2. Sustainability disclosure

Globally, investors have increasingly expanded their focus to consider the financial risks and opportunities posed by broader economic, environmental and societal challenges, and the resilience of companies to these risks and how they manage them. As a result, policy makers in several jurisdictions have introduced regulatory frameworks governing how companies should manage and disclose risks related to sustainability matters.

The promotion of corporate governance policies that support the sustainability and resilience of corporations was an overarching goal in the 2023 revision of the G20/OECD Principles, the leading international standard for corporate governance. Among many other issues, the revised Principles include a chapter on “Sustainability and resilience”, which provides policy recommendations to support companies in managing the risks and opportunities of the climate transition and other sustainability challenges. This includes a recommendation for corporate governance frameworks to include reliable, consistent and comparable disclosure of material sustainability-related information.

There are many different aspects to a sustainability disclosure framework, including the stringency of disclosure requirements (e.g. binding rules, recommendations, comply or explain approaches), coverage of the framework, the use of metrics when a company sets sustainability-related goals, the materiality concept used, the target audience of the disclosure and whether there is any flexibility in its applicability.

Over recent years sustainability concerns have become increasingly incorporated into financial markets and the broader economy. This can be seen in the sharp increase in assets under management of investment funds labelled as ESG- or climate-focused, and in the prevalence of sustainability issues such as climate change and human capital management, along with a range of traditional governance issues, in institutional investors’ reported engagement preferences (OECD, 2022[1]). This has led to an increasing demand for corporate disclosure related to sustainability issues broadly, and a consequent need for regulatory frameworks of such disclosure where they were not already in place.

Table 2.1 below provides a summary of the regulatory framework for sustainability disclosure in 18 Asian jurisdictions. All of these jurisdictions have some form of national framework in place, although the nature and scope differ. The table divides them into three broad categories: binding requirements, i.e. codified in laws, regulations or listing rules; comply or explain structures in guidelines, codes or principles; and voluntary recommendations (also in guidelines, codes or principles).

The most common approach, implemented or under consideration in 13 jurisdictions, is a form of binding requirement for corporate sustainability disclosure. This is the case in Bangladesh, China, Hong Kong (China), India, Indonesia, Japan, Korea, Malaysia, Singapore, Sri Lanka, Chinese Taipei, Thailand and Viet Nam. However, as detailed below, there are major differences in how these are applied, including the scope of companies covered. Section 2.3 and Table 2.4 provide more details on the flexibility and proportionality measures within each framework.

As shown in Table 2.1, four jurisdictions, Lao PDR, Mongolia, Pakistan and the Philippines, apply a comply or explain approach, all referring to their respective corporate governance codes or relevant corporate governance regulation. Cambodia has recommendations on sustainability disclosure that only refers to the financial sector and in China listed companies and state-owned enterprises are encouraged to disclose sustainability-related information (CSRC, 2021[2]).

In Bangladesh, the corporate governance code published by the Securities and Exchange Commission (2018[3]) mandates the publication of a Directors’ Report to shareholders which should include, among other things, threats to “sustainability and [a] negative impact on [the] environment”. Compliance with the code is mandatory for all listed companies (Bangladesh SEC, 2020[4]) (Dhaka Stock Exchange[5]). China has a combination of a binding requirement and a recommendation for corporate sustainability disclosure depending on the type of company. Listed companies identified as key pollutant-discharging units are required to disclose relevant environmental information (CSRC, 2021[2]). In addition, companies listed on the STAR market of the Shanghai Stock Exchange and companies included in the Shenzhen 100 Index, are required to disclose sustainability-related information (Shanghai Stock Exchange, 2020[6]) (Shenzhen Stock Exchange, 2020[7]). In Hong Kong (China), the listing requirements of the HKEX stock exchange include the publication of an annual ESG report (HKEX, 2020[8]). In India, sustainability-related reporting is mandatory for the 1 000 largest companies by market capitalisation from the financial year 2022-23, using a format called the Business Responsibility and Sustainability Report (BRSR) (SEBI, 2021[9]). The Securities and Exchange Board of India (SEBI) has also introduced disclosure (with limited assurance) of sustainability information contained in a framework called the BRSR Core (sub-set of the BRSR), on a comply or explain basis for the value chain of the top 250 listed companies by market capitalisation. This will apply from the financial year 2024-25 for disclosure and 2025-26 for assurance (SEBI, 2023[10]). In Indonesia, the Financial Services Authority (OJK) introduced a rule in 2017 that requires financial institutions to release annual and five-year sustainable finance action plans defining a time line and a strategy for the integration of environmental, social and governance criteria aspects, and the development of products and/services into their business plans. These include the submission of a Sustainable Finance Action Plan and/or a Sustainability Report to the regulator (OJK, 2017[11]). In Japan, following recent legislation, listed companies are required by the Financial Services Authority to disclose sustainability-related information, including issues related to the environment, human rights, anti-corruption, as well as governance and risk management procedures for dealing with these risks (Morgan Lewis, 2022[12]). Moreover, companies listed on the Prime Market must analyse and disclose risks and opportunities related to climate change. The Japanese Corporate Governance Code (following a comply or explain approach) also instructs companies to “appropriately disclose their initiatives on sustainability when disclosing their management strategies” (JPX, 2021[13]).

In Korea, an amendment of the Environmental Technology and Industry Support Act in 2021 expanded mandatory disclosure of environmental information – including plans for environmental management such as reducing the discharge of environmental pollutants – from a small set of designated “green companies” to all listed companies with total assets exceeding KRW 2 trillion (c. USD1.5 billion) ( (Environmental Technology and Industry Support Act (Article 16-8)[14]) and (Article 22-10 (1) of the Enforcement Decree of the Environmental Technology and Industry Support Act, 2021[15])). In addition, the Korean Financial Services Commission in 2018 announced that large firms (with total assets exceeding KRW 2 trillion, c. USD 1.5 billion) listed in KOSPI would be obliged to disclose material governance-related information since 2019. The Korea Exchange amended the KOSPI Market Disclosure Regulation to support this regulatory change. In 2021, the Korean Financial Services Commission also announced plans to gradually expand mandatory sustainability disclosure to all companies listed on its benchmark KOSPI market by 2030 (see also Table 2.4) (FSC Korea, 2021[16]). In Malaysia in September 2022, the stock exchange (Bursa Malaysia) enhanced its sustainability reporting framework for listed issuers on the Main Market and ACE Market, which will be implemented on a phased approach, beginning with annual reports for financial years ending 31 December 2023 onwards. This includes the required disclosure of a common baseline of sustainability themes and indicators, climate-related disclosures which are aligned with the TCFD Recommendations,1 as well as a statement on whether the Sustainability Statement has been subjected to internal review by the listed issuer’s internal auditors or independent assurance (Bursa Malaysia, 2022[17]). In 2016, the Singapore Exchange (SGX) introduced a mandatory sustainability reporting for listed issuers to include certain prescribed elements2 on a ‘comply or explain’ basis. Climate reporting based on the recommendations of the TCFD was subsequently introduced on a ‘comply or explain’ basis for all listed issuers for financial years starting from 2022, with mandatory climate reporting for listed issuers in the (i) financial, (ii) agriculture, food and forest products, and (iii) energy industries from financial year 2023; and those in the (iv) materials and buildings, and (v) transportation industries from financial year 2024 (see Table 2.4 for details) (SGX, 2022[18]).

In Sri Lanka, the Colombo Stock Exchange requires companies to disclose their policies on ESG matters and details related to the implementation of these policies (CSE, 2023[19]). In Chinese Taipei, the stock exchange requires certain listed companies to publish a sustainability report (TWSE, 2022[20]). This applies to listed companies from the food, chemical and financial/insurance industries, companies which derive 50% or more of their operating revenues from food and beverage, or companies with a paid capital of at least NTD 2 billion (c. USD 64 million). In Thailand, the Securities and Exchange Commission amended its regulation on annual disclosure for listed companies in 2020, consolidating two previous disclosures, the annual registration statement and the annual report, into a single document called the Form 56-1 One Report (SEC Thailand, 2017[21]). The amendment has been applicable since 2021 for early adopters and became fully effective starting in 2022. This report format includes disclosure on ESG performance, greenhouse gas emissions (GHGs) and human rights, among other things (Thailand SEC, 2021[22]). In Viet Nam, the Ministry of Finance issued a disclosure regulation in 2020 requiring listed companies to report their impacts on the environment and society (Circular 96/2020/TT-BTC, 2020[23]). The requirement has been effective since 2021 and follows a collaboration between the State Securities Commission of Viet Nam (SSC) and the International Finance Corporation in 2016 to prepare a guidance document for companies related to such disclosure (see Table 2.3 for further information).

The frameworks in most jurisdictions summarised in Table 2.1 apply to a broad range of sustainability measures. Still, certain jurisdictions, including Cambodia and Malaysia give priority to climate-related issues within the broader framework. Climate change is one of the sustainability issues investors tend to focus on in their engagement; one survey of 42 institutional investors with a total of USD 29 trillion in assets under management found that 85% of respondents “strongly agreed” they had sought engagement with companies on climate change, which was by far the most common issue (Morrow Sodali, 2021[24]). From a company perspective, as shown in Section 1.2, climate change is one of the most pressing financially material issues both globally and in Asia.

When a company sets sustainability-related goals, certain jurisdictions also require or recommend the disclosure of tangible metrics to allow for an evaluation of the extent to which the company is fulfilling or progressing towards those goals. In Hong Kong (China), Indonesia, Japan, Malaysia, Singapore, Chinese Taipei and Thailand, such disclosure is mandatory for at least a subset of companies.

Globally, international standards and frameworks are being developed to enable companies to provide comprehensive, comparable and reliable sustainability information. In the meantime, several jurisdictions have also been introducing local disclosure frameworks, sometimes incorporating aspects of international standards and frameworks. While local disclosure frameworks are better positioned to address jurisdiction-specific factors, international standards and frameworks play a critical role in facilitating reliable, comparable and comprehensive sustainability disclosure. The G20/OECD Principles of Corporate Governance (revised in 2023) emphasise the important role of internationally recognised standards in the design of local disclosure frameworks: “[s]ustainability-related disclosure frameworks should be consistent with high quality, understandable, enforceable and internationally recognised standards that facilitate the comparability of sustainability-related disclosure across companies and markets” (OECD, 2023[25]).

Several Asian jurisdictions have created local frameworks or provided guidance with respect to certain elements from internationally accepted standards (see Table 2.3 for details). Table 2.2 presents some of the most commonly used international standards in Asia (see also Section 2.40). These standards differ mainly in terms of coverage, level of detail, target audience and how they define materiality. In terms of coverage of issues, the Task Force on Climate-Related Financial Disclosures (TCFD) recommendations and Carbon Disclosure Project (CDP) Questionnaires cover only a limited number of issues such as climate change, while the Sustainability Accounting Standards Board (SASB) Standards, Global Reporting Initiative (GRI) Standards and Integrated Reporting (IR) Framework incorporate a considerable range of sustainability issues. In terms of target audience, a large majority of existing sustainability-related reporting frameworks cite investors as their main audience with the notable exception of the GRI Standards, which target shareholders and multiple stakeholders, and the CDP Questionnaires, which target investors and supply chain customers as the audience.

With respect to the level of detail of these standards and frameworks (both in terms of guidance and requirements), they can be split into those that are principles-based and those that prescribe detailed information. Principles-based standards provide flexibility for companies by providing only guidelines – rather than detailed rules to disclose each and every piece of information (e.g. companies exercise professional judgement to decide what to disclose under each principle) and these types of standards can usefully be complemented with guidance to provide comparability across companies and over time. On the other hand, other standards are more prescriptive and provide greater detail on how companies should account for and report sustainability information, which can be helpful for emerging and complex issues. Among the standards and frameworks summarised in Table 2.2, the TCFD recommendations3 and the IR Framework are principles-based, while the SASB Standards, the GRI Standards and the CDP Questionnaires provide greater detail on how companies should disclose sustainability information. The concept of materiality adopted in the various standards/frameworks depends on the targeted primary users of the information. If investors, who are assumed to make investment and voting decisions based on a company’s expected future cash flows, are the primary users, the standards/frameworks adopt a financial materiality approach. As shown in Table 2.2, the TCFD recommendations, the SASB Standards and the IR Framework adopt a financial materiality approach, and are primarily targeted at investors. The GRI Standards adopt a double materiality approach that incorporates what is financially material, but also includes within its scope information relevant to the understanding of a company’s impact on the environment and on society.

An important policy question for jurisdictions developing their sustainability disclosure frameworks is whether to mandate a specific reporting framework or allow companies the freedom to choose. The adoption of a single disclosure standard, either international or local, can facilitate the comparability of sustainability information across companies. However, it is important to ensure that these standards address the needs of specific sectors and consider country-specific factors. The revised G20/OECD Principles note that ensuring consistency and interoperability between regional or national frameworks and internationally recognised standards can still allow for flexibility of complementary local requirements, including on matters where specific geographical characteristics or jurisdictional requirements may influence materiality.

Among the 18 Asian jurisdictions in Table 2.3, China, Hong Kong (China), India, Indonesia, Japan, Korea, Malaysia, the Philippines, Singapore, Chinese Taipei, Thailand and Viet Nam have already developed or are developing local disclosure frameworks/guidance for companies to disclose sustainability information. Most of these jurisdictions include certain aspects of, or suggest the use of, international standards and frameworks. Japan and Korea have created their own sustainability standards boards to further expand and manage relevant sustainability-related disclosure frameworks. In Bangladesh, Cambodia, Lao PDR, Mongolia, Pakistan and Sri Lanka, the regulation regarding disclosure of sustainability-related information is still at an early stage.

In China, the China Securities Regulatory Commission (CSRC) provides guidance on the disclosure of sustainability-related information within broader guidelines on annual reports for companies offering securities to the public. The guidelines include articles recommending companies disclose relevant sustainability-related information on a voluntary basis with no reference to international standards (CSRC, 2021[27]). In Hong Kong (China), the listing rules set out the general local disclosure framework, and for more comprehensive disclosure for relevant industries or sectors, companies are recommended to refer to existing international sustainability-related reporting standards and frameworks (HKEX, 2020[8]). In India the Securities Exchange Board of India has designed the new Business Responsibility and Sustainability Report (BRSR) to be interoperable with other internationally accepted reporting frameworks such as the Global Reporting Initiative, Sustainability Accounting Standards Board and the Task Force on Climate-Related Financial Disclosures (SEBI, 2021[28]; SEBI, 2021[29]). The provisions categorise the information as “Essential” and “Leadership”. All entities that are required to publish a Business Responsibility and Sustainability Report (BRSR) must disclose essential indicators, while leadership indicators can be disclosed on a voluntarily basis. Companies are allowed to report based on internationally accepted reporting frameworks, however, in order to avoid double reporting they can provide cross-reference to these reporting frameworks in their BRSRs. Additionally, the Institute of Chartered Accountants of India has established a Sustainability Reporting Standards Board to review the emerging trends globally and evaluate need for further standard setting in India (ICAI, 2023[30]).

In Indonesia, OJK provides guidance on the disclosure of sustainability-related information. The guidance refers to several international standards which are adapted to conditions that can be implemented in Indonesia (OJK, 2017[31]). In Japan, the 2023 amendments of the Cabinet Office Order on the Disclosure of Narrative Information serve as the sustainability disclosure framework (FSA, 2023[32]). This amendment was made in accordance with a report by the Working Group on Corporate Disclosure published in June 2022. The report sets out three viewpoints for the Financial Services Agency (FSA) which is responsible for developing sustainability disclosure framework: to position sustainability-related information as a key disclosure item and make continuous improvement for the sustainability-related disclosure; to pay attention to good practices in private corporations and investors’ needs when developing details of sustainability-related disclosure; and to lead a global discussion and fully ensure comparability (Working Group on Corporate Disclosure in Japan, 2022[33]). Against this background, the Principles Regarding the Disclosure of Narrative Information included in the amendment provide details on the requirements when disclosing sustainability-related information (FSA, 2023[34]). Further detailed sustainability disclosure standards, based on the International Sustainability Standards Board (ISSB) Standards, will be developed and implemented by the Sustainability Standards Board of Japan no later than 31 March 2025 (IFRS, 2023[35]). The Financial Services Commission of Korea has announced that it will phase in sustainability disclosure for listed companies. Companies are encouraged to voluntarily disclose sustainability-related information by 2025. Starting in 2025, large companies over the specific threshold will be required to mandatorily disclose sustainability information. The binding requirement will be expanded to all KOSPI listed firms in 2030. Starting in 2025, companies are encouraged to voluntarily disclose sustainability-related information, which will gradually become a binding requirement by 2030. Additionally, the Korean Sustainability Standards Board will develop domestic sustainability standards based on ISSB standards (KASB, 2021[36]).

In Malaysia, Bursa Malaysia’s listing requirements serve as the local sustainability disclosure framework for listed issuers on the Main Market and ACE Market (focused on smaller growth companies) of the stock exchange. The disclosure framework includes climate-related disclosures which are aligned with the TCFD recommendations (Bursa Malaysia, 2022[37]). In 2019, the SEC Philippines issued local guidelines on sustainability reporting that builds upon four international standards and frameworks, the GRI Standards, the IR Framework, the SASB Standards and the TCFD Recommendations (The SEC Philippines, 2019[38]). In Singapore, sustainability reporting requirements for listed issuers are set out in the SGX-ST Listing Rules, with a Sustainability Reporting Guide available in Practice Note 7.6 of the SGX-ST Listing Manual. The SGX Group has also proposed a list of 27 core ESG metrics as guidance for issuers in providing an aligned set of ESG data. Though not mandated, the metrics serve as a starting point for what listed issuers can disclose in their sustainability reports (SGX, 2016[39]).

In Chinese Taipei, the reporting rules of the Taiwan Stock Exchange include references to global international standards including the GRI Standards (TWSE, 2022[20]). In Thailand, the Form 56-1 One Report, adopted in 2020, expects companies to use a report framework proportionate to its size and complexity, and to meet not only local requirements but also international standards (the GRI Standards are referenced) (SEC Thailand, 2020[40]; SEC Thailand, 2017[21]). In addition, SEC Thailand has also become an official TCFD supporter since December 2020 (SEC Thailand, 2021[41]). As a supporter, the SEC Thailand have organised capacity building events to enhance the understanding of listed companies on how to adopt international standards. In Viet Nam, the circular on disclosure of information on securities markets also includes guidance on disclosure of certain sustainability information (Circular 96/2020/TT-BTC, 2020[23]). In 2016, the SSC of Viet Nam in coordination with the International Finance Corporation (IFC) and building on the GRI standards published the Environmental & Social (E&S) Disclosure Guide for listed companies (SSC Viet Nam and IFC, 2016[42]). In Pakistan, the Securities and Exchange Commission of Pakistan (SECP) issued in 2013 the Corporate Social Responsibility Voluntary Guidelines encouraging companies to consolidate and report their policies and activities in a separate Corporate Social Responsibility Report (Securities and Exchange Commission of Pakistan, 2013[43]).5

Within a typical disclosure standard/framework, company executives need to decide what information is material to disclose. When doing so, they need to consider the possibility of materiality changing over time, according to the local context, company-specific circumstances and jurisdictional requirements. Traditionally, accounting standards for financial reports have considered investors to be the primary users of corporate disclosure, which typically means that only information relevant to their investment or voting decisions would need to be reported. However, sustainability-related information disclosure frameworks could also be structured to expand the primary user audience to multiple stakeholders. A piece of information may need to be disclosed, for instance, if it is relevant for employees or customers, even if the information is not reasonably expected to affect an investor’s decision to trade a company’s securities or influence its voting in a shareholder meeting.

The revised G20/OECD Principles acknowledge that corporate sustainability-related disclosures may benefit stakeholders (OECD, 2023[25]). Regarding materiality of the information to be disclosed, they state that environmental and social matters could be classified as material if this information can reasonably be expected to affect a company’s asset value and its ability to generate revenues and long-term growth. A company’s impact on society and the environment that might affect its value as well as an information that might decrease the competitive strength of a company could also be considered material.

Among the 18 Asian jurisdictions in Table 2.3, in China, Hong Kong (China), India, Indonesia, Malaysia, the Philippines, Sri Lanka, Chinese Taipei and Thailand sustainability disclosure targets multiple stakeholders, while in Bangladesh, Japan and Singapore the primary users are investors.

In three above-mentioned Asian jurisdictions with disclosure targeting multiple stakeholders, the materiality assessment of sustainability information takes a broader perspective, including stakeholders in addition to investors. Particularly, in Hong Kong (China), the listing rules of the stock exchange define sustainability-related information as material if it is determined by the board to be sufficiently important to investors and other stakeholders (HKEX, 2020[8]). In India, Principle 4 of the National Guidelines on Responsible Business Conduct, which is the basis for the Circular on BRSR, states that “businesses should respect the interests of and be responsive to all its stakeholders” (SEBI, 2021[29]; SEBI, 2021[28]). The listing requirements on the sustainability reporting framework of Bursa Malaysia define material information as that which “substantively influence[s] the assessments and decisions of stakeholders” (Bursa Malaysia, 2022[44]).

Two jurisdictions specifically include stakeholders as relevant users of the sustainability information in their corporate governance frameworks. The code of best practice on corporate governance in Sri Lanka recommends companies to include “sufficient information to enable investors and other stakeholders to assess how ESG risks and opportunities are recognised, managed, measured and reported” (ICAS, 2017[45]). The Philippines corporate governance code includes other stakeholders in addition to shareholders as the target audience to whom “the impact of a wide range of sustainability issues” should be disclosed (SEC Philippines, 2016[46]).

In guidance related to the disclosure of sustainability information for securities issuers, the CSRC in China refers to sustainability information to be disclosed as “information that has a significant impact on investors’ value judgments and investment decisions”. At the same time, companies are encouraged to include relevant information in their sustainability disclosure, among other things, the protection of the rights and interests of employees, customers and consumers, and the protection of the environment and sustainable development (CSRC, 2021[2]).

In Bangladesh, disclosure of sustainability-related information is still an early stage, however, the corporate governance code recommends that directors report relevant sustainability matters to shareholders (Bangladesh SEC, 2018[3]). In Singapore, the Practice Note 7.6 (Sustainability Reporting Guide) in the SGX-ST Listing Manual sets out that listed issuers, when identifying the “material ESG factors” to be disclosed, are to consider their relevance or impact to the business, strategy, financial planning, business model and key stakeholders (SGX, 2016[39]).

The assurance of sustainability disclosure by an independent, competent and qualified third party – similar to external auditing of financial reports – may enhance investors’ confidence in disclosure and allow for greater comparability of sustainability reports across companies. However, high quality assurance for all disclosed sustainability-related information might not be possible or could be very costly. With these considerations in mind, the revised G20/OECD Principles, acknowledge the importance of assurance of sustainability disclosure and recommend phasing in of requirements for annual assurance attestations. However, in cases where high quality assurance is too costly or not possible, the G20/OECD Principles recommend the consideration of mandatory assessment of the most relevant sustainability-related metrics or disclosures, such as greenhouse gas emissions. Additionally, in the long-term, converging the level of assurance between financial statements and sustainability-related disclosures is noted as necessary (OECD, 2023[25]).

Currently, independent assurance is encouraged in several Asian jurisdictions: Hong Kong (China), Indonesia, Malaysia, Mongolia, Singapore, Viet Nam and Thailand. In India, it is mandatory and in Chinese Taipei, it is mandatory for specific industries while it is encouraged for all issuers (Table 2.3). In July 2023, in order to enhance the reliability of sustainability disclosures, SEBI in India introduced the BRSR Core containing a limited set of critical/core Key Performance Indicators (KPIs), for which listed entities shall obtain reasonable assurance. In the initial stage, this will apply to the top 150 listed entities by market capitalisation, from the financial year 2023-24. The requirement will gradually be extended to the top 1 000 listed entities by the financial year 2026-27 (SEBI, 2023[10]).

The sustainability reporting framework of Bursa Malaysia does not require the review of sustainability disclosure by an independent, competent and qualified assurance service provider. However, listed issuers are required to include a statement on whether the information has been subject to internal review by the internal auditor or independent assurance performed in accordance with recognised assurance standards (Bursa Malaysia, 2022[17]). Similarly, the Financial Services Authority in Indonesia does not require the sustainability information to be verified. However, if the information is verified, companies are required to include the written verification from an independent third party in their sustainability report (OJK, 2017[31]).

The listing rules of the stock exchange in Hong Kong (China) provide guidance on sustainability reporting and encourage companies to seek independent assurance. If they do, the rules require companies to include the level, scope and the processes adopted for the assurance in the relevant reports (HKEX, 2020[8]). In Mongolia, the sustainability information reporting guidance for listed companies encourages independent assurance of disclosed sustainability information (FRC Mongolia, IFC, WB and UN, 2022[47]). In Chinese Taipei, the Financial Supervisory Commission’s action plan on sustainable development for companies listed on the Taiwan Stock Exchange (TWSE) and the Taipei Stock Exchange (TPEx) encourages third-party assurance (FSC Chinese Taipei, 2023[48]). In Singapore, listed issuers are encouraged to consider independent external assurance on important aspects of its sustainability report in its initial years, expanding coverage in subsequent years. External assurance should be performed in accordance with recognised assurance standards, for example, the International Standard on Assurance Engagements (ISAE) 3000, the Singapore Standards on Assurance Engagement (SSAE) 3000, the AA 1000 Assurance Standards or the International Organization for Standardization (ISO). The issuer should disclose in the sustainability report the scope of assurance, the identity of the external assurer, the standards used and key findings (SGX, 2016[39]). Similarly, in Viet Nam, a guide on environmental and social disclosure published by the SSC in collaboration with the IFC stresses the importance of independent assurance (SSC Viet Nam and IFC, 2016[42]). In Thailand, only GHGs emission are required to be verified by a reviewer registered with the Thailand Greenhouse Gas Management Organization (a public organisation) or by a reviewer using widely accepted international standards.6

Sound corporate governance regulation promotes the efficient allocation of capital to the real economy, as well as the effective use of capital by individual companies. To fulfil these aims, the regulatory framework should take into account the diverse and specific needs of entrepreneurs, investors and stakeholders who are impacted by the actions of companies. This underscores why the G20/OECD Principles emphasise the importance of developing a regulatory framework that is flexible enough to meet the unique needs of corporations operating under widely disparate circumstances (OECD, 2023[25]).

Regarding the disclosure of sustainability information, companies and regulators might need time to develop adequate processes and good practices. In addition, sustainability disclosure carries certain costs for corporations, which remains relatively constant regardless of the firm’s size. Thus, without appropriate flexibility and proportionality measures, the cost and efforts associated with reporting sustainability-related information may not be balanced by the potential benefits. In this respect, the G20/OECD Principles acknowledge that “sustainability disclosure frameworks need to be flexible in relation to the existing capacities of companies and relevant institutions.”

Table 2.4 below presents an overview of the flexibility and proportionality approaches with respect to sustainability disclosure across 18 Asian jurisdictions. Seven of these jurisdictions have introduced flexibility components for smaller companies in their relevant frameworks, namely, China, India, Indonesia, Korea, Malaysia, Chinese Taipei and Thailand.

The approaches can broadly be split into three. The first approach is to exclude smaller companies from mandated sustainability disclosure, and only subject larger companies to sustainability disclosure. This is the case in China and India. In China, while sustainability disclosure is recommended to most listed companies, larger listed companies (such as those included in the Shenzhen 100 Index) are required to disclose sustainability information within their Social Responsibility Reports (Shenzhen Stock Exchange, 2020[7]). In India, the sustainability disclosure requirement applies to the top 1 000 listed companies by market capitalisation (SEBI, 2021[9]). Importantly, as described in Section 2.2, in July 2023, the SEBI Board introduced additional requirement for the assurance of sustainability information. The assurance requirement will initially be applied to the top 150 listed companies by market capitalisation for a limited set of key performance indicators (KPIs) (SEBI, 2023[10]).

The second approach is to design separate disclosure standards for listed companies of different sizes. For instance, in Malaysia, the climate-related disclosure requirements for listed issuers on the ACE Market (focused on smaller growth companies) are different from that of the Main Market. While companies on the Main Market are required to disclose TCFD-aligned information, companies on the ACE Market are only required to disclose a plan to transition towards a low-carbon economy (Bursa Malaysia, 2022[49]; Bursa Malaysia, 2022[50]).

The third approach is to have different time schedules for companies of different sizes. Indonesia and Korea apply this approach. In Korea, the mandate for sustainability reporting disclosure will extend to listed companies with total assets of KRW 2 trillion (c. USD 1.5 billion) or more from 2025, and it will apply universally to all listed companies from 2030 onwards (FSC Korea, 2021[16]). In Indonesia, for instance, financial services institutions are categorised based on their core capital with different implementation deadlines for sustainability disclosure, with the application date of the requirements ranging between 2020-2025 for each category (OJK, 2017[11]).

There are also jurisdictions that used a combined flexible and proportional approach. For example, in Chinese Taipei, listed companies in certain industries and with paid-in capital over TWD 10 billion (c. USD 322 million) are required to file a sustainability report since 2015. Later in 2021, the revised reporting rules require companies with paid-in capital over TWD 5 billion (c. USD 161 million) to disclose relevant ESG information, along with companies in specific industries. In addition, companies with paid in capital over TWD 2 billion (c. USD 64 million) should start disclosing from 2023, while companies with paid-in capital below TWD 2 billion are required to disclose from 2025 (TWSE, 2021[51]).

Another important aspect that policy makers should consider in designing sustainability disclosure frameworks is how quickly market participants can adjust to the sustainability disclosure requirements. Normally, a phase-in period is adopted when establishing sustainability frameworks to allow companies adequate time to adjust to changes. Sustainability disclosure entails technical adjustments and capacity building so a phase-in period can help companies as well as regulators to develop adequate resources to adjust to the new requirements. In this respect, the revised G20/OECD Principles acknowledge that it may be appropriate to prioritise the disclosure requirements of some of the most relevant sustainability matters, while phasing in other requirements, such as independent external assurance, or establishing some recommendations in “comply or explain” corporate governance codes (OECD, 2023[25]). Eight of the 11 jurisdictions with binding requirements have adopted phase-in periods for disclosure requirements: Hong Kong (China), India, Indonesia, Korea, Malaysia, Singapore and Chinese Taipei. In addition, the Philippines, which requires listed companies to disclose sustainability information on a comply or explain basis, has also adopted a three-year phase-in period for this framework (SEC Philippines, 2019[52]).

Globally, 7 924 listed companies disclosed sustainability information in the form of a sustainability report or an integrated report that includes sustainability issues in 2021, representing 19% of all listed companies worldwide (Figure 2.1, Panel A). When measured by market capitalisation the share is as high as 84% (representing USD 103 trillion of equity in 2021), reflecting the fact that sustainability reporting is widespread among larger companies (Panel B).

Similar dynamics can be seen in Asia, although sustainability reporting is generally less prevalent in the region compared to global figures. Thirteen per cent of companies listed in Asia disclose sustainability information, equivalent to 74% of total market capitalisation (USD 27 trillion). However, these aggregate figures mask significant diversity within the region. For example, in Chinese Taipei, sustainability reports are published by companies representing 91% of total domestic market capitalisation, whereas in Sri Lanka the figure is only 14%. The average share in the region is 63%, which, again, is lower than the aggregate Asian share (74%) since larger companies, and therefore larger markets, publish these reports to greater extent than smaller ones. The share of companies that disclose sustainability information by market capitalisation is over 70% in nine jurisdictions: Hong Kong (China), India, Japan, Malaysia, the Philippines, Singapore, Chinese Taipei and Thailand.

Figure 2.2 shows the prevalence of sustainability disclosure across industries. Around the globe, companies that made up at least 75% of the total market capitalisation across industries disclosed sustainability information. The highest share is found among utilities and real estate companies, where companies representing 90% and 88% of market capitalisation in these industries respectively have reported sustainability information. Basic materials follow, with their share amounting to 86% of total market capitalisation. In Asia, the share of market capitalisation is the largest among companies from the financials and utilities industries, at 95% and 89%, respectively. The share of companies that disclose sustainability information by market capitalisation is over 85% in three other industries: energy, real estate and consumer cyclicals.

As discussed in Section 2.3, flexibility and proportionality measures are often applied to sustainability disclosure frameworks. A closer look at the sustainability disclosure at the company level reveals that there are pronounced differences between sustainability disclosure in large versus small companies, as shown in Figure 2.3. Large (small) companies are defined as those with market capitalisation above (below) the median level for each region/jurisdiction. Globally, almost four in ten large companies disclose sustainability-related information, while this number is only less than one in ten for smaller companies. A similar trend is also observed in Asia. Indeed, across all Asian countries, the share of sustainability disclosure for larger companies is significantly higher than for smaller companies. For instance, in Chinese Taipei, while 61% of large companies report sustainability information, only 13% of small companies report this information.

Companies use many different international frameworks and standards to disclose information on their sustainability-related risks and opportunities. On top of that, as shown in Section 2.2, a growing number of jurisdictions provide guidance on sustainability disclosure and are introducing their own standards and frameworks. Figure 2.4 provides information on companies’ use of selected frameworks and standards. Globally, the most used standard is the CDP questionnaires with 2 890 companies publishing sustainability information in line with this standard, representing 55% of total market capitalisation. The GRI Standards are applied by 3 246 companies, accounting for 45% of market capitalisation. The TCFD’s recommendations are used by 2 638 companies that represent 44% of market capitalisation and the SASB Standards are followed by 1572 companies (38% of market capitalisation). Other international frameworks and standards, including local ones, are used by 2 527 companies, representing 11% of global market capitalisation.

In Asia, the numbers are slightly different. The GRI Standards are applied by the largest number of companies in Asia (1 338 companies, representing 42% of the market capitalisation), followed by the CDP’s questionnaires (837 companies, representing 31% of market the capitalisation), TCFD’s Recommendations (1 038 companies, representing 29% of the market capitalisation) and the SASB Standards (1 572 companies, representing 38% of the market capitalisation).

There are four jurisdictions where the GRI Standards is not the most commonly used framework. In Japan and India, the CDP questionnaires is the most commonly used standard, and in Pakistan and Viet Nam, companies mostly report using other standards.

While the number of companies reporting sustainability information is relatively high, the assurance of disclosed sustainability information by an independent third party is considerably less frequent. Globally, the sustainability information disclosed by 2 683 companies, representing only 6% of all the listed companies has been reviewed by a competent and qualified assurance service provider (Figure 2.5 Panel A). These companies represent 51% of the market capitalisation of all listed companies (Figure 2.5 Panel B). This is significantly lower than the share of the market capitalisation of companies disclosing sustainability information, which is 84% as shown in Figure 2.1 above.

In Asia, the share of companies by number and market capitalisation with sustainability information assured by an independent third party is 4% and 37%, respectively, which is lower than the global figures. Similar to the trend in disclosure of sustainability information, there are also significant differences across jurisdictions. The share of companies that have independent assurance for their sustainability information by market capitalisation is over the global share (51%) in three jurisdictions: Japan (57%), Korea (66%) and Chinese Taipei (84%), while the share is significantly lower in Pakistan, Sri Lanka and Viet Nam with 2%, 11% and 6%, respectively.


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← 1. Listed issuers on the ACE Market are not required to include climate-related disclosures. However, they are required to disclose a basic plan to transition towards a low-carbon economy.

← 2. Material environmental, social and governance factors; policies, practices and performance; targets; sustainability reporting framework; and board statement.

← 3. The TCFD recommendations also include a number of documents providing detailed guidance on how to better comply with the recommendations, such as the report “Guidance on Scenario Analysis for Non-Financial Companies”

← 4. As of June 2023, the Sector standards for Oil and Gas, Coal, and Agriculture, Aquaculture and Fishing have been completed.

← 5. In relation to other sustainability standards, the Securities and Exchange Commission of Pakistan has also issued the Green Bonds Guidelines to contribute positively to protect the environment, combat climate change, promote and facilitate issuance of green bonds. The SECP has also issued Gender Bond Guidelines to promote gender equality, women empowerment, uplift the low-income segment of women and facilitate issuers of debt securities to diversify their source of financing. The SECP also issued Stewardship Guidelines for Institutional Investors recommending to integrate in their engagement policy sustainability considerations including environmental, social and governance factors.

← 6. To accommodate Thai firms, SEC grants an annual fee exemption to listed companies equal to the GHGs emission verifying fees for the period of 2021-2023 and it is being considered to further these initiative for another three years.

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