While public debate in Europe sometimes suggests a desire for a "regulatory pause" or a sense of retreat from environmental constraints, a very different reality is emerging on the international stage.
Far from acting alone, the European Union has ignited a movement that its primary trading partners are now adopting with unprecedented vigor.
From China to California, through the emerging powers of Southeast Asia (Malaysia, Thailand, Philippines) and the dynamic economies of Latin America and Africa (Brazil, Nigeria), climate reporting is no longer an option but a market requirement.
These jurisdictions—pillars of the value chains for French and European companies—are deploying increasingly strict transparency frameworks, often aligned with global ISSB (International Sustainability Standards Board) standards.
Here is an overview of the primary carbon reporting regulations deployed or being deployed worldwide.
1. The Giants
🇨🇳 China
This is the turning point of early 2026. Beijing has just published its first standard, aligned with the ISSB's IFRS S2.
It incorporates the four fundamental pillars that companies must now document:
- Governance: How governing bodies monitor climate-related risks and opportunities.
- Strategy: The actual and potential impact of climate change on the company's business model and financial planning.
- Risk Management: The processes used to identify and assess climate-related risks.
- Metrics and Targets: Quantitative measures (greenhouse gas emissions) and the targets set by the company.
Furthermore, China has decided to move toward the European sustainability reporting approach by adopting double materiality:
- How climate affects their financial value (financial materiality).
- How their activities impact the environment and society (impact materiality).
The Chinese Ministry of Finance announced that this sustainability reporting will initially be voluntary for companies but will become mandatory progressively, starting with large listed companies and eventually extending to SMEs.
Additionally, sector-specific application guidelines (power, steel, coal, etc.) will be released gradually.
🇺🇸 California
SB 253 is entering into force. Large American companies operating in California must now disclose their emissions.
The SB 253 (Climate Corporate Data Accountability Act), adopted by California in October 2023, goes much further than the U.S. SEC's (Securities and Exchange Commission) projects by imposing total transparency on greenhouse gas emissions.
Key points as of early 2026:
- Who is covered? The law applies to any entity (not just California-based firms) that:
- Does business in California.
- Generates total annual global revenues exceeding $1 billion.
- It is estimated that over 5,000 companies are affected, including many French and European multinationals with a commercial presence in the state.
- Disclosure Requirements: Companies must annually publish their greenhouse gas emissions following the GHG Protocol.
- Implementation Timeline:
- 2026: First reporting deadline for Scopes 1 and 2 (based on 2025 fiscal year data).
- 2027: Mandatory reporting begins for Scope 3 (based on 2026 fiscal year data).
- 2026-2030: Phasing in of assurance requirements.
- Penalties: Non-compliance can result in fines of up to $500,000 per year. However, the regulator (CARB) noted that in 2026, it will show leniency toward companies demonstrating a "good faith" effort to comply, acknowledging the technical difficulty of data collection.
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2. Asia-Pacific
This is the zone where regulation is progressing fastest, anchored to international standards (ISSB).
🇳🇿 New Zealand (Since 2023)
The Aotearoa New Zealand climate standards (known as NZ CS 1, 2, and 3) are issued by the External Reporting Board (XRB).
They are based on the four classic TCFD (Task Force on Climate-related Financial Disclosures) pillars: Governance, Strategy, Risk Management, and Metrics/Targets.
🇲🇾 Malaysia
Malaysia reached a milestone in late 2024 with the launch of the National Sustainability Reporting Framework (NSRF).
This framework aims to harmonize the country's ESG reporting with global ISSB standards.
Reporting began last year for the largest listed companies and continues this year and in 2027 for other listed and large non-listed companies.
🇦🇺 Australia
Australian reporting is based on the Australian Sustainability Reporting Standards (ASRS), developed by the AASB.
These are closely aligned with ISSB standards:
- AASB S1: General requirements (currently voluntary, except for climate-related aspects).
- AASB S2: Climate-specific disclosures (mandatory). It requires detailing governance, strategy, risk management, and climate metrics/targets. Deployment has been underway since 2025.
🇸🇬 Singapore
In Singapore, the ACRA (Accounting and Corporate Regulatory Authority) and the exchange regulator (SGX RegCo) oversee the national climate reporting framework.
Deployment began last year with the requirement for the largest listed companies to publish Scope 1, 2, and 3 emissions. For other companies, Scope 3 disclosure remains voluntary for now.
🇹🇼 Taiwan
Driven by the FSC (Financial Supervisory Commission), Taiwan adopted a rigorous roadmap to align its listed companies with ISSB standards.
The first reports are expected in 2027 (based on 2026 data) for the largest listed entities.
🇹🇭 Thailand
The SEC (Securities and Exchange Commission) of Thailand finalized its mandatory climate reporting roadmap in late November 2025.
Initially, companies are only required to apply the general standard (IFRS S1) as it pertains to climate information.
The climate-specific standard (IFRS S2) must be applied in full. Companies have an additional two years to publish Scope 3 emissions.
🇵🇭 Philippines
The transition to mandatory climate reporting is led by the Philippine SEC, which officially adopted the Philippine Financial Reporting Standards (PFRS) S1 and S2.
These are exact local transcriptions of the global ISSB standards.
🇭🇰 Hong Kong
Authorities have published the Hong Kong Sustainability Disclosure Standards.
Since January 1, 2025, all companies listed on the Main Board must follow the new ISSB-based climate reporting requirements. 2026 marks the first publication year for major issuers.
3. Emerging Markets
🇧🇷 Brazil
Strict mandatory reporting for listed companies begins for fiscal years starting January 1, 2026 (first reports published in 2027).
🇲🇽 Mexico
Mexico published its National Sustainability Standards (NIS) in January 2025, aligned with the ISSB.
🇷🇼 Rwanda & 🇹🇿 Tanzania
- Rwanda: Through the National Bank of Rwanda (BNR), the country has imposed climate reporting directives on the financial sector.
- Tanzania: The Dar es Salaam Stock Exchange (DSE) has already published ESG guidelines for its members, focusing on the extractive industry and tourism—two sectors highly vulnerable to climate change.
🇳🇬 Nigeria, 🇰🇪 Kenya & 🇬🇭 Ghana (2027-2028 Horizon)
- Nigeria: The country is currently working on a phased implementation plan that will first include the banking and oil sectors.
- Kenya: The Central Bank of Kenya (CBK) already imposes climate reports on banks. Extension to listed companies is planned for 2027 to align with global standards.
- Ghana: The country is preparing a regulatory framework to increase transparency in its mining (gold) and agriculture (cocoa) sectors, which are essential for exports to the EU.
4. Europe
🇬🇧 United Kingdom
The UK has utilized the SECR (Streamlined Energy and Carbon Reporting) framework since April 1, 2019.
It aims to increase transparency on energy costs and greenhouse gas emissions to inform investors and stakeholders. It covers large companies (listed and unquoted) which must disclose Scopes 1 and 2 emissions or energy-related emissions in the UK.
Furthermore, the UK is expected to publish the final version of its new sustainability reporting project based on ISSB standards in early 2026.
🇪🇺 European Union
The CSRD (Corporate Sustainability Reporting Directive) is now in its concrete implementation phase for the largest companies.
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