July 2026; Act 158 signed 17 June 2026 and effective 1 July 2026, with deposit initiators to apply to form a PRO by 1 January 2027, sales limited to PRO participants from 1 July 2027, PRO stewardship plan due 1 April 2028, and redemption rate goals of 75% from 1 July 2030 and 80% from 1 July 2033

Covered entities

Producers of covered electronic devices, architectural paint, primary and rechargeable batteries and covered household hazardous products sold in Vermont; beverage container deposit initiators; mercury thermostat manufacturers

New York runs product-by-product EPR through NYSDEC, covering electronics, rechargeable batteries, paint, mercury thermostats, pharmaceuticals and carpet, with each statute setting manufacturer registration, collection and reporting duties. The Packaging Reduction and Recycling Infrastructure Act did not pass in 2026: the Senate amended the bill in April but did not vote on it, and the Assembly Speaker did not bring it to the floor.

Enforcement

Mandatory

Effective date

Electronic Equipment Recycling and Reuse Act effective 28 May 2010 with collection from 1 April 2011; Rechargeable Battery Recycling Act signed 10 December 2010; Postconsumer Paint Collection Act effective 9 May 2022; Drug Take Back Act effective 2019; carpet EPR: under DEC enforcement discretion (19 December 2025, clarified 22 January 2026) plans are due 31 December 2026 and programs and the retailer sales restriction start 1 July 2027, while the ban on PFAS in carpet applies from 31 December 2026

Covered entities

Manufacturers of covered electronic equipment, rechargeable batteries, architectural paint, mercury thermostats and prescription drugs sold in New York; carpet producers (including carpet cushion and artificial turf) under the carpet EPR law

New Jersey's main EPR statute is the Electronic Waste Management Act, which makes manufacturers fund free recycling of TVs, monitors, computers and small printers for consumers and small businesses. The Electric and Hybrid Vehicle Battery Management Act, approved in January 2024, extends producer responsibility to vehicle propulsion batteries. New Jersey has no paint stewardship or packaging EPR law; a paint bill passed both houses in 2021 but was pocket vetoed in January 2022.

Enforcement

Mandatory for covered electronics and EV batteries

Effective date

E-Waste Act effective 1 January 2009; amendments in P.L. 2016, c.87 approved 9 January 2017; Electric and Hybrid Vehicle Battery Management Act (S3723) approved 8 January 2024 as P.L. 2023, c.222

Covered entities

Manufacturers of covered electronic devices sold in New Jersey; manufacturers of electric and hybrid vehicles for their propulsion batteries

Connecticut runs one of the broadest sets of US product stewardship laws under DEEP, beginning with electronics (2007) and now covering paint, mattresses, mercury thermostats, gas cylinders, tires and batteries. The mattress program (run by Mattress Recycling Council) recycles around 200,000 mattresses a year and saves municipalities millions in disposal fees.

Enforcement

Mandatory

Effective date

Electronics EPR effective 1 January 2009; paint 2011; mattresses 2013 (program running since May 2015); mercury thermostats 2014; gas cylinders 2022 (programs expected to start October 2025); tires 2023 (program expected to start March 2026); battery EPR enacted June 2025, with the Battery Network's plan submitted to DEEP on 1 July 2026 and public comment closed 7 August 2026

Covered entities

Manufacturers of covered electronics, paint, mattresses, mercury thermostats, propane and other gas cylinders, tires and batteries sold in Connecticut

Massachusetts has no EPR statute. MassDEP runs disposal bans on mattresses and textiles and chaired a legislative EPR commission whose January 2026 report recommended EPR programs for paint, mattresses, batteries and electronics. For plastics and other packaging, it recommended a MassDEP advisory subcommittee and a needs assessment within two years of funding. Paint bills H.886 and S.647 were reported favorably in 2025 and remain in the Ways and Means committees.

Enforcement

Mostly voluntary or disposal-ban based, pending legislation

Effective date

EPR Commission created by Chapter 239 of the Acts of 2024 (approved 20 November 2024) and formed in spring 2025; final report dated 15 January 2026 and placed on file in the Senate 29 January 2026; mattress and textile disposal bans effective 1 November 2022

Covered entities

No statutory producer obligations yet beyond waste bans; the commission recommended EPR for paint (by 1 July 2026), mattresses, batteries and electronics

Minnesota became the fifth US state with packaging EPR when Governor Walz signed the Packaging Waste and Cost Reduction Act in May 2024. Producers have had to belong to a PRO (Circular Action Alliance) since July 2025, and from 2032 covered packaging must be reusable, refillable, recyclable or compostable. MPCA runs the needs assessments and collection lists and oversees the program alongside existing electronics and paint stewardship laws.

Enforcement

Mandatory

Effective date

HF 3577 signed 21 May 2024; producers must be members of a registered PRO after 1 July 2025; the PRO's first annual registration listing producers and brands was due 1 July 2026; MPCA initial needs assessment due 31 December 2026; statewide recyclable and compostable lists due 1 July 2028; from 1 January 2029 producers may sell covered materials only under an approved stewardship plan; PRO reimbursement of service providers at no less than 50% of net cost by 1 February 2029, 75% by 1 February 2030 and 90% by 1 February 2031; from 1 January 2032 covered materials must be reusable, refillable, or on the recyclable or compostable lists; electronics program since 2007; paint program since 2014

Covered entities

Producers (brand owners, packaging manufacturers or distributors) of packaging and paper sold into Minnesota; electronics, paint and boat wrap producers under their respective laws

Illinois requires electronics manufacturers to register with Illinois EPA and fund recycling of covered devices under the 2017 Consumer Electronics Recycling Act. Paint manufacturers fund PaintCare drop-off sites under the Paint Stewardship Act (program launched December 2025), and since 1 January 2026 battery producers must take part in an approved stewardship plan (Illinois EPA approved The Battery Network's plan on 29 October 2025). Packaging EPR is not enacted; an advisory council under the Statewide Recycling Needs Assessment Act must report recommendations, including on producer responsibility for packaging and paper, by 1 December 2026.

Enforcement

Mandatory for electronics, paint and batteries; packaging not yet regulated

Effective date

Original e-waste law effective 1 January 2009; Consumer Electronics Recycling Act enacted 25 August 2017, effective 1 January 2019; Paint Stewardship Act signed 28 July 2023, effective 1 January 2024, PaintCare program launched December 2025; battery stewardship act signed 9 August 2024, producer participation required from 1 January 2026 and retailer sales restriction from 1 July 2026; recycling needs assessment advisory council report due 1 December 2026

Covered entities

Manufacturers of covered electronic devices sold to Illinois residents; manufacturers of architectural paint sold at retail in Illinois; producers of portable and medium-format batteries and battery-containing products sold in or into Illinois

Rhode Island bans televisions and computers from landfill and requires manufacturers to fund either their own take-back program or the state-run RI Resource Recovery Corporation scheme. Paint producers fund PaintCare drop-offs under the 2012 stewardship law, and mattress producers fund collection through a stewardship council whose plan the RI Resource Recovery Corporation approves. A 2025 law requires DEM to commission a statewide needs assessment for packaging, paper and beverage container recycling, with a final report due 1 December 2026.

Enforcement

Mandatory

Effective date

E-waste act effective 1 January 2009 with landfill ban from 2009; paint stewardship effective 1 July 2014; mattress stewardship council plan due 1 July 2015; packaging and beverage container needs assessment law effective 30 June 2025, with an interim report due 1 April 2026 and a final report due 1 December 2026

Covered entities

Manufacturers of covered electronic devices and architectural paint sold in Rhode Island; mattress producers through the mattress stewardship council; mercury thermostat producers

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.

Türkiye incorporated IFRS S1 and S2 fully into Turkish law as TSRS 1 and TSRS 2 on 29 December 2023, with mandatory application from fiscal year 2024 for listed entities, banks and other entities above size thresholds. KGK has since raised the size thresholds, removed portfolio management companies from scope, extended first-year transition reliefs for 2024 first-time reporters, and adopted the ISSB's greenhouse gas disclosure amendments to IFRS S2 as TSRS 2 amendments effective 2027.

Enforcement

Mandatory

Effective date

Fiscal periods starting on or after 1 January 2024; revised thresholds from periods starting on or after 1 January 2025; TSRS 2 GHG amendments from periods starting on or after 1 January 2027 (early application permitted)

Covered entities

All listed entities, banks (regardless of size, except banks within the Savings Deposit Insurance Fund and unlisted banks with one branch or fewer than 250 employees, which were not required to report for 2024 or 2025), and other entities exceeding two of three thresholds in two consecutive periods: total assets TRY 1 billion, annual net sales TRY 2 billion, 500 employees (KGK decision of 13 January 2026, replacing TRY 500m, TRY 1bn and 250 employees). Portfolio management companies were removed from mandatory scope by KGK decision of 14 August 2025.

Switzerland requires large public-interest companies to report on non-financial matters, with climate reporting based on the TCFD recommendations on a comply-or-explain basis. After the 2024 consultation, the Federal Council asked the FDJP to prepare simpler options. Its April 2026 NUFG consultation draft would require reports to follow a standard used in the EU (ESRS) or an equivalent standard recognized by the Federal Council, with limited assurance by an audit firm and supervision by the Federal Audit Oversight Authority. The explanatory report names IFRS Sustainability Disclosure Standards with GRI additions as a possible equivalent, but says equivalence is not yet clear.

Enforcement

Voluntary or under development

Effective date

Not yet specified. The NUFG draft leaves entry into force to the Federal Council, allows publication only once the popular initiative 'Für verantwortungsvolle Grossunternehmen' is withdrawn or rejected, and keeps prior law for financial years running at entry into force and those starting in the following two years

Covered entities

Current rules (Art. 964a CO): public-interest entities that, together with controlled entities, have at least 500 FTE on annual average and exceed CHF 20 million balance sheet total or CHF 40 million turnover, in two consecutive years; entities controlled by a reporting parent or one filing an equivalent foreign report are exempt. NUFG draft (Art. 9): Swiss companies that, with controlled entities, have more than 1,000 FTE and more than CHF 450 million worldwide turnover in two consecutive years, plus Swiss subsidiaries or branches of foreign groups with more than CHF 450 million Swiss turnover; the Federal Council estimates about 100 companies instead of about 200 today.

EU directive requiring in-scope companies to report sustainability information in their management report using the European Sustainability Reporting Standards (ESRS). Omnibus I (Directive (EU) 2026/470) raised the scope thresholds to 1,000 employees and EUR 450 million turnover and added a value chain cap. The revised ESRS (Delegated Regulation (EU) 2026/1563) cut the number of mandatory datapoints and apply from FY2027.

Enforcement

Mandatory

Effective date

Wave 1 (large public-interest entities with more than 500 employees) has reported since FY2024. Member States may exempt wave 1 undertakings below the new thresholds for FY2025 and FY2026. All other in-scope EU undertakings report from FY2027 (Directive (EU) 2025/794). Third-country groups report from FY2028. Omnibus I transposition deadline: 19 March 2027. Revised ESRS enter into force 10 November 2026 and apply to financial years beginning on or after 1 January 2027; undertakings may use them for FY2026.

Covered entities

EU undertakings and parent undertakings of groups that exceed both an average of 1,000 employees and EUR 450 million net turnover (Directive (EU) 2026/470). Listed SMEs are out of scope. Third-country groups with more than EUR 450 million net turnover in the EU in each of the last 2 consecutive financial years report through an EU subsidiary or branch with more than EUR 200 million net turnover. Value chain undertakings with 1,000 employees or fewer can decline information requests that go beyond the voluntary standard (Delegated Regulation (EU) 2026/1560).

Classification system defining environmentally sustainable economic activities. Article 8 requires in-scope undertakings to disclose the share of their turnover, CapEx and OpEx that comes from environmentally sustainable activities as defined by the taxonomy. Delegated Regulation (EU) 2026/73 simplified the reporting templates, lets non-financial undertakings skip assessing activities that together make up less than 10% of turnover or CapEx, lets them skip the OpEx assessment where OpEx is not material to the business model, and simplified certain do-no-significant-harm criteria.

Enforcement

Mandatory

Effective date

Article 8 disclosures apply from 1 January 2022 (phased by environmental objective). Simplified disclosure rules under Delegated Regulation (EU) 2026/73 apply from 1 January 2026; undertakings could keep the previous rules for FY2025.

Covered entities

Non-financial and financial undertakings required to publish sustainability information under Article 19a or 29a of Directive 2013/34/EU. Under Directive (EU) 2026/470, that means undertakings and groups exceeding 1,000 employees and EUR 450 million net turnover from FY2027; Member States may exempt smaller wave 1 undertakings for FY2025 and FY2026.

Fund-level and entity-level sustainability disclosure rules for EU financial market participants and advisers. The Commission's November 2025 review proposal would create 3 product categories (sustainable, transition and ESG basics) with minimum criteria, reduce disclosure volume, and apply 18 months after entry into force. The Council and Parliament's ECON committee have adopted their positions; trilogues follow Parliament's plenary vote.

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 very large EU and non-EU companies to identify, prevent and address adverse human rights and environmental impacts in their own operations, their subsidiaries' operations and their chains of activities. Omnibus I (Directive (EU) 2026/470) raised the thresholds, deleted the climate transition plan obligation, removed the EU-wide civil liability rule (liability now rests on national law), and capped fines at 3% of net worldwide turnover.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2028. National measures apply to all in-scope companies from 26 July 2029; Article 16 reporting applies for financial years starting on or after 1 January 2030.

Covered entities

EU companies with more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover, or ultimate parents of groups reaching those thresholds. Non-EU companies with more than EUR 1.5 billion net turnover in the EU in the financial year before the last. Separate thresholds apply to franchising and licensing groups (royalties above EUR 75 million plus turnover above EUR 275 million).

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. Entity-level disclosures from 2 December 2025 for firms with more than GBP 50bn AUM and from 2 December 2026 for firms with more than GBP 5bn AUM.

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 2021-663 of 27 May 2021, published in JORF n°0122 of 28 May 2021 and in force the day after publication (Art. D. 533-16-1 CMF in force 29 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 (codified at Art. L. 229-68 of the Environmental Code) prohibits advertisers from claiming that a product or service is carbon neutral, or using wording with an equivalent meaning, unless they make publicly available a GHG emissions report covering the product's direct and indirect emissions, the avoid-reduce-offset approach with a reduction trajectory and quantified annual targets, and the offsetting methods used. The environment minister can issue a formal notice and then fines of EUR 20,000 for individuals and EUR 100,000 for legal entities, raisable to the full amount spent on the unlawful operation (Art. L. 229-69).

Enforcement

Mandatory

Effective date

Law published 24 August 2021; Art. L. 229-68 Environmental Code in force since 25 August 2021; carbon-neutrality claim rules applied from 1 January 2023 (Decree 2022-539 of 13 April 2022; Art. R. 229-110 in force 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 in force as of 23 September 2026; Art. 12 provides for entry into force on a date set by Royal Decree, no earlier than 1 January 2020, and no date has been set

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. Micro and small operators and natural persons established by 31 December 2024 apply from 30 June 2027, except for timber products covered by the EU Timber Regulation (30 December 2026). Products added by Delegated Regulation (EU) 2026/2102 are covered from 30 December 2027.

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 products listed in Annex I. Delegated Regulation (EU) 2026/2102 removes cattle hides, skins and leather, retreaded tyres, soybeans for sowing, certain vulcanised rubber articles, conveyor and transmission belts, and aircraft and motor vehicle seats, and adds soluble coffee, certain palm oil derivatives and frozen cattle tongues (from 30 December 2027). 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 adopted 26 June 2026 (C(2026) 4386; OJ C/2026/4637, 3 September 2026). Forced Labour Single Portal launched 30 June 2026; the forced labour risk database is in development; the Single Information Submission Point opens 14 December 2027.

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.

The EU runs product-specific EPR regimes for packaging, electrical and electronic equipment, batteries, vehicles and single-use plastics, putting collection, recycling and recycled-content obligations on producers placing goods on the single market. The Packaging Regulation has applied directly in all Member States since 12 August 2026, with recyclability, reuse and recycled-content rules phasing in. The new End-of-Life Vehicles Regulation sets vehicle design, recycled-content and EPR rules from 1 September 2028.

Enforcement

Mandatory

Effective date

PPWR entered into force 11 February 2025 and has applied since 12 August 2026 (Article 67(5) from 12 February 2029; other obligations phase in later). Battery Regulation entered into force 17 August 2023 with phased obligations through 2027. ELV Regulation (EU) 2026/1738 entered into force 13 August 2026 and applies from 1 September 2028, when Directive 2000/53/EC is repealed (some Directive provisions continue until 2032). WEEE Directive in force since 2012; SUP Directive transposition deadline 3 July 2021.

Covered entities

Producers, importers and distributors placing packaging, EEE, batteries, vehicles or single-use plastic products on the EU market, regardless of material or origin

The UK runs separate producer responsibility regimes for packaging, electrical equipment, batteries and end-of-life vehicles. Under the 2024 pEPR rules, large packaging producers pay PackUK disposal fees that cover the cost of managing household packaging waste, and from year 2 (2026-27) those fees vary with recyclability. Producers still meet recycling obligations by obtaining packaging recycling notes (PRNs and PERNs).

Enforcement

Mandatory

Effective date

pEPR Regulations made 11 December 2024, in force 1 January 2025; first assessment year 2025-26 (first notices of liability October 2025, based on 2024 packaging data); confirmed year 2 (2026-27) fees due later in 2026; WEEE Regs since 1 January 2014; Battery Regs since 5 May 2009

Covered entities

Packaging producers established in the UK with annual turnover of GBP 1 million or more that supplied or imported more than 25 tonnes of packaging in the previous year. Large producers (turnover above GBP 2 million and more than 50 tonnes) pay household packaging disposal fees and must meet recycling obligations with PRNs or PERNs; small producers have fewer duties. WEEE producers placing EEE on the UK market; battery and ELV producers.

Switzerland operates advance disposal fee (vRG) schemes for electrical and electronic equipment, batteries, glass bottles and PET, run by industry organizations (SENS, SWICO, Inobat, PET-Recycling Schweiz) under federal ordinances. The Packaging Ordinance adopted in June 2026 replaces the beverage container rules: packaging must be minimized, suitable for recycling and use recycled content where feasible (from 2030); sellers of beverage cartons and single-use plastic packaging above the thresholds must take them back unless they finance an industry scheme (from 2031); and recycling rates of at least 70% for beverage cartons and 55% for single-use plastic packaging apply from 2032, with possible mandatory deposits if missed. Until then, collection of plastic packaging remains largely industry-led and voluntary.

Enforcement

Mandatory

Effective date

VREG in force since 1 July 1998, revised scope effective 1 January 2022; VVEA effective 1 January 2016, amended 1 August 2026; VerpV in force 1 January 2027, with advance disposal fee for glass packaging (Art. 8) from 1 January 2028, general packaging requirements (Art. 3) from 1 January 2030, subsidiary take-back duty for beverage cartons and single-use plastic packaging (Art. 4) from 1 January 2031, and minimum recycling rates (Art. 7) from 1 January 2032; battery and glass advance disposal fees in place since the 1990s

Covered entities

Manufacturers, importers and retailers of electrical and electronic equipment, batteries, glass and PET beverage containers placing products on the Swiss market. Under the VerpV: manufacturers and importers of glass packaging (extended beyond beverage containers from 2028); retailers and manufacturers placing filled beverage cartons or single-use plastic packaging on the market that exceed CHF 1 million turnover and 500 kg of packaging in two consecutive years (take-back duty from 2031 unless met through an industry organization); all retailers and manufacturers supplying filled packaging (design requirements from 2030).

Norway implements EU-style EPR through Avfallsforskriften, requiring producers of packaging, EEE, batteries and vehicles to join a producer responsibility organization approved by the Environment Agency. Since July 2025 the previous 1,000 kg-per-material exemption for packaging has been abolished, so every importer or producer must register and report. Chapter 7A requires producers of certain single-use plastic products to join an approved scheme and cover municipal cleanup and collection costs from 2027, and Chapter 7B sets EPR for plastic-containing fishing and aquaculture gear.

Enforcement

Mandatory

Effective date

Avfallsforskriften in force since 2004 (latest amendment FOR-2025-12-18-2839, in force 1 January 2026); Chapter 7 packaging EPR revised effective 1 July 2025 (lower registration limit removed); Chapter 7A in force on adoption (FOR-2025-11-12-2278), with the duty to cover municipal costs applying to costs from 1 January 2027 and first payment due 1 October 2028; Chapter 7B in force 1 January 2026, with §§ 7B-4 to 7B-7 applying from 1 March 2027; WEEE provisions since 1999

Covered entities

Any company that professionally imports or manufactures packaging, packaged products, EEE, batteries or vehicles for the Norwegian market; from July 2025 all packaging producers regardless of volume. Also producers that first place certain single-use plastic products on the Norwegian market (food and beverage containers, cups, flexible food packaging, light carrier bags, wet wipes, tobacco filters, balloons) and producers of fishing, recreational fishing and aquaculture gear containing plastic.

Türkiye runs a national Zero Waste framework that pairs source separation rules for institutions with producer responsibility duties for packaging and electrical equipment, all administered by the Ministry of Environment, Urbanisation and Climate Change. Packaging producers must register in the zero waste information system, hit recovery targets and pay deposits or fees set under the Packaging Waste Control Regulation.

Enforcement

Mandatory

Effective date

Zero Waste Regulation effective 12 July 2019, amended 9 October 2021; Packaging Waste Control Regulation effective 26 June 2021

Covered entities

Public institutions, large commercial premises, packaging producers and importers, EEE producers; building and premises operators required to set up zero waste systems on phased schedule in annexes

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.

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.

Singapore requires SGX-listed issuers to make climate disclosures based on IFRS S2 and the climate-related parts of IFRS S1, phased from FY2025: Scope 1 and 2 emissions for all issuers and full climate reporting for STI constituents first, with Scope 3 for STI constituents from FY2026. SGX RegCo and ACRA extended most timelines on 25 August 2025. On 27 July 2026 ACRA's Interim Sustainability Standards Committee opened consultation on draft SFRS S1 and SFRS S2, proposing that only SFRS S2 be mandatory.

Enforcement

Mandatory

Effective date

Listed issuers, FY starting on or after: 1 January 2025 – Scope 1 and 2 GHG emissions for all listed issuers, plus other ISSB-based climate disclosures for STI constituents; 1 January 2026 – Scope 3 for STI constituents; 1 January 2028 – other ISSB-based climate disclosures for non-STI issuers with market cap of S$1 billion or more (as at 30 June 2025); 1 January 2030 – other ISSB-based climate disclosures for non-STI issuers below S$1 billion. Large non-listed companies: ISSB-based climate disclosures including Scope 1 and 2 from FY2030. External limited assurance on Scope 1 and 2: listed issuers from FY2029, large non-listed companies from FY2032.

Covered entities

All SGX-listed issuers, phased by STI membership and market capitalization. Large non-listed companies with annual revenue of at least S$1 billion and total assets of at least S$500 million (from FY2030, to be set in legislation). Scope 3 stays voluntary for non-STI issuers and large non-listed companies until further notice.

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

Scope 1 and 2 GHG emissions mandatory for all listed issuers (Main Board and GEM) from FY2025. Other climate requirements (Part D of the ESG Code) on a comply-or-explain basis for all Main Board issuers from FY2025 and voluntary for GEM issuers. Mandatory for Hang Seng Composite LargeCap Index constituents from FY2026.

Effective date

Financial years commencing on or after 1 January 2025 (Scope 1 and 2 mandatory for all issuers; comply-or-explain for Main Board); financial years commencing on or after 1 January 2026 (mandatory for HSCI LargeCap constituents)

Covered entities

All HKEX-listed issuers (Scope 1 and 2); all Main Board issuers (comply-or-explain on other climate requirements); HSCI LargeCap constituents (mandatory); GEM issuers encouraged to report other climate requirements voluntarily

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 FSC requires TWSE- and TPEx-listed companies to include a dedicated 'Sustainability-related Financial Information' section in their annual reports, prepared under FSC-endorsed IFRS S1 and S2, in three phases from FY2026. The November 2025 rules require board approval, consistency with the financial reports, assurance on Scope 1 and 2 emissions and GHG Protocol measurement, and allow a three-year Scope 3 deferral.

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 (paid-in capital between TWD 5bn and TWD 10bn). Phase III: FY2028, reported in 2029 (all other listed companies). Scope 3 may be omitted for the first three fiscal years of application; Phase I companies begin Scope 3 with FY2029, reported by March 2030.

Covered entities

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

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.

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

Indonesia's IAI issued national Sustainability Disclosure Standards based on IFRS S1 and S2 (PSPK 1 and PSPK 2) on 1 July 2025, effective 1 January 2027. OJK consulted in February and March 2026 on a regulation that would require certain financial institutions, issuers and public companies to prepare sustainability reports under these standards; the final rule is pending.

Enforcement

Voluntary or under development

Effective date

PSPK 1 and PSPK 2 effective 1 January 2027. Which entities must apply them depends on the pending OJK regulation.

Covered entities

To be set by OJK. The draft OJK regulation (February 2026) covers financial services institutions, issuers and public companies. The IAI roadmap proposed climate disclosures first, with other sustainability topics voluntary in the initial period.

The Philippine SEC issued Memorandum Circular No. 16, s. 2025, adopting PFRS S1 and S2 (local versions of IFRS S1 and S2) with limited extra transition reliefs, including a two-year Scope 3 relief for all tiers. The largest listed companies start with FY2026, mid-sized listed companies with FY2027, and smaller listed companies, PDEx-only debt issuers and large non-listed companies with FY2028. Limited assurance over Scope 1 and 2 emissions follows two years after each tier starts.

Enforcement

Mandatory

Effective date

Tier 1 (PSE-listed, market cap above PHP 50bn as of 31 December 2025): FY beginning on or after 1 January 2026, reporting in 2027. Tier 2 (PSE-listed, market cap above PHP 3bn up to PHP 50bn): FY beginning on or after 1 January 2027, reporting in 2028. Tier 3 (PSE-listed with market cap of PHP 3bn or less; companies with debt securities listed only on PDEx; large non-listed entities with annual revenue above PHP 15bn): FY beginning on or after 1 January 2028, reporting in 2029. Limited assurance on Scope 1 and 2 required two years after each tier's first adoption.

Covered entities

Publicly listed companies (tiered by market capitalization), companies whose debt securities are listed only on PDEx, and large non-listed entities with annual revenue above PHP 15bn. Until their adoption year, listed companies continue to follow SEC MC No. 4, s. 2019.

Korea's KSSB finalized KSSB Standards No. 1 and No. 2, based on IFRS S1 and S2, on 26 February 2026. The FSC's final roadmap of 8 July 2026 makes sustainability disclosure part of statutory business reports under the FSCMA from 2028 (FY2027) for KOSPI companies with consolidated assets of KRW 10 trillion or more, widening to KRW 5 trillion in 2029, with a three-year liability safe harbor, third-party verification from 2030 and Scope 3 deferred to 2031 or later.

Enforcement

Mandatory under the announced roadmap once FSCMA and related rules are amended; voluntary until then

Effective date

Filing from 2028 for FY2027: KOSPI-listed companies with total consolidated assets of KRW 10 trillion or more. From 2029: threshold lowered to KRW 5 trillion. From 2030: authorities to consider lowering it to KRW 2 trillion after reviewing 2028 to 2029 practice. Third-party verification from 2030. Scope 3 deferred to 2031 (KRW 10 trillion or more), 2032 (KRW 5 trillion or more) and 2033 (KRW 2 trillion or more).

Covered entities

KOSPI-listed companies, phased by total consolidated assets (KRW 10 trillion, then KRW 5 trillion, possibly KRW 2 trillion), reporting on a consolidated basis. FSC estimates 291 companies (including affiliates) in 2028 and 3,171 in 2029. Other listed companies may disclose voluntarily through KRX using KSSB standards. SMEs that are not high emitters are exempt from Scope 3.

Thailand's SEC will require listed companies to apply IFRS S1 and S2 on a climate-first, phased basis, starting with Scope 1 and 2 GHG emissions backed by third-party assurance. In November 2025 it moved SET50 and SET100 companies back one year, so SET50 companies apply the standards from 2027 and report in 2028, while mai companies and listed trusts and funds come last, applying from 2030 and reporting in 2031.

Enforcement

Mandatory under approved principles; implementing regulations pending

Effective date

Effective year / reporting year: SET50 constituents (December 2026 index review) 2027 / 2028; SET100 constituents (December 2027 index review) 2028 / 2029; all other SET-listed companies, including IPOs, 2029 / 2030; mai-listed companies and listed REITs, infrastructure funds, infrastructure trusts and property funds, including IPOs, 2030 / 2031.

Covered entities

SET- and mai-listed companies (Thai or foreign incorporated) and IPO applicants, excluding non-listed companies and LiVEx issuers; listed REITs, infrastructure trusts, property funds and infrastructure funds

New Zealand's mandatory climate-related disclosure regime was introduced into the Financial Markets Conduct Act 2013 by a 2021 amendment. CREs report under the XRB's TCFD-based standards NZ CS 1, 2 and 3, and assurance of GHG disclosures follows NZ SAE 1. The XRB has proposed replacing these with an ISSB-based NZ IFRS S2.

Enforcement

Mandatory

Effective date

Reporting periods beginning on or after 1 January 2023

Covered entities

Climate reporting entities (CREs) under the Financial Markets Conduct Act 2013: large listed issuers (currently equity issuers above NZD 60 million market capitalization and debt issuers above NZD 60 million quoted face value), banks, building societies, insurers and investment scheme managers above set thresholds. The Financial Markets Conduct Amendment Bill proposes raising the listed-issuer threshold to NZD 1 billion for equity and debt issuers and removing managed investment schemes.

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

Corporations whose group meets a corporate group threshold (50,000 t CO2-e scope 1 and 2 emissions, or 200 TJ of energy produced or consumed) or that control a facility meeting a facility threshold (25,000 t CO2-e, or 100 TJ produced or consumed). The CER lists 890 registered controlling corporations for 2024-25.

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

ENRM Guidelines: issued 8 December 2020, effective June 2022 after an 18-month transition. Transition Planning Guidelines: issued 5 March 2026; 18-month transition from issuance (ends September 2027).

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.

Japan implements EPR through a stack of product-specific recycling laws, with manufacturers and importers funding take-back and recycling for packaging (JCPRA), large home appliances (AEHA), small electronics, end-of-life vehicles (JARC) and batteries (JBRC). MOE and METI jointly oversee the system, with consumers and retailers each carrying defined collection roles.

Enforcement

Mandatory

Effective date

Containers and Packaging Recycling Act fully effective 2000 (PET 1997); Home Appliance Recycling Act effective 1 April 2001; ELV Recycling Act fully effective 1 January 2005; Small Home Appliance Recycling Act effective 1 April 2013; amended Act on the Promotion of Effective Utilization of Resources in force 1 April 2026, with recycled-plastic plans applying from the first business year starting on or after 1 October 2026 (first plans due by end of September 2027)

Covered entities

Manufacturers, importers and users of containers and packaging (PET, glass, paper, plastic); manufacturers of four covered home appliances (TVs, fridges, washing machines, ACs); small appliance producers; vehicle manufacturers; battery producers. From April 2026, producers of plastic containers and packaging at 10,000 metric tons or more (excluding food packaging other than PET bottles, and medicines), automobiles at 10,000 units or more, and ACs, TVs, fridges and washing machines at 50,000 units or more must file recycled-plastic use plans and annual reports; manufacturers of mobile batteries, smartphones and heated tobacco devices carry take-back and recycling duties

South Korea was one of the first non-EU countries to adopt EPR. Under Article 16 of the Resource Recycling Act, producers and importers of packaging and listed products must meet annual mandatory recycling rates set by the Minister of Climate, Energy and Environment, and those that fall short pay recycling charges administered by the Korea Environment Corporation. From 2026 the EEE regime covers all electrical and electronic equipment rather than a fixed list of 50 items.

Enforcement

Mandatory

Effective date

EPR system launched 1 January 2003; EEE and ELV Act effective 1 January 2008; EEE EPR extended from 50 listed items to all electrical and electronic equipment from 1 January 2026, with listed exclusions

Covered entities

Manufacturers and importers of packaging (paper packs, metal cans, glass bottles, synthetic resin packaging) and of listed products (including lubricants, batteries, tires, fluorescent lamps and certain synthetic resin products) above sales thresholds; from 2026, manufacturers and importers of all electrical and electronic equipment, except excluded categories such as large industrial equipment and military goods and except manufacturers with sales under KRW 1 billion and importers under KRW 300 million

Under Articles 15 to 18 of the Waste Disposal Act, businesses responsible for designated articles and containers register with MOENV and pay recycling, clearance and disposal fees into the Resource Recycling Management Fund, which subsidizes certified collectors and recyclers (the 4-in-1 Recycling Program). The July 2026 amendments add designated renewable energy generation equipment to this system. The Resource Circulation Promotion Act, which replaced the Resource Recycling Act in June 2026, lets MOENV require green design, reuse and reduction plans, product disclosure and labeling, and producer responsibility organizations for designated waste products and packaging.

Enforcement

Mandatory

Effective date

4-in-1 Recycling Program established 1997; Resource Recycling Act promulgated 3 July 2002 and in force one year later; Resource Circulation Promotion Act promulgated 17 June 2026 and in force on promulgation, except Article 14 (mandatory green design for designated products) and Article 38(1), which take effect two years after promulgation; Waste Disposal Act amendments promulgated 15 July 2026 and in force on promulgation, except Articles 39 to 39-5 and related penalties, which take effect two years after promulgation

Covered entities

Manufacturers, importers and sellers of designated articles and their packaging and containers, and of the raw materials for them (including containers, batteries, tires, lubricants, electrical and electronic equipment and vehicles); from July 2026, manufacturers, importers and installers of designated renewable energy generation equipment; producers MOENV designates under the Resource Circulation Promotion Act for green design, reuse, reduction, labeling and producer responsibility organization duties

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

India runs separate EPR regimes for plastic packaging, e-waste, batteries, tires, used oil, end-of-life vehicles and construction and demolition waste, with products containing aluminum, copper and zinc added from April 2026. Producers register and report on CPCB's EPR portals and meet rising collection, recycling and recycled-content targets, mostly by buying EPR certificates generated by registered recyclers and processors.

Enforcement

Mandatory

Effective date

Plastic EPR Guidelines effective 16 February 2022, single-use ban from 1 July 2022; Battery Waste Rules effective 24 August 2022; Tire EPR effective 21 July 2022; E-Waste Rules 2022 effective 1 April 2023; used oil EPR effective 1 April 2024; ELV EPR effective 1 April 2025; C&D waste EPR effective 1 April 2026; non-ferrous metal EPR effective 1 April 2026

Covered entities

Producers, importers and brand owners (PIBOs) of plastic packaging; producers of listed electrical and electronic equipment; producers of all batteries; producers and importers of tires; makers, sellers and importers of base oil and lubricating oil under their own brand; vehicle producers (ELV Rules); building projects with a built-up area of 20,000 square meters or more (C&D Rules); producers of listed products containing aluminum, copper or zinc

Australia's federal product stewardship framework sits under the Recycling and Waste Reduction Act 2020. The National Television and Computer Recycling Scheme and the Australian Packaging Covenant are co-regulatory, used oil and mercury-added products have mandatory arrangements, and other products rely on accredited voluntary schemes. Container deposit schemes are run by the states and territories. Packaging reform and a national solar panel recycling pilot are in progress, but no new mandatory scheme has been made.

Enforcement

Mandatory for NTCRS and container deposit schemes; voluntary or co-regulatory for other product streams

Effective date

Product Stewardship Act 2011 commenced 8 August 2011 and was succeeded by the Recycling and Waste Reduction Act 2020 (No. 119, 2020), latest compilation 1 July 2026. NTCRS has operated since 2011. The first state container deposit scheme (SA) dates from 1977. Tasmania's scheme started 1 May 2025.

Covered entities

Liable parties (importers and manufacturers) of televisions, computers, printers and peripherals under NTCRS; brand owners under the co-regulatory packaging arrangement (Australian Packaging Covenant); parties covered by the mandatory mercury-added products rules; beverage suppliers under state and territory container deposit schemes. Government-accredited voluntary arrangements cover tyres, mobile phones, large plastic bags, plastic paint pails, power tools and newspapers.

New Zealand's Waste Minimisation Act lets the Minister for the Environment declare priority products that must be managed under accredited stewardship schemes. Six were declared in 2020. The tyre scheme, Tyrewise, has run since March 2024 with a stewardship fee on new tyres. The Government approved regulations for an agrichemicals and farm plastics scheme in December 2025.

Enforcement

Mandatory once schemes are accredited; voluntary accreditation otherwise

Effective date

Waste Minimisation Act 2008 in force from 26 September 2008; six priority products declared 30 July 2020; tyre scheme (Tyrewise) launched 1 March 2024

Covered entities

Producers and importers of six declared priority products: plastic packaging including beverage packaging, tyres, e-waste, refrigerants and other synthetic greenhouse gases, agrichemicals and their containers, and farm plastics

Singapore's Resource Sustainability Act covers e-waste, packaging and food waste. NEA has run a regulated e-waste EPR scheme since July 2021, and the Beverage Container Return Scheme, run by the NEA-licensed, producer-led BCRS Ltd., started on 1 April 2026 with a 10-cent deposit on plastic and metal beverage containers. Companies with turnover above SGD 10 million must report packaging data and 3R plans each year.

Enforcement

Mandatory

Effective date

Passed 4 September 2019; partially commenced 1 January 2020; regulated e-waste EPR scheme operational from 1 July 2021; food-waste segregation duties from 2024; Beverage Container Return Scheme commenced 1 April 2026, with a transition period to 30 September 2026, after which only containers bearing the Deposit Mark may be sold

Covered entities

Producers (manufacturers and importers) of regulated electrical and electronic products and their retailers; producers of pre-packaged beverages in plastic and metal containers of 150 ml to 3 L (Beverage Container Return Scheme); companies supplying regulated goods with annual turnover above SGD 10 million (mandatory packaging reporting); large food-waste generators

Vietnam's EPR regime under Articles 54 and 55 of the 2020 Law on Environmental Protection is now set out in Decree 110/2026/ND-CP, in force since 25 May 2026. Producers and importers must meet mandatory recycling rates for listed packaging, batteries, lubricants, tires and electronics, either by recycling themselves, working through a PRO or authorized recyclers, or paying into the Vietnam Environment Protection Fund. Road vehicles come in from 1 January 2027.

Enforcement

Mandatory

Effective date

LEP 2020 in force 1 January 2022; EPR recycling obligations under Decree 08/2022 from 1 January 2024 (packaging, batteries, lubricants, tires) and 1 January 2025 (EEE); Decree 110/2026/ND-CP issued 1 April 2026 and in force 25 May 2026, applying to obligations from 2026 onward; road vehicles placed on the market from 1 January 2027

Covered entities

Manufacturers and importers of products and packaging listed in Appendix I of Decree 110/2026: commercial packaging of food, cosmetics, medicines, fertilizer, animal feed, veterinary drugs, detergents and cement; batteries and accumulators; lubricants; tires; electrical and electronic equipment (including solar panels); road vehicles from 2027. Exempt: exports and temporary imports, and producers and importers whose revenue from the listed packaged goods is under VND 30 billion per year

The Philippines' Extended Producer Responsibility Act of 2022 makes large enterprises responsible for recovering a rising share of their plastic packaging footprint, from 20% in 2023 to 80% by 2028 and beyond. DENR oversees registration, audited compliance reports and PRO recognition under DAO 2023-02.

Enforcement

Mandatory

Effective date

RA 11898 lapsed into law on 23 July 2022 without the President's signature and took effect 15 days after publication (14 August 2022 [uncertain: publication date not re-verified]); IRR (DAO 2023-02) signed January 2023; recovery targets of 20% by 31 December 2023, 40% by 2024, 50% by 2025, 60% by 2026, 70% by 2027 and 80% by 31 December 2028 and every year after

Covered entities

Large enterprises (total assets above the medium-enterprise ceiling under RA 9501, PHP 100 million) that generate plastic packaging waste; enterprises sharing the same brand, label or trademark are obligated when their combined assets exceed that ceiling

Malaysia runs industry-led voluntary EPR through the Malaysian Recycling Alliance and is preparing a government EPR regulation for packaging, reported to begin as a voluntary phase in 2026 and become mandatory by 2030. The NRES Plastics Sustainability Roadmap 2021 to 2030, which first targeted mandatory EPR from 2026, sets 25% recycling of post-consumer plastic packaging by 2025, 15% average recycled content by 2030 and a 76% collected-for-recycling rate by 2030.

Enforcement

Voluntary today, becoming Mandatory

Effective date

Roadmap published 2021 (it planned a voluntary phase 2023 to 2025 and mandatory EPR from 2026); packaging EPR regulation reported to start with a voluntary phase in 2026 and become mandatory by 2030

Covered entities

Producers and brand owners of packaging, including plastics, participating voluntarily from 2026 (for example through the Malaysian Recycling Alliance, MAREA); mandatory obligations expected by 2030

Thailand does not yet have a mandatory EPR law. The Pollution Control Department drafted the Sustainable Packaging Management Act, which would require producers to fund recovery and recycling of glass, metal, paper, plastic and composite packaging through certified PROs, and held public consultations in 2024 and 2025. A separate draft WEEE Management Act was updated in September 2025.

Enforcement

Voluntary today, becoming Mandatory

Effective date

Draft Packaging Act posted for public hearing 18 March 2024; second public consultation 11 to 25 February 2025; no enactment found as of 23 September 2026; government intent reported as a mandatory regime by 2027 [uncertain]

Covered entities

Producers and importers of glass, metal, paper, plastic and composite packaging placed on the Thai market once the Sustainable Packaging Management Act is enacted

Indonesia's Ministerial Regulation 75/2019 imposes mandatory waste-reduction roadmaps on producers in manufacturing, retail and food service, requiring them to redesign products and packaging, take back used items and cut waste 30% by 2029. Single-use plastic items including styrofoam food packaging, plastic cutlery, straws and small sachets are slated for phase-out by 2029.

Enforcement

Mandatory

Effective date

PERMENLHK 75/2019 enacted 5 December 2019; ten-year roadmap covers 2020 to 2029 with 30% waste reduction target by 2029

Covered entities

Producers in the manufacturing, brand-owner, retail and food and beverage service sectors that use plastic, paper, metal or glass packaging and certain single-use items

Hong Kong's Product Eco-responsibility Ordinance is umbrella legislation under which EPD has rolled out three Producer Responsibility Schemes covering plastic shopping bags (2009), waste electrical and electronic equipment (2018, enhanced 2024) and glass beverage containers (2023). Suppliers pay levies that fund WEEE Park and licensed glass and plastic recyclers.

Enforcement

Mandatory

Effective date

PERO enacted July 2008; Plastic Shopping Bag Charging Scheme effective 7 July 2009 (full coverage 1 April 2015 and charge raised 31 December 2022); WEEE PRS effective 1 August 2018, enhanced scope from 1 July 2024; Glass PRS phased in first half 2023; Miscellaneous Amendments Bill 2025 passed by LegCo 23 July 2025

Covered entities

Suppliers and sellers of regulated electrical equipment (8 categories pre-2024, all EEE from July 2024), retailers selling plastic shopping bags, and suppliers of glass beverage containers placed on the Hong Kong market

The Institute of Chartered Accountants, Ghana adopted IFRS S1 and S2 through a roadmap approved on 28 March 2024. Voluntary use runs through periods ending 31 December 2026. Mandatory application starts with periods beginning on or after 1 January 2027 for Significant Public Interest Entities and specified high-impact sectors, then 1 January 2028 for other companies. An ISSA 5000 assurance roadmap dated 17 August 2026 phases in mandatory limited assurance from 2028 and reasonable assurance on all disclosures by 2031 for the first group.

Enforcement

Mandatory

Effective date

Voluntary: accounting periods beginning on or after 1 January 2024 through periods ending on or before 31 December 2026. Mandatory: periods beginning on or after 1 January 2027 for Significant Public Interest Entities, including specified oil and gas, mining, refinery, automobile, cement and non-renewable power generation companies; periods beginning on or after 1 January 2028 for Other Mandatory Adopters. Mandatory assurance (ICAG ISSA 5000 roadmap): SPIEs limited assurance from 1 January 2028, reasonable assurance with limited assurance on Scope 3 from 1 January 2029 to 31 December 2030, reasonable assurance on all disclosures from 1 January 2031; OMAs limited assurance from 1 January 2029, reasonable assurance with limited assurance on Scope 3 from 1 January 2030 to 31 December 2031, reasonable assurance on all disclosures from 1 January 2032

Covered entities

Significant Public Interest Entities: entities listed on any recognized exchange in Ghana; regulated non-listed banks, insurance companies, corporate trustees and registered pension schemes; public limited companies; private companies that are holding companies of public or regulated entities; and, regardless of listing, upstream oil and gas companies holding petroleum agreements, mining exploration and production companies, oil and gas refineries, automobile producers, cement manufacturers and non-renewable power generators. Other Mandatory Adopters: all other companies under the Companies Act, 2019 (Act 992) except SPIEs, government organizations (other than SOEs reporting under IFRS) and Non-Mandatory Companies. Non-Mandatory Companies (no public accountability, annual revenue of not more than GHS 50 million in the two preceding years or total assets of GHS 40 million) may apply voluntarily. Government and not-for-profit (IPSAS) entities: ICAG will set a date once IPSASB standards are issued

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 from 2024 and mandatory application for public interest entities from 2027, large non-public-interest entities from 2028 and SMEs from 2029. In 2026 ICPAK required public interest entities to complete a readiness assessment before the 2027 start; its September 2026 report found an average readiness score of 1.51 out of 4.

Enforcement

Mandatory

Effective date

Voluntary: accounting periods beginning on or after 1 January 2024. Mandatory: 1 January 2027 for public interest entities; 1 January 2028 for large non-public-interest entities; 1 January 2029 for SMEs. Government organizations reporting under IPSAS: 1 July 2028 according to ICPAK's September 2026 readiness report (the November 2024 roadmap notice listed this as to be determined by ICPAK). Mandatory assurance for PIEs: limited assurance from 1 January 2028, reasonable assurance with limited assurance on Scope 3 from 1 January 2029, reasonable assurance on all disclosures from 1 January 2030; large non-PIEs 2029, 2030 and 2031; SMEs 2030, 2031 and 2032; government organizations 1 July 2030, 2031 and 2032

Covered entities

Public interest entities, which ICPAK's 2026 readiness assessment covered as seven sectors: companies listed on the Nairobi Securities Exchange, commercial banks regulated by the Central Bank of Kenya, insurers regulated by the Insurance Regulatory Authority, retirement benefit schemes regulated by the Retirement Benefits Authority, fund managers of collective investment schemes and alternative investment funds regulated by the Capital Markets Authority, deposit-taking SACCOs regulated by SASRA, and large state corporations and government-controlled entities reporting under IFRS. Later phases: large non-PIEs (2028), SMEs (2029), and government organizations reporting under IPSAS

The Financial Reporting Council of Nigeria adopted IFRS S1 and S2 through a March 2024 roadmap, amended in February 2026 alongside Sustainability Reporting Guideline 1. Voluntary application runs to 2027. Mandatory application starts for public interest entities with periods beginning on or after 1 January 2028 and for SMEs from 2030, and governments move to the IPSASB climate standard from 2028.

Enforcement

Mandatory

Effective date

Early adopters: periods ending on or before 31 December 2023. Voluntary: accounting periods beginning on or after 1 January 2024 through periods ending on or before 31 December 2027. Mandatory: accounting periods beginning on or after 1 January 2028 for public interest entities; 1 January 2030 for SMEs (early adoption encouraged). Governments and government organizations: IPSASB SRS 1 from financial years beginning 1 January 2028. Assurance or verification required from the third year of reporting, reaching reasonable assurance on all disclosures from the seventh year

Covered entities

Public interest entities as defined in the FRC Act 2011 (as amended): listed entities, regulated non-listed entities, public limited companies, private holding companies of public or regulated entities, concession entities, privatized entities in which government keeps an interest, entities doing government public works with annual contract sums of N1 billion or more, government licensees, and other entities with annual turnover of N30 billion or more; SMEs from 2030. Governments and government organizations (also PIEs under the Act) apply IPSASB SRS 1 from 2028 instead of IFRS S1 and S2

The Institute of Certified Public Accountants Rwanda issued a roadmap adopting IFRS S1, IFRS S2 and future ISSB Standards across four entity groups. Group 1 Tier I financial institutions began simplified climate-only reporting in FY2025 while listed entities stayed on the Rwanda Stock Exchange ESG Guidelines. Listed entities move to simplified ISSB reporting in FY2026, and all Group 1 entities apply full ISSB Standards from FY2027.

Enforcement

Mandatory

Effective date

Group 1 (listed entities and Tier I financial institutions): Initial Phase from FY2025 (listed entities report under the RSE ESG Guidelines in this phase), 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): simplified framework from FY2028 and Intermediate Phase requirements from FY2029. Limited assurance is required in the second year of full ISSB application, with reasonable assurance after at most two years of limited assurance

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

Tanzania's National Board of Accountants and Auditors adopted IFRS S1 and S2 through Technical Pronouncement No. 1 of 2024 for public interest and public sector entities from financial years beginning on or after 1 January 2025. Technical Pronouncement No. 1 of 2026 sets where disclosures sit and permits a separate stand-alone sustainability report. It keeps public sector entities on IFRS S1 and S2 until IPSASB standards take effect and requires entities and audit firms to assess their readiness for ISSA 5000 assurance.

Enforcement

Mandatory

Effective date

Financial years commencing on or after 1 January 2025. Technical Pronouncement No. 1 of 2026 amendments apply to annual periods beginning 1 January 2027 (early adoption encouraged)

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

The Institute of Certified Public Accountants of Uganda adopted IFRS S1 and S2 on 4 September 2024 and approved its final implementation roadmap on 2 September 2025. Entities may report voluntarily from 2026. Mandatory application is phased from 2028 for listed entities, financial institutions, insurers and IFRS-reporting Government Business Entities, from 2029 for pension schemes, SACCOs, large companies and other public interest entities, and from 2030 for SMEs.

Enforcement

Mandatory

Effective date

Voluntary: accounting periods beginning on or after 1 January 2026 (readiness assessment required before reporting). Mandatory: 1 January 2028 for listed entities, financial institutions including microfinance deposit-taking institutions, insurers and reinsurers, and Government Business Entities using IFRS Accounting Standards; 1 January 2029 for retirement benefit schemes, SACCOs, large companies and other public interest entities; 1 January 2030 for SMEs. Government and other public sector entities: to be determined by ICPAU once IPSASB sustainability standards are available. Mandatory assurance (ISSA 5000) for the 2028 group: limited assurance from 1 January 2029, reasonable assurance excluding Scope 3, scenario analysis and transition plans from 2030, reasonable assurance with limited assurance on Scope 3 from 2031, reasonable assurance on all disclosures from 2032; one year later for the 2029 group

Covered entities

2028: entities whose debt or equity is traded, or being issued for trading, on a domestic, foreign or over-the-counter market; all financial institutions and microfinance deposit-taking institutions; insurers and reinsurers; and Government Business Entities applying IFRS Accounting Standards. 2029: retirement benefit schemes, SACCOs, large companies and other public interest entities as defined in ICPAU's IFRS for SMEs implementation guidelines. 2030: SMEs. All entities may report voluntarily from 2026

Zimbabwe's Public Accountants and Auditors Board issued a final roadmap on 11 April 2026 for applying IFRS S1 and S2. Listed companies, banks, IFRS-reporting state-owned enterprises and high environmental impact entities report voluntarily in 2026 and 2027 and must apply the standards from 2028. Other public interest entities and smaller entities follow from 2029, and public sector entities will get a separate IPSAS roadmap.

Enforcement

Mandatory

Effective date

Category 1: voluntary 2026 and 2027; mandatory from 2028 (IFRS S1 and S2 with standard and jurisdictional transitional exemptions); full IFRS S2 compliance by 2030 and full ISSB compliance by 2031. Category 2: voluntary 2026 to 2028; mandatory from 2029; full ISSB compliance by 2032. Category 3: voluntary 2026 to 2028; mandatory from 2029 (entity chooses areas to report on), IFRS S1 and S2 apply from 2030, full ISSB compliance by 2033. Category 4 (IPSAS public sector entities): separate roadmap to follow. Years are the reporting years shown in the roadmap tables

Covered entities

All entities preparing general purpose financial statements under IFRS, in four categories. Category 1: listed companies (ZSE and VFEX), banking institutions and building societies, state-owned enterprises applying IFRS, and high environmental impact entities applying IFRS (including those carrying out activities that require an Environmental Impact Assessment under the Environmental Management Act). Category 2: unlisted insurers and reinsurers, life and funeral assurers, deposit-taking microfinance institutions, pension funds and other public interest entities. Category 3: non-deposit-taking microfinance institutions, micro-insurers and entities without public interest. Category 4: public sector entities applying IPSAS

South Africa's Section 18 EPR Regulations make producers and importers of paper, packaging, electrical and electronic equipment and lighting responsible for collection, recycling and recovery targets set by DFFE, either individually or via a PRO. Reporting against gazetted targets has been running since January 2022, with progressive expansion to additional waste streams.

Enforcement

Mandatory

Effective date

Section 18 Regulations published 5 November 2020, in force 5 May 2021; producer registration deadline 5 November 2021; first reporting against targets January 2022

Covered entities

Producers (manufacturers, brand owners, importers and converters) and PROs in six sectors: paper and packaging, electrical and electronic equipment, lighting, lubricant oils, pesticides and portable batteries. DFFE's EPR system shows 2,009 registered producers and 86 PROs across these sectors (draft NWMS 2026, Table 6). No textiles EPR notice has been gazetted.

Kenya's 2024 EPR Regulations make producers and importers of packaging, EEE, batteries, vehicles and a wide list of non-packaging items register with NEMA, submit four-year EPR plans, build take-back systems and report annually. The rules implement the polluter-pays principle introduced by the Sustainable Waste Management Act 2022.

Enforcement

Mandatory

Effective date

Regulations gazetted 4 November 2024; producers in operation before commencement had six months to apply for registration with NEMA (by 4 May 2025) under regulation 23; importers must obtain an EPR Import Certificate through the National Electronic Single Window System from 14 March 2026

Covered entities

Producers and importers of five product categories: non-hazardous packaging; hazardous packaging including industrial chemicals, oils, pharmaceuticals, agrochemicals, paints and solvents; EEE, batteries and mercury devices; end-of-life motor vehicles and machinery; non-packaging items including textiles, furniture, tyres, diapers and sanitary products

Israel makes manufacturers and importers of packaging, electrical equipment, batteries and beverage containers responsible for collection and recycling targets set by the Ministry of Environmental Protection. The Packaging Law requires at least 60% recycling of packaging waste. For 2026–2027 the Deposit Law sets an annual collection target of 73% and a two-year average target of 77% for beverage containers, and 90% of collected containers must be recycled.

Enforcement

Mandatory

Effective date

Packaging Law passed 19 January 2011, in force 1 March 2011; Deposit Law passed 1999, implemented October 2001, expanded to 1.5 to 5 litre containers 1 December 2021; EEE and Batteries Law effective 1 March 2014

Covered entities

Manufacturers and importers of packaging, beverage containers, electrical and electronic equipment, and portable batteries placed on the Israeli market

The status of extended producer responsibility in the UAE is uncertain. On 23 September 2026 MOCCAE's legislation page listed Federal Law No. 12 of 2018 on Integrated Waste Management, its executive regulation (Cabinet Resolution No. 39 of 2021), Cabinet Resolution No. 116 of 2023 on recyclables establishments and Ministerial Decision No. 380 of 2022 on single-use products, but no federal EPR instrument. This entry reports only what the authority's site shows. Companies should confirm the current position with MOCCAE and the relevant emirate authority before relying on it.

Enforcement

Not established (no EPR instrument found on the authority's site)

Effective date

No EPR start date found. Federal Law No. 12 of 2018 and Cabinet Resolution No. 39 of 2021 are listed on MOCCAE's legislation page; whether they carry producer responsibility obligations was not confirmed.

Covered entities

Not confirmed. No EPR scheme with defined obligated producers was found on MOCCAE's legislation page.

Morocco's main waste statute Loi 28-00 set the framework for integrated waste management, complemented by Loi 77-15 banning single-use plastic bags and an ecotax on plastic raw materials. A formal REP scheme for household packaging is in preparation by the Ministère de la Transition Énergétique under work supported by GIZ and the World Bank.

Enforcement

Mandatory for waste management duties; REP for packaging not yet implemented

Effective date

Loi 28-00 promulgated 22 November 2006; Loi 77-15 plastic bag ban effective 1 July 2016; ecotax decree implemented 2014 to 2015

Covered entities

Producers, importers and distributors of plastic raw materials (subject to ecotax); future REP scheme expected to cover household packaging producers

Nigeria's National Environmental (Plastic Waste Control) Regulations, 2026 make plastic EPR mandatory across the value chain. Producers, importers and brand owners must fund and organize recovery of the plastics they place on the market, obtain permits and registrations, report through a central data platform, and meet recycled-content targets for PET packaging of 25% from 2028 and 50% from 2030. EPR for electronics and food and beverage packaging continues under NESREA's EPR program.

Enforcement

Mandatory for plastics (phased); other streams under NESREA's EPR program and sector regulations

Effective date

Sanitation and Wastes Control Regulations effective 2009; NESREA EPR program from 2014 (food and beverage) and 2016 (EEE); Plastic Waste Control Regulations, 2026 gazetted by June 2026 and publicly unveiled 4 September 2026, with recycled PET content of 25% required from 1 January 2028 and 50% from 1 January 2030

Covered entities

Producers, converters, brand owners, importers, retailers, recyclers and waste managers across the plastics value chain; producers, importers and distributors of electrical and electronic equipment and food and beverage packaging

Egypt's Waste Management Law 202/2020 established a Waste Management Regulatory Authority and set EPR as a principle in Article 17, with details left to executive regulations and product-by-product decrees. The first concrete EPR step is a 37.5 EGP per kilogram fee on certain single-use plastic shopping bags under PM Decree 662/2025, effective June 2025.

Enforcement

Mandatory

Effective date

Law 202/2020 issued October 2020; Executive Regulations effective February 2022; PM Decree 662/2025 issued 2 March 2025 with fees from 3 June 2025

Covered entities

Producers and importers of priority products designated by the Minister of Environment; from 2025, producers and importers of single-use plastic shopping bags

Ghana's Environmental Protection Act, 2025 (Act 1124) repealed Act 917 and carries forward the advance eco levy on electrical and electronic equipment, paid into an Electrical and Electronic Waste Management Fund, along with take-back obligations; L.I. 2250 stays in force under the Act. A separate Extended Producer Responsibility Act covering packaging, plastics, glass, metals, textiles and electronics is being drafted, and EPA Ghana is preparing to enforce a ban on Styrofoam takeaway products from January 2027.

Enforcement

Mandatory for EEE; Voluntary or pending for other streams

Effective date

Act 1124 assented 6 January 2025, repealing Act 917; L.I. 2250 in force since 2016 and continued under Act 1124; Styrofoam (EPS) takeaway product ban from January 2027; broader EPR Act not enacted as of 23 September 2026

Covered entities

Producers and importers of electrical and electronic equipment pay the advance eco levy under Act 1124; the proposed EPR Act would extend obligations to producers of packaging, plastics, glass, metals and textiles

Rwanda applies a polluter-pays approach through an environmental levy of 0.2% on imports packaged in plastic and a strict ban on plastic carry bags and single-use plastics. Manufacturers, wholesalers and retailers must collect and segregate used plastic items and hand them to licensed recyclers, while e-waste obligations sit under a 2019 ministerial order administered by REMA.

Enforcement

Mandatory

Effective date

Plastic carry bag and single-use plastics ban under Law No. 17/2019 of 10 August 2019; environmental levy of 0.2% on plastic-packaged imports [uncertain: legal basis cited as Law 48/2017 not verified]; e-waste ministerial order operational from 2019 [uncertain]

Covered entities

Manufacturers, importers, wholesalers and retailers of plastic carry bags, single-use plastic items, electrical and electronic equipment and imported plastic-packaged goods

Tunisia's ECO-LEF system is one of Africa's oldest packaging EPR-style schemes, financed by a 7% ecotax on imported plastic raw materials and managed by ANGED to subsidise licensed collectors and recyclers. The system has shrunk in recent years, prompting calls for reform and modernisation toward a fuller REP framework.

Enforcement

Mandatory

Effective date

ECO-LEF launched 1997; revised 2001; system covered about 180 enterprises in 2004, reduced to roughly 30 collectors and recyclers by 2025

Covered entities

Importers of plastic raw materials (subject to 7% ecotax) and packaging producers placing products on the Tunisian market