Sustainability disclosures are becoming mandatory across APAC, starting with listed companies. What are the timelines, reporting obligations, and key considerations ahead of the first reporting season?
Key takeaways:
- From 2026, Hong Kong, Singapore, and Australia will require listed companies to disclose greenhouse gas emissions.
- Elsewhere, Japan, Thailand, and the Philippines are finalising their frameworks and deadlines expected in 2027.
- Companies listed in APAC should define reporting boundaries, develop a long-term roadmap, and strengthen internal reporting frameworks and awareness.
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Momentum for climate disclosures continues to build in the Asia-Pacific (APAC) region, even as global regulatory landscapes grow more fragmented. In the US, the Securities and Exchange Commission recently dropped its defence of climate disclosure rules, while the European Union has delayed certain sustainability requirements under its Omnibus package.
In the APAC region, New Zealand has joined India and Vietnam at the forefront of climate reporting, having launched its mandatory regimes in 2024. Meanwhile, other key markets, such as Japan, the Philippines, and Indonesia, are putting the finishing touches to their regulatory frameworks. Although some jurisdictions, such as Singapore and South Korea, have delayed their deadlines, the regional trend continues to move toward mandatory reporting.
This shift will first impact listed companies, with requirements cascading down to smaller businesses over time. As the window to prepare narrows, companies should stay ahead to navigate the emerging landscape.
Major economies phase in from 2026
China
China has taken a major step toward sustainability disclosures. In April 2024, the Beijing, Shanghai, and Shenzhen stock exchanges issued basic standards requiring select listed companies, including those on the SSE 180 Index, STAR 50 Index, Shenzhen 100 Index, ChiNext and dual-listed businesses, to publish corporate sustainability reports by 30 April 2026, covering the 2025 financial year. The reports will need to include information on climate change, pollution, waste management, and social contributions.
Hong Kong
Hong Kong is rolling out climate disclosure requirements in phases. All listed companies on Hong Kong Stock Exchange must report scope 1 and 2 greenhouse gas (GHG) emissions for financial years commencing on or after 1 January 2025. They will also need to address broader climate disclosures on a “comply or explain” basis, while it will become mandatory for “Large Cap” issuers (companies with the highest market value) on the Hang Seng Hang Seng Composite LargeCap Index.
Singapore
Singapore mandates scope 1 and 2 emissions reporting for all listed companies from the 2025 financial year. Strait Times Index (STI) constituents must adopt International Sustainability Standards Board (ISSB)-aligned disclosures and begin scope 3 reporting from the 2026 financial year. In August 2025, Singapore Exchange Regulation deferred scope 3 reporting for non-STI companies and postponed external assurance requirements for scope 1 and 2 emissions to 2029.
Australia
Australia’s climate reporting began with the Treasury Laws Amendment Act 2024, which received Royal Assent in September 2024. Entities meeting two of the following criteria – more than AU$500 million (US$322 million) revenue, more than AU$1 billion (US$644 million) gross assets, or more than 500 employees – must begin reporting from the financial year 2025. Reports must include a climate statement, director’s declaration, disclosures on material climate-related financial risks, scope 1, 2, and 3 emissions, and governance, strategy, and risk management.
Malaysia
Under the National Sustainability Reporting Framework (NSRF), issued in September 2024, Main Market-listed issuers with market capitalisation above M$2 billion (US$472 million) as of 31 December 2024 must begin reporting from the 2025 financial year. Scope 3 emissions reporting will start from the 2027 financial year. The NSRF aligns with International Financial Reporting Standards and expands metrics to include biodiversity impacts and social responsibility.
Taiwan
Taiwan launched its sustainability reporting regime, requiring all listed companies, including those with paid-in capital under NT$2 billion (US$64 million), to submit their financial year 2024’s sustainability reports by August 2025. In May 2025, the Financial Supervisory Commission removed previous exemptions based on industry or size. New rules require disclosures on carbon reduction targets tied to net asset value and salary data for full-time non-managerial staff.
Deadlines beyond 2026
Japan
Japan has set a phased roadmap for mandatory sustainability disclosure and third-party assurance. Starting with the fiscal year ending March 2027, companies with a market capitalisation of over ¥3 trillion (US$19.85 billion) must begin sustainability reporting. Those between ¥1 trillion (US$6.61 billion) and ¥3 trillion (US$19.85 billion) follow in March 2028, and companies between ¥500 billion (US$3.3 billion) and ¥1 trillion (US$6.61 billion) by March 2029. Required disclosures include governance, strategy, risk management, and GHG emission reduction targets and other sustainability-related indicators.
Philippines
Under timelines proposed by the Securities and Exchange Commission, publicly listed companies with a market capitalisation above 50 billion pesos (US$860 million) as of 31 December 2025 are to begin reporting in 2027. Companies between 3 billion pesos (US$51.67 million) and 50 billion pesos (US$860 million) follow in 2027, and those below 3 billion pesos (US$51.67 million), alongside non-listed entities, by 2028.
South Korea
South Korea has postponed its original 2025 mandate for KOSPI-listed companies with assets over 2 trillion won (US$1.4 billion) to post-2026, with possible further delays. The phased rollout will extend to all KOSPI-listed firms by 2030. Key obligations include ensuring board-level approval of climate disclosures, quantifying all relevant emissions, and publishing a transition plan for carbon-reduction targets.
Thailand
Thailand recently sought feedback on draft guidelines for sustainability reporting. The Securities and Exchange Commission has proposed that listed companies in the SET50 index begin reporting in 2027 for the 2026 financial year . The ISSB standards will eventually apply to all listed entities, including real estate investment trusts, infrastructure trusts, property funds, and infrastructure funds, from fiscal year 2030.
What should businesses consider ahead of the first reporting season?
Define reporting boundaries
Companies should assess whether they are preparing their disclosures at the entity level or group level, especially when operating across multiple jurisdictions. Some regulators may allow consolidated reporting or exemptions for subsidiaries. For example, a Hong Kong-listed parent may aggregate climate disclosures for its overseas subsidiaries if they share similar characteristics and such aggregation does not obscure material information.
Develop a long-term roadmap
With climate reporting becoming a compliance obligation across APAC, businesses should build a multi-year roadmap to identify gaps, set priorities, and align internal processes. This includes preparing for future phases such as scope 3 emissions, assurance requirements, and sector-specific metrics.
Find out more about global ESG reporting requirements on Lexology PRO.
Strengthen internal capacity and awareness
Legal and compliance teams should collaborate with sustainability, finance, and operations to ensure consistent and accurate reporting. This includes educating teams on environmental and liability implications, identifying suitable language and topics for disclosures, and developing additional disclosures to accompany the climate statement to enhance transparency and reduce greenwashing risks.
Read more on Lexology PRO’s key lessons from top fines on greenwashing of H1 2025.