Want to know when climate-related disclosure will be required for businesses/institutions in your country and which standard is mandated? In this post, we will summarize mandatory climate reporting around the world continent by continent. And we will strive to keep this list updated for you.
Africa
South Africa
South Africa is currently the only African country with a mandatory climate-related disclosure regulation. Their Companies Act of 2008 requires large companies listed on the Johannesburg Stock Exchange (JSE) to disclose certain environmental information, including greenhouse gas emissions. That said, there is no specific standard or exact date for South Africa’s mandated climate-related disclosure.
Other African Countries
Several other African countries are also considering or developing mandatory climate disclosure regulations, including:
- Kenya
- Morocco
- Nigeria
Asia-Pacific
Australia
ClDisclosures are expected to be mandatory in Australia starting as early as mid-2024 for some large companies, based on the International Sustainability Standards Board’s (ISSB) climate standard, IFRS S2. The exact rollout will be phased in over the next few years.
Learn more: https://www.jdsupra.com/legalnews/mandatory-climate-related-financial-8672596/
Hong Kong
Climate-related disclosures in Hong Kong become mandatory for listed companies starting on January 1, 2025. The mandated standard aligns with the International Sustainability Standards Board’s (ISSB) climate standard, IFRS S2.
India
Securities and Exchange Board of India (SEBI) has mandated the top 1000 listed companies to make ESG disclosures under the framework of Business Responsibility and Sustainability Report (BRSR). Starting financial year 2024–25, the top 250 listed companies are required to disclose Scope 3 GHG emissions.
Learn more: https://insights.slaughterandmay.com/apac-esg-india/index.html
New Zealand
In New Zealand, mandatory climate-related disclosures have been in effect since 2023 for major financial institutions covered by the Financial Markets Conduct Act (FMC Act), including banks, insurers, and investment managers. New Zealand doesn’t have a single mandated standard. However, the regulations require these institutions to report in accordance with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations.
Learn more: https://www.fma.govt.nz/business/services/climate-reporting-entities/
Singapore
Mandatory climate-related disclosures in Singapore will be phased in starting in fiscal year 2025. Disclosures need to align with the International Sustainability Standards Board’s (ISSB) standards, specifically IFRS S1 and S2.
Other APAC Countries
Other Asia-Pacific countries on path to mandatory climate disclosure include:
- China
- Japan
- South Korea
Middle East
There are currently no mandatory requirements in Middle Eastern countries for sustainability reporting. However, the following Middle Eastern countries encourage climate related disclosure:
- Saudi Arabia
- UAE
Europe
European Union
Starting 2024, large companies (> 500 employees), banks & insurance companies in EU member countries are required to make climate- related disclosure in accordance with the EU Corporate Sustainability Reporting Directive (CSRD). This mandatory disclosure will roll out in 3 stages:
- 2024: Companies and their subsidiaries already submitting non-financial reports;
- 2025: Large companies and their subsidiaries that are currently not subjected to non-financial reports;
- 2026: Listed SMEs.
Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2464
France
In France, large companies and institutional investors had been gradually required to make climate-related disclosure since 2010 according to the French Reporting Act (Grenelle II), which is aligned with TCFD recommendations and EU Taxonomy.
Germany
Since 2017, large companies meeting at least two of three criteria: > 250 employees, turnover exceeding €40 million, balance sheet total exceeding €20 million need to make climate-related disclosure according to the Non-Financial Reporting Directive (NFRD) in Germany, which is aligned with TCFD recommendations. This requirement is expected to be superseded by EU CSRD.
Switzerland
Climate-related disclosure is mandatory for listed companies with over 500 employees, over CHF 20 million in assets or over CHF 40 million in turnover in Switzerland starting 1 January 2024 according to the Swiss Ordinance against Unsustainable Practices (OUNP), which is aligned with TCFD recommendations.
Learn more: https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-91859.html
United Kingdom
Starting 6 April 2022 in the UK, large public interest entities (companies listed on a stock exchange, credit institutions, and insurance companies) are required to disclose climate-related financial information in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)..
Other European Countries
The following European countries encourage voluntary adoption of climate-related disclosure:
- Denmark
- Netherlands
- Norway
- Sweden
North America
Canada
In Canada, climate-related disclosure is gradually phased-in starting 2024 for banks, insurance companies, and other federally incorporated or registered trust and loan companies, following Task Force on Climate-related Financial Disclosures (TCFD) standards. Public companies are expected to follow in the near future.
United States
On March 6, 2024, the Securities and Exchange Commission (SEC) adopted final rules to enhance and standardize climate-related disclosures by public companies and in public offerings. These rules require registrants to disclose material climate-related risks, activities to mitigate or adapt to such risks, information about the registrant’s board of directors’ oversight of climate-related risks, management’s role in managing material climate-related risks, and information on any climate-related targets or goals that are material to the registrant’s business, results of operations, or financial condition. Additionally, the rules mandate disclosure of Scope 1 and/or Scope 2 greenhouse gas (GHG) emissions by certain larger registrants when those emissions are material. The compliance date depends on the registrant’s filer status and the content of the disclosure:
- 2024: Large accelerated filers
- 2025: Accelerated and non-accelerated filers
- 2026: Smaller reporting companies
Learn more:
- https://www.sec.gov/files/33-11275-fact-sheet.pdf
- https://dart.deloitte.com/USDART/home/publications/deloitte/heads-up/2024/sec-climate-disclosure-requirements-ghg-emissions-executive-summary
South America
There are currently no mandatory requirements in South American countries for sustainability reporting. However, the following South American countries encourage climate related disclosure:
- Brazil
- Chile
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