While public debate in Europe sometimes reveals a desire for a "regulatory pause" or a sense of retreat in the face of environmental constraints, a very different reality is emerging at the international level.
The European Union has initiated a movement that its main trading partners are now beginning to appropriate with unprecedented vigor.
From China to California, through the emerging powers of Southeast Asia (Malaysia, Thailand, Philippines) and the dynamic economies of Latin America or Africa (Brazil, Nigeria), climate reporting is no longer an option, but a market requirement. These jurisdictions, pillars of the value chains of French companies, are deploying increasingly strict transparency frameworks, often aligned with the global standards of the ISSB.
Here is an overview of the main carbon reporting regulations deployed around the world or about to be.
1. The giants
- 🇨🇳 China
This is the turning point of the year so far. Beijing has just published its first standard (aligned with ISSB/IFRS S2).
Here are the four fundamental pillars that companies must now document:
- Governance: How the governing bodies monitor climate risks and opportunities.
- Strategy: The real 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: The quantitative measures (greenhouse gas emissions) and targets set by the company.
However, China has also decided to move closer to the European approach to sustainability reporting with 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 has announced that this sustainability reporting will be on a voluntary basis for companies in the first instance but will gradually become mandatory, from large listed companies to SMEs.
Furthermore, sector-specific application guides (electricity, steel, coal...) will also be published progressively.
- 🇺🇸 California
The SB 253 comes into force. Large American companies operating in California must publish their emissions.
The SB 253 law (Climate Corporate Data Accountability Act), adopted by California in October 2023, goes much further than the SEC's (the US securities regulator) projects by imposing total transparency on greenhouse gas emissions.
Here are the key points to know at the beginning of the year 2026.
Who is affected?
The law does not apply only to Californian companies. It targets any entity that:
- Does business in California
- Generates a global annual turnover of more than 1 billion dollars.
What needs to be declared
Companies must publish their greenhouse gas emissions annually, following the GHG Protocol.
The implementation schedule (Updated 2026)
- 2026: First reporting deadline for Scopes 1 and 2 (based on 2025 fiscal year data).
- 2027: Start of the obligation to report on Scope 3 (based on 2026 fiscal year data).
- 2026-2030: Increase in verification. As of 2026, "limited assurance" by a third party is required for Scopes 1 and 2, moving to "reasonable assurance" (more stringent) in 2030.
Penalties
Non-compliance with the law can result in fines of up to $500,000 per year. However, the regulator (CARB) has specified that in 2026, it will show leniency towards companies demonstrating a "good faith" effort to comply, recognizing the technical difficulty of collecting this data.
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2. Asia-Pacific
This is the area where regulation is progressing the fastest, aligned with international standards (ISSB):
- New Zealand 🇳🇿 since 2023
The climate standards of Aotearoa New Zealand (named NZ CS 1, 2 and 3) are issued by the External Reporting Board (XRB). They are based on the four pillars of the TCFD (Governance, Strategy, Risk Management, Metrics).
- Malaysia 🇲🇾
Malaysia took a major step at the end of 2024 with the launch of the National Sustainability Reporting Framework (NSRF). This framework aims to harmonize the country's ESG reporting with the international standards of the ISSB.
Reporting began last year for the largest listed companies, and deployment continues this year and in 2027 for other listed companies and large unlisted companies.
- Australia 🇦🇺
Australian reporting is based on the Australian Sustainability Reporting Standards (ASRS), developed by the AASB. These standards are closely aligned with the global standards of the ISSB:
- AASB S1: General requirements (currently voluntary, except for climate-related aspects).
- AASB S2: Climate-specific provisions (mandatory). It requires detailing governance, strategy, risk management, as well as climate metrics and targets.
Deployment has been underway since 2025.
- Singapore 🇸🇬
In Singapore, the ACRA (Accounting and Corporate Regulatory Authority) and the stock exchange regulator (SGX RegCo) oversee the national climate reporting framework.
Its deployment began last year with the obligation for the largest listed companies to publish their greenhouse gas emissions from scopes 1, 2, and 3.
For other companies, the publication of scope 3 emissions remains voluntary for now.
- Taiwan 🇹🇼
Under the impetus of the FSC (Financial Supervisory Commission), Taiwan has adopted a rigorous roadmap to align its listed companies with the international standards of the ISSB.
The first reports are expected in 2027 on the data of the 2026 fiscal year and concern the largest listed companies.
- Thailand 🇹🇭
In Thailand, the SEC (Securities and Exchange Commission) finalized in late November 2025 its roadmap for mandatory climate reporting, integrating the international standards of the ISSB.
Initially, companies are only required to apply the general standard (IFRS S1) to the extent that it concerns climate information. The climate-specific standard (IFRS S2) must, however, be applied in full. Companies have two additional years to publish their scope 3 emissions.
- Philippines 🇵🇭
The transition to mandatory climate reporting is led by the Securities and Exchange Commission (SEC) of the Philippines, which has officially adopted the Philippine Financial Reporting Standards (PFRS) S1 and S2. These standards are the exact local transcriptions of the global standards of the ISSB.
- Hong Kong 🇭🇰
The authorities have published the Hong Kong sustainability disclosure standards.
Since January 1, 2025, all companies listed on the Main Board must follow the new climate reporting requirements based on the ISSB.
2026 is the year of the first publication for major issuers.
3. Emerging markets
🇧🇷 Brazil
Brazil was one of the first in the world to officially announce the adoption of ISSB standards.
The strict obligation for listed companies will begin for financial years starting from January 1, 2026 (first reports published in 2027).
🇲🇽 Mexico
Mexico published in January 2025 the national sustainability standards (NIS) 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 directives for its members, focusing on the extractive industry and tourism, two sectors vulnerable to climate change.
🇳🇬 Nigeria, 🇰🇪 Kenya & 🇬🇭 Ghana (Horizon 2027-2028)
- 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. The extension to listed companies is planned to align with global standards by 2027.
- Ghana: the country is preparing its regulatory framework to enhance the transparency of its mining (gold) and agriculture (cocoa) sectors, essential for its exports to the EU.
4. Europe
United Kingdom 🇬🇧
The United Kingdom already has the SECR (Streamlined Energy and Carbon Reporting) as a regulatory framework for energy and carbon reporting, and has since April 1, 2019. It aims to increase transparency on energy costs and greenhouse gas (GHG) emissions of companies to inform investors and stakeholders.
Large companies (listed and non-listed) are concerned and must publish their greenhouse gas emissions from Scopes 1 and 2 or their energy-related emissions in the UK.
Furthermore, the United Kingdom must publish at the beginning of this year the final version of its new sustainability reporting project, which will also be based on ISSB standards.
The European Union 🇪🇺
The CSRD directive is in its concrete phase for the largest companies.
To learn more:
- What is the CSRD?
- Where do we stand on the simplification of the CSRD and CS3D?
- The ESRS and their simplification
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