Regulatory tracker: Corporate climate disclosures rules by jurisdiction — what's live, pending, and proposed

More than 50 countries now have live, pending, or proposed corporate climate disclosure rules, up from fewer than 10 in 2020. For multinational companies and their procurement teams, tracking which rules apply, where, and by when has become a compliance function in its own right. This tracker breaks down the regulatory landscape jurisdiction by jurisdiction so teams can prioritize readiness investments where enforcement is imminent.

Why It Matters

Climate disclosure regulation is no longer concentrated in Europe. Mandatory reporting requirements are spreading across Asia-Pacific, the Americas, and parts of Africa, creating a patchwork of overlapping obligations. Companies operating in multiple jurisdictions face divergent timelines, scope requirements, and assurance expectations. Procurement teams are directly affected because supply chain emissions (Scope 3) feature prominently in most new frameworks, meaning disclosure obligations cascade through supplier networks regardless of where a supplier is headquartered.

The cost of non-compliance is rising. The EU's Corporate Sustainability Reporting Directive (CSRD) carries penalties up to 10 million euros or 5% of net turnover in some member states. California's SB 253 imposes escalating fines for late or inaccurate filings. And beyond direct penalties, companies that lag on disclosure face procurement exclusion as large buyers increasingly require verified emissions data from suppliers.

Key Concepts

Mandatory vs. voluntary disclosure: Mandatory rules require reporting by law with penalties for non-compliance. Voluntary frameworks like CDP or GRI remain important but are increasingly being absorbed into mandatory requirements.

Scope coverage: Rules differ in whether they require Scope 1 only, Scope 1-2, or full Scope 1-2-3 disclosure. Scope 3 requirements carry the highest compliance burden because they depend on data from suppliers and customers.

Assurance levels: Limited assurance involves analytical review procedures. Reasonable assurance requires detailed testing of data and controls, equivalent to a financial audit. Most new regulations start with limited assurance and escalate to reasonable assurance over two to four years.

Double materiality: Some frameworks (notably CSRD) require companies to report both how climate risks affect the company (financial materiality) and how the company affects the climate (impact materiality). Others focus on financial materiality alone.

What's Live: Regulations Currently in Force

European Union: CSRD

The Corporate Sustainability Reporting Directive took effect for the first wave of companies (large public-interest entities with 500+ employees) in January 2024 for fiscal year 2024 reporting. The second wave covering all large companies began January 2025. Reporting follows the European Sustainability Reporting Standards (ESRS), which require full Scope 1, 2, and 3 disclosure, double materiality assessments, transition plans, and limited assurance. Reasonable assurance requirements phase in by 2028. Approximately 50,000 companies fall within scope, including non-EU companies with significant EU revenues starting in 2028.

United Kingdom: Streamlined Energy and Carbon Reporting (SECR) and TPT

The UK's SECR rules, live since 2019, require quoted companies and large unquoted companies to disclose energy consumption and Scope 1-2 emissions in annual reports. The Transition Plan Taskforce (TPT) framework, endorsed by the Financial Conduct Authority, requires premium-listed companies to publish transition plans or explain why they have not. The UK government confirmed in 2025 that it will adopt UK-endorsed ISSB standards (IFRS S1 and S2) for large companies, with first reports expected for fiscal years beginning on or after January 2026.

Japan: Amended Financial Instruments and Exchange Act

Japan's Financial Services Agency mandated climate-related disclosures aligned with ISSB standards for approximately 4,000 listed companies starting April 2025. Disclosures are included in annual securities reports and require Scope 1 and 2 reporting, with Scope 3 on a comply-or-explain basis. Third-party assurance is expected to become mandatory by fiscal year 2027.

California: SB 253 and SB 261

California's Climate Corporate Data Accountability Act (SB 253) requires companies doing business in California with over $1 billion in annual revenue to report Scope 1, 2, and 3 emissions starting in 2026 (for fiscal year 2025 data). SB 261 requires companies with over $500 million in revenue to prepare climate-related financial risk reports. Independent third-party verification is required, with limited assurance for Scope 1-2 immediately and Scope 3 assurance phasing in by 2030.

Singapore: SGX Listing Rules

The Singapore Exchange mandated climate reporting aligned with TCFD recommendations for all listed issuers starting fiscal year 2024. From 2025, reporting must align with ISSB standards (IFRS S2). External assurance is required for Scope 1 and 2 emissions from 2027 onward.

What's Pending: Rules Finalized but Not Yet Fully Effective

United States: SEC Climate Disclosure Rules

The SEC finalized climate disclosure rules in March 2024, requiring large accelerated filers to disclose Scope 1 and 2 emissions with phased-in assurance requirements. The rule does not mandate Scope 3 disclosure but requires qualitative descriptions of material climate risks and transition activities. Legal challenges have delayed implementation, with the rule currently stayed pending court decisions. If upheld, first reports would apply to fiscal years beginning in 2025 for large accelerated filers.

Australia: Treasury Laws Amendment

Australia passed mandatory climate reporting legislation in 2024. Group 1 entities (large reporters with revenues above AUD 500 million) must report for fiscal years starting July 2025. Scope 3 reporting is required from the second year onward. The framework aligns with ISSB standards and requires limited assurance from the first reporting period, escalating to reasonable assurance by 2030.

Brazil: CVM Resolution

Brazil's securities regulator (CVM) issued Resolution 193 requiring listed companies to report sustainability information aligned with ISSB standards starting fiscal year 2026. The first year allows voluntary adoption with mandatory compliance beginning 2027. Scope 3 reporting is required on a phased basis.

India: BRSR Core

The Securities and Exchange Board of India (SEBI) mandated the Business Responsibility and Sustainability Report (BRSR) for the top 1,000 listed companies by market capitalization. The BRSR Core framework, requiring reasonable assurance for select KPIs including Scope 1 and 2 emissions, became mandatory for the top 150 companies in fiscal year 2024-25, extending to the top 500 by 2026-27. Scope 3 disclosure remains voluntary but is included in the extended BRSR framework.

Hong Kong: HKEX Enhanced Climate Reporting

The Hong Kong Stock Exchange enhanced its ESG reporting requirements effective January 2025, mandating climate disclosures aligned with ISSB standards for all listed issuers. Scope 1 and 2 disclosure is mandatory, with Scope 3 on a comply-or-explain basis for the first two years. Interim disclosures are required within a specified timeframe.

What's Proposed: Rules Under Development

Canada: Proposed Scope 3 Standards

Canada's securities regulators proposed mandatory climate disclosure rules aligned with ISSB standards. The current proposal includes Scope 1 and 2 for reporting issuers, with Scope 3 under consultation. Industry feedback pushed back on the pace of Scope 3 requirements, and final rules are expected in late 2026.

South Korea: Korea Sustainability Disclosure Standards (KSDS)

South Korea's Financial Services Commission announced mandatory sustainability reporting using KSDS (based on ISSB standards) for listed companies with assets above KRW 2 trillion, starting 2027. Full market coverage is planned by 2030. Scope 3 disclosure will follow a phased approach.

European Union: CSRD Extension to Non-EU Companies

The CSRD's third wave, effective from fiscal year 2028, extends reporting obligations to non-EU companies generating over 150 million euros in EU revenues. This provision brings an estimated 10,000 additional companies into scope, many headquartered in the United States, China, and other markets with different domestic requirements.

South Africa: JSE Climate Disclosure Guidance

The Johannesburg Stock Exchange issued climate disclosure guidance aligned with ISSB standards and is consulting on mandatory adoption for all listed issuers. A final determination is expected in 2026, with mandatory reporting likely starting fiscal year 2027.

What's Working

ISSB convergence is reducing fragmentation. More than 20 jurisdictions have committed to adopting or aligning with IFRS S1 and S2, creating a baseline that reduces duplication for multinational reporters. Companies that build ISSB-aligned data infrastructure can serve multiple regulatory requirements simultaneously.

Phased approaches are improving data quality. Jurisdictions that start with Scope 1-2 and phase in Scope 3 over two to three years report higher data quality in initial filings. Japan and Singapore's experience shows that comply-or-explain provisions for Scope 3 allow companies to improve measurement methodology before mandatory deadlines.

Digital reporting taxonomies are accelerating compliance. The ESRS digital taxonomy (XBRL) and similar machine-readable formats being developed for ISSB-aligned jurisdictions allow automated data validation and cross-jurisdictional comparisons.

What's Not Working

Scope 3 data remains the primary bottleneck. Despite advances in carbon accounting software, supplier-specific emissions data is available for fewer than 35% of Scope 3 categories in most filings. Procurement teams struggle to collect verified data from tier-2 and tier-3 suppliers, particularly in emerging markets where capacity is limited.

Assurance capacity is constrained. The rapid expansion of mandatory assurance requirements has outpaced the availability of qualified sustainability assurance providers. Wait times for Big 4 sustainability assurance engagements exceeded six months in major markets during 2025, and costs have increased 25-40% year over year.

Legal uncertainty in the US creates planning challenges. The ongoing litigation around SEC climate rules leaves US-headquartered companies uncertain about federal requirements, even as California and state-level rules advance. Many companies are preparing for the SEC rule while simultaneously building compliance programs for CSRD and California requirements.

Key Players

Established Leaders

• IFRS Foundation (ISSB): Sets global baseline sustainability disclosure standards adopted by 20+ jurisdictions. IFRS S1 and S2 provide the foundation for most new regulations.
• European Financial Reporting Advisory Group (EFRAG): Developed the ESRS standards underpinning CSRD. Maintains ongoing technical guidance and Q&A processes.
• International Auditing and Assurance Standards Board (IAASB): Developing ISSA 5000, the global standard for sustainability assurance engagements expected to be finalized in late 2026.

Emerging Startups

• Persefoni: Carbon accounting platform supporting CSRD, SEC, and ISSB disclosure requirements. Used by 200+ enterprises across multiple jurisdictions.
• Sweep: Paris-based carbon management platform with multi-framework compliance for EU and global regulations.
• Watershed: Enterprise carbon accounting software used by Stripe, Airbnb, and Klarna with expanding regulatory reporting modules.
• Plan A: Berlin-based platform offering automated CSRD and ESRS compliance with supplier engagement tools.

Key Investors and Funders

• Sequoia Capital: Lead investor in Watershed and multiple carbon accounting platforms.
• World Bank Group: Funding capacity building for climate disclosure in developing economies through the Climate Support Facility.
• European Commission: Providing technical assistance grants for CSRD implementation in smaller EU member states.

Action Checklist

1. Map all jurisdictions where your company has reporting obligations, revenue thresholds, or subsidiary presence that triggers disclosure requirements
2. Identify the earliest mandatory deadline across all applicable jurisdictions and use it to set your compliance timeline
3. Assess current data infrastructure against the most demanding standard you face (typically CSRD with full Scope 1-2-3 and double materiality)
4. Engage a sustainability assurance provider at least 12 months before your first mandatory reporting date to secure capacity
5. Implement carbon accounting software that supports multi-framework output (ESRS, ISSB, SEC, California) from a single data set
6. Establish supplier engagement programs for Scope 3 data collection, prioritizing tier-1 suppliers in high-emission categories
7. Build internal governance structures that assign clear ownership of climate data across finance, sustainability, and procurement functions

FAQ

Which regulation should companies prioritize if they operate in multiple jurisdictions? Start with the regulation that has the earliest mandatory deadline and broadest scope. For most multinationals, this is CSRD because it requires Scope 1-2-3 disclosure, double materiality, and assurance. Building CSRD-ready infrastructure typically satisfies 80-90% of other jurisdictional requirements.

How much does compliance with mandatory climate disclosure cost? First-year implementation costs range from $200,000 to $2 million for large enterprises, covering software, data collection, assurance, and internal capacity building. Ongoing annual costs typically decrease 30-50% after the initial setup year.

Will ISSB adoption eliminate the need for jurisdiction-specific compliance? Not entirely. While ISSB provides a global baseline, many jurisdictions layer additional requirements on top. The EU adds double materiality and detailed sector standards. California adds Scope 3 verification timelines that differ from ISSB. Companies still need to track jurisdiction-specific additions.

What happens if a company misses a disclosure deadline? Consequences vary by jurisdiction. CSRD penalties are set by individual EU member states and can include fines, director liability, and audit qualifications. California imposes administrative penalties up to $500,000 annually. In most markets, non-compliance also triggers investor scrutiny and potential procurement exclusion.

How should procurement teams prepare for cascading disclosure obligations? Procurement teams should integrate climate data requirements into supplier qualification processes, include emissions reporting clauses in new contracts, and establish tiered engagement programs that prioritize high-spend and high-emission suppliers for primary data collection.

Sources

1. European Commission. "Corporate Sustainability Reporting Directive: Implementation Timeline and Technical Standards." EC, 2025.
2. International Financial Reporting Standards Foundation. "IFRS S1 and S2: Jurisdictional Adoption Tracker." IFRS Foundation, 2025.
3. California Air Resources Board. "SB 253 Climate Corporate Data Accountability Act: Implementation Guidance." CARB, 2025.
4. Japan Financial Services Agency. "Amendments to the Financial Instruments and Exchange Act: Sustainability Disclosure Requirements." JFSA, 2025.
5. Australian Treasury. "Climate-Related Financial Disclosure: Treasury Laws Amendment." Australian Government, 2024.
6. Securities and Exchange Commission. "The Enhancement and Standardization of Climate-Related Disclosures: Final Rule." SEC, 2024.
7. Hong Kong Stock Exchange. "Enhanced Climate Reporting Framework: Implementation Guide." HKEX, 2025.
8. International Auditing and Assurance Standards Board. "ISSA 5000: General Requirements for Sustainability Assurance Engagements." IAASB, 2025.