ESG Regulations, Laws, and Reporting Requirements - Last Updated: August 4, 2026
In recent years, a growing number of ESG (environmental, social, and governance) laws and regulations have been passed around the world to create better consistency, transparency, and quality among corporate ESG disclosure, sustainable investment, and ESG practices and financial products.
The European Union (EU) has some of the world's most advanced ESG regulations of any economic region. Under the banner of a 'European Green New Deal', Europe is implementing a sweeping set of measures designed to fight climate change, support sustainable innovation, and make Europe the first climate-neutral continent by 2050.
However, beyond just Europe, many other governments and countries have passed (or proposed) new ESG regulations in recent years, including Australia, Brazil, Canada, Chile, China, Colombia, Hong Kong, India, Japan, Singapore, South Korea, the United States, and the United Kingdom. Several of these regimes moved from proposal to live obligation during 2025 and 2026, and at least two (the United States and Brazil) have moved in the opposite direction.
While an exhaustive list and overview of global, country-by-country ESG regulations simply isn't possible due to the number of different laws and a constantly evolving ESG regulatory landscape, this page summarizes many of the top international ESG regulations and policies that matter most for global investors and companies.
Australia: Key ESG Regulations
Australia requires large businesses, financial institutions, and asset owners to publish annual climate-related financial disclosures within their annual financial reporting, covering governance, strategy, risk management, greenhouse gas (GHG) emissions, and climate scenario analysis. This regime is mandatory and already in force
Australia's mandatory climate reporting regime is live. What began as a January 2023 Treasury consultation paper on a climate risk disclosure framework became law in 2024. Entities that already prepare annual financial reports under Chapter 2M of the Corporations Act 2001 must now also prepare a Sustainability Report, in accordance with the Australian Sustainability Reporting Standards (ASRS) issued by the Australian Accounting Standards Board (AASB).
The core climate standard is AASB S2, Australia's implementation of the ISSB's IFRS S2 climate-related disclosures standard. Reporting is phased across three groups by entity size, with each group needing to meet two of three thresholds:
- Group 1 - reporting periods beginning on or after 1 January 2025. Consolidated revenue of A$500 million or more, consolidated gross assets of A$1 billion or more, or 500 or more employees. The first Group 1 sustainability reports have already been prepared and lodged
- Group 2 - reporting periods beginning on or after 1 July 2026. Consolidated revenue of A$200 million or more, consolidated gross assets of A$500 million or more, or 250 or more employees. Group 2 also captures asset owners (including superannuation funds and managed investment schemes) with A$5 billion or more in assets under management
- Group 3 - reporting periods beginning on or after 1 July 2027. Consolidated revenue of A$50 million or more, consolidated gross assets of A$25 million or more, or 100 or more employees. Group 3 entities only need to report under AASB S2 if they have material climate-related risks and opportunities - but an entity concluding it has none must still explain that conclusion
Scope 1 and Scope 2 emissions are required from an entity's first reporting year. Scope 3 emissions become mandatory from the second year, giving each group a one-year runway to build value chain data collection. Reports require a directors' declaration and are subject to phased assurance requirements.
Read more about Australia's ESG and climate regulations, or our detailed guide to AASB S1 and S2 reporting requirements in Australia.
Brazil: Key ESG Regulations
Brazil was among the first countries in the world to adopt the ISSB's IFRS S1 and S2 standards through its securities regulator, the CVM. The originally mandatory regime was reversed in May 2026: sustainability reporting is now voluntary, with a "comply or explain" duty from 2027 for companies that choose not to report
In 2023, Brazil's securities and exchange regulator, the Comissão de Valores Mobiliários (CVM), issued Resolution 193, formally adopting the ISSB's IFRS S1 and IFRS S2 sustainability reporting standards into Brazilian securities law. Under the original rule, sustainability-related financial disclosure was voluntary for fiscal years 2024 and 2025, and would become mandatory for publicly traded companies for fiscal years beginning on or after 1 January 2026.
That mandate no longer exists. On 29 May 2026, the CVM issued Resolution 244, which amends Resolution 193 and revokes the mandatory disclosure requirement. Brazilian issuers now operate under a voluntary framework with three practical consequences:
- Publishing a sustainability report is optional, regardless of company size or listing status
- From 2027, a company that chooses not to report must publicly explain the reasons for that decision - a "comply or explain" obligation rather than a reporting obligation
- Companies that do report must still apply the ISSB standards as adopted in Brazil, so the content requirements are unchanged for voluntary reporters
Brazil is a useful reminder that ESG regulatory timelines can move backwards as well as forwards. Companies that built reporting capability for the 2026 mandate have not wasted the investment - investor, lender, and value chain demand for the same data continues, and voluntary reporters still report against the full ISSB standards - but the specific compliance deadline they were working toward no longer applies.
Canada: Key ESG Regulations
Canada has published national sustainability disclosure standards (CSDS 1 and CSDS 2), but they remain voluntary - the Canadian Securities Administrators (CSA) paused work on a mandatory climate disclosure rule in April 2025. Canadian listed companies remain subject to existing continuous disclosure obligations and certain ESG-related provisions, such as gender diversity disclosure related to board composition
Beginning in 2021, the CSA proposed climate-related disclosure requirements for reporting issuers based on the Task Force on Climate-related Financial Disclosures (TCFD) framework. In parallel, the Canadian Sustainability Standards Board (CSSB) developed Canadian Sustainability Disclosure Standards CSDS 1 and CSDS 2, based on the ISSB's IFRS S1 and S2, effective for annual reporting periods beginning on or after 1 January 2025.
Neither is mandatory. On 23 April 2025, the CSA announced it was pausing its work on a mandatory climate-related disclosure rule (and on a parallel diversity disclosure project), citing rapid changes in the global economic and geopolitical landscape and a focus on the competitiveness of Canadian capital markets. No mandatory start date has been set. CSDS 1 and CSDS 2 remain voluntary unless and until a securities regulator adopts them.
Two things are still true for Canadian reporting issuers, and they matter more than the paused rule:
- Issuers remain subject to Canada's existing continuous disclosure requirements, which already oblige them to disclose material climate-related information that would reasonably be expected to affect the market price or value of their securities. A paused rule does not pause materiality
- Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (Bill S-211) is separate, in force, and imposes its own annual reporting obligation on covered entities
For entities that do choose to report against CSDS 1 and CSDS 2 voluntarily, the standards allow later start dates than IFRS S1 and S2 for the hardest disclosures: non-climate sustainability topics and Scope 3 emissions are subject to extended transition relief. The disclosure content itself follows the familiar four-pillar structure:
- Governance: an issuer’s board’s oversight of and management’s role in assessing and managing climate-related risks and opportunities
- Strategy: disclosure on the short-, medium- and long-term climate-related risks and opportunities the issuer has identified and the impact on its business, strategy and financial planning, where such information is material. As a modification from the TCFD recommendations, the proposed disclosure would not include the requirement to disclose “scenario analysis”, which is an issuer’s description of the resilience of its strategy within different climate-related scenarios, including a 2°C or lower scenario
- Risk management: how an issuer identifies, assesses and manages climate-related risks and how these processes are integrated into its overall risk management
- Metrics and targets: the ESG metrics and targets used by an issuer to assess and manage climate-related risks and opportunities where the information is material, including Scope 1, 2, and 3 greenhouse gas emissions
For more on ESG in Canada, please read our guide to Canadian ESG reporting standards, frameworks, and requirements here, or our overview of Canadian ESG reporting requirements by entity type.
China: Key ESG Regulations
China requires index-constituent and dual-listed companies on the Shanghai, Shenzhen, and Beijing stock exchanges to publish annual sustainability reports, under guidelines issued by the exchanges at the direction of the China Securities Regulatory Commission (CSRC)
In April 2024, the Shanghai, Shenzhen, and Beijing stock exchanges each issued sustainability reporting guidelines for listed companies, developed under the guidance of the China Securities Regulatory Commission (CSRC). The guidelines took effect on 1 May 2024 and constitute China's first mandatory corporate sustainability disclosure requirement.
Mandatory reporting applies to companies continuously included in any of the following indices during the reporting period, plus companies dual-listed in mainland China and abroad:
- SSE 180 Index (Shanghai Stock Exchange)
- STAR 50 Index (Shanghai Stock Exchange STAR Market)
- Shenzhen 100 Index (Shenzhen Stock Exchange)
- ChiNext Index (Shenzhen Stock Exchange)
Roughly 457 companies fall within this mandatory scope, and they were required to publish sustainability reports covering calendar year 2025 by 30 April 2026. That is a small fraction of China's listed universe by company count, but these issuers accounted for around two-thirds of national greenhouse gas emissions, so the effective coverage is far larger than the headline number suggests. All other listed companies on these exchanges are encouraged to report voluntarily under the same guidelines.
The guidelines use a four-pillar disclosure structure - governance, strategy, risk and opportunity management, and metrics and targets - which will be familiar to anyone already working with TCFD or ISSB reporting, though the topic coverage reflects Chinese policy priorities rather than a direct ISSB transposition.
Separately, China's Ministry of Finance finalised Basic Guidelines for national corporate sustainability disclosure standards in December 2024, setting the direction for a unified, economy-wide reporting regime that would extend well beyond listed companies over time.
European Union (EU): Key ESG Regulations
Major EU Sustainability Reporting Laws and Regulations
The EU has introduced over a dozen different ESG regulations in recent years, including the Sustainable Finance Disclosure Regulation (SFDR), Corporate Sustainability Reporting Directive (CSRD), and other key ESG-related regulations. In February 2026, the Omnibus I Directive substantially narrowed who has to comply with the CSRD and CSDDD
Unlike most other countries and economic regions, Europe has enacted and proposed a host of different ESG regulations across nearly all sectors of the EU economy. Before working through the individual regulations, however, one 2026 change now governs how most of them apply.
On 24 February 2026 the Council of the EU adopted the Omnibus I Directive, published in the Official Journal on 26 February 2026 as Directive (EU) 2026/470 and in force from 18 March 2026. It amends the CSRD, the CSDDD, the Accounting Directive, and the Audit Directive with the stated aim of reducing reporting burden. The two changes that matter most:
- CSRD scope - sustainability reporting now applies to large undertakings with more than 1,000 employees and more than €450 million in net turnover. Because both conditions must be met, the great majority of companies previously captured by the CSRD are no longer in scope
- CSDDD scope - due diligence thresholds rise to EU companies with more than 5,000 employees and more than €1.5 billion in net worldwide turnover, up from 1,000 employees and €450 million
If you scoped a CSRD programme before 2026, it is worth re-running the assessment. Many companies that were in scope are now out of it, and some that remain in scope have a different reporting start date than they originally planned for. Note also that being out of CSRD scope does not remove value chain data requests from in-scope customers, investors, and lenders.
Top EU ESG regulations include:
- Sustainable Finance Disclosure Regulation (SFDR) - Regulates investment management sustainability reporting in the EU
- Corporate Sustainability Reporting Directive (CSRD) - Regulates corporate sustainability reporting in the EU, now applying to undertakings above the Omnibus I thresholds. Reporting is done against the European Sustainability Reporting Standards (ESRS), which are themselves being simplified - see our explainer on the difference between the CSRD and the ESRS
- EU Taxonomy for Sustainable Activities - A common classification system for sustainable economic activities, projects, and investments
- German Supply Chain Due Diligence Law (LkSG) and Corporate Sustainability Due Diligence Directive (CSDDD) - Regulates corporate supply chain due diligence and reporting, now applying above the raised Omnibus I thresholds
Other EU Sustainability Laws and Regulations to Track
- EU ecodesign for sustainable products - Updates to the EU's existing Ecodesign Directive to establish a framework to ecodesign requirements for specific products and product groups to significantly improve their circularity, energy performance and overall environmental sustainability
- EU green claims initiative - A set of measures to clarify environmental labels on products and penalize greenwashing
- EU regulation on deforestation-free products - Sets mandatory due diligence rules for companies which place specific commodities on the EU market that are associated with deforestation and forest degradation, including soy, beef, palm oil, wood, cocoa, coffee, and some derived products, like leather, chocolate, and furniture. Its purpose is to ensure that only deforestation-free and legal products (according to the laws of the country of origin) are allowed on the EU market
- Proposal for a revision of EU legislation on packaging and packaging Waste - Another pending EU legal revision to promote reusable packaging options, get rid of unnecessary packaging, limit overpackaging, and provide clear labels to support correct recycling will require all EU packaging to be fully recyclable by 2030
- The EU "Women on Boards" Directive (Directive (EU) 2022/2381) required large, listed EU companies to have at least 40% of their non-executive director positions held by women by 30 June 2026 - a deadline that has now passed. Member States could instead elect a 33% target applied across executive and non-executive positions combined, and are required to have penalties in place for companies that miss it.
All of these EU laws and regulations have important implications for companies and investors, particularly the major four (SFRD, CSRD, EU Taxonomy, and CSDDD).
- Learn more about the EU Corporate Sustainability Reporting Directive (CSRD)
- Learn more about the Sustainable Finance Disclosure Regulation (SFDR)
- Learn more about the EU Taxonomy for Sustainable Activities
- Learn more about EU supply chain due diligence laws
- Read our full overview of EU sustainability reporting requirements
- Learn how CSRD biodiversity reporting relates to TNFD nature disclosure
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Hong Kong: Key ESG Regulations
Hong Kong requires all companies listed on HKEX to disclose Scope 1 and Scope 2 greenhouse gas emissions, under climate requirements built directly on the ISSB's IFRS S2. The largest issuers moved to full mandatory climate reporting, including Scope 3, from financial years beginning in 2026
Hong Kong Exchanges and Clearing (HKEX) has taken a "climate-first" approach to implementing the ISSB standards, introducing new climate disclosure requirements into the Listing Rules that are closely based on IFRS S2. The requirements apply on a tiered basis:
- All listed issuers - Scope 1 and Scope 2 greenhouse gas emissions disclosure is mandatory for financial years commencing on or after 1 January 2025. This covers Main Board issuers and GEM issuers alike
- LargeCap issuers - constituents of the Hang Seng Composite LargeCap Index move to full mandatory climate reporting, including Scope 3 value chain emissions, for financial years commencing on or after 1 January 2026
- Other Main Board issuers - the wider climate requirements beyond Scope 1 and 2 apply on a "comply or explain" basis, giving smaller issuers time to build the underlying data capability
The practical significance of Hong Kong's approach is that it is one of the first markets to make Scope 3 disclosure a hard listing requirement for its largest companies, rather than a comply-or-explain expectation. For multinationals with a Hong Kong listing, the Scope 3 boundary work is typically the long pole - see our guidance on calculating Scope 3 emissions if you are starting from a standing start.
For a fuller breakdown, read our guide to Hong Kong HKEX ESG reporting requirements.
India: Key ESG Regulations
Currently, the top 1,000 listed companies in India are required to publish a Business Responsibility Report (BRR) as a part of their annual corporate reporting. BRR reports detail a company's actions and metrics related to Environmental, Social and Governance (ESG), in a new Business Responsibility and Sustainability Report (BRSR) format specified by the Securities and Exchange Board of India (SEBI). Other listed companies may submit the BRR or BSRS voluntarily
Over the past decade, India has gradually evolved its corporate ESG reporting regulations into last year's introduction of the Business Responsibility and Sustainability Report (BRSR) report. The BSRS is a new Indian ESG report standard that builds on the Business Responsibility Report (BRR) format originally mandated in 2012.
BSRS reports are now mandatory for the top 1,000 listed companies in India by market capitalisation from FY2022–23.
The BSRS report is designed around nine principles outlined by SEBI, developed to align with the United Nations Sustainable Development Goals (SDGs):
- Principle 1: Businesses should conduct and govern themselves with integrity, and in a manner that is ethical, transparent and accountable
- Principle 2: Businesses should provide goods and services in a manner that is sustainable and safe
- Principle 3: Businesses should respect and promote the well-being of all employees, including those in their value chains
- Principle 4: Businesses should respect the interests of and be responsive to all its stakeholders
- Principle 5: Businesses should respect and promote human rights
- Principle 6: Businesses should respect and make efforts to protect and restore the environment
- Principle 7: Businesses, when engaging in influencing public and regulatory policy, should do so in a manner that is responsible and transparent
- Principle 8: Businesses should promote inclusive growth and equitable development
- Principle 9: Businesses should engage with and provide value to their consumers in a responsible manner
BSRS ESG reports are divided into three sections:
- General disclosures: The section contains details of the listed entity; products and services; operations; employees; holding, subsidiary and associate companies (including joint ventures); corporate social responsibility (CSR); and transparency and disclosure compliances
- Management and process disclosures: This section requires information related to a company's policy and management processes; governance; leadership and oversight
- Principle performance disclosures: This section requires companies to report on ESG KPIs in alignment with the nine outlined BSRS principles. KPIs are grouped into two categories: (1) essential indicators (mandatory to report) and (2) leadership indicators (voluntary to report)
Examples of BSRS KPIs include energy usage, GHG emissions, water consumption and withdrawal, employee well-being, worker health and safety, human rights protections, and anti-corruption and bribery controls.
Japan: Key ESG Regulations
Japan has made sustainability disclosure legally mandatory for the largest companies listed on the Tokyo Stock Exchange Prime Market, using the Sustainability Standards Board of Japan (SSBJ) standards. Requirements phase in by market capitalisation from the fiscal year ending March 2027
The Sustainability Standards Board of Japan (SSBJ) published Japan's sustainability disclosure standards in March 2025, incorporating the key elements of the ISSB's IFRS S1 and IFRS S2. In a Cabinet Office Order finalised on 26 February 2026, Japan's Financial Services Agency (FSA) made application of those standards legally mandatory for companies listed on the Tokyo Stock Exchange (TSE) Prime Market, with disclosure made in the annual securities report.
Mandatory application phases in by market capitalisation:
- ¥3 trillion or more - from the fiscal year ending 31 March 2027. This first wave captures roughly 69 companies, effectively Japan's largest corporations
- ¥1 trillion or more - from the fiscal year ending 31 March 2028
- ¥500 billion or more - from the fiscal year ending 31 March 2029
Assurance requirements follow the disclosure requirements on a lag, and the FSA has signalled that mandatory application may extend to all Prime Market companies in later years. Companies outside the Prime Market, and those below the market capitalisation thresholds, may apply the SSBJ standards voluntarily.
For Japanese companies with European operations, it is worth checking SSBJ obligations against CSRD scope after the Omnibus I changes described above - the two regimes overlap substantially in data requirements even where the reporting formats differ.
Singapore: Key ESG Regulations
In Singapore, the Monetary Authority of Singapore (MAS) is implementing a "Green Finance Action Plan" in accordance with Singapore's UN 2030 net zero target. This includes environmental risk management (ERM) guidelines for banks, asset managers and insurers, a "Green Taxonomy" and green loan framework, and disclosure requirements for ESG funds
On 28 January 2021, the Monetary Authority of Singapore (MAS) and MAS-led Green Finance Industry Taskforce (GFIT) issued a proposed taxonomy for Singapore-based financial institutions to identify activities that can be considered sustainable or transitioning towards sustainability, called the “Green Taxonomy”, similar in many respects to the EU's taxonomy.
In 2022, GFIT released a second Green Taxonomy consultation paper which outlines standards for economic activities in three industries: energy, transport, and real estate. Singapore is prioritizing these three sectors due to their high environmental intensity and impact in Singapore. This second consultation paper also outlines Singapore's climate mitigation objectives: (1) climate change adaptation, (2) protection of healthy ecosystems and biodiversity, (3) promotion of resource resilience and circular economy, and (4) pollution prevention and control.
Beyond the Green Taxonomy, Singapore also requires all ESG investment funds to submit annual disclosure on their investment focus; strategies; criteria and metrics used in selecting investments; asset allocation; and the risks associated with their ESG strategies. ESG and "sustainable" funds must also allocate at least two‑thirds of their net assets under management to ESG and sustainable investments, consistent with their stated strategy.
The MAS is also developing "Project Greenprint", a blockchain-based system for standardizing and storing ESG data, using a common ESG disclosure framework. MAS has also issued guidance that it will be introducing mandatory ESG disclosure requirements for financial institutions, based on the IFRS' International Sustainability Standards Board (ISSB) sustainability reporting standards currently under development.
Switzerland: Key ESG Regulations
Starting with business year 2023, Swiss "companies of public interest" are required to complete annual ESG reporting on climate, social, labor and human rights, and corporate governance matters under article 964a et seqq. of the Swiss Code of Obligations (CO)
In 2023, the Swiss Federal Council adopted new legislation on non-financial ESG reporting under the Swiss Code of Obligations (CO). This includes an Ordinance on Climate Disclosures, aligned with the TCFD framework, where eligible Swiss companies must disclose their GHG emissions, quantitative CO2 targets, and develop a climate transition plan comparable with Switzerland's national climate goals.
Swiss ESG reporting requirements apply to entities which meet any of the following criteria:
- Publicly listed on a stock exchange
- Require a license, recognition, authorization or registration from the Swiss Financial Market Supervisory Authority FINMA (such as banks or insurers)
- Have issued bonds outstanding
And (i) have an annual average of at least 500 full-time employees and (ii) exceed at least one of the following two thresholds: balance sheet total of CHF 20 million or revenues of CHF 40 million in two consecutive business years. Companies meeting these requirements are only exempt if they are controlled by another eligible entity, or are required to prepare an equivalent report under a foreign law, such as the EU CSRD.
Swiss climate disclosures must be published in an entity's report on non-financial matters in accordance with Articles 964a–964c of the CO. If a company does not make disclosures on climate issues in accordance with the Swiss Code of Obligations, it must either demonstrate that it complies in other ways with the climate disclosure obligations, or declare it does not "follow any climate concept" and justify its decision.
Beyond mandatory climate disclosures, Swiss companies must also report on significant ESG risks to their business, how their company's principlal business activities related to ESG matters under the double materiality principle, and the KPIs used to measure their ESG progress and performance. Similar to UK regulations, Swiss entities may use a "comply and explain" approach, excluding certain ESG disclosures and instead explaining why the information has been excluded. In addition to the non-financial reporting obligations, all Swiss companies must also comply with supply chain due diligence requirements related to conflict materials and preventing child labor.
Read our detailed guide to the Swiss Federal Act on Sustainable Corporate Governance for the full reporting and due diligence requirements.
Under Swiss regulations, non-financial ESG reports must be approved by the governing body responsible for approving the entity's annual financial report, souch as the company's shareholders' assembly or, in other cases, its board of directors. Reports must be published electronically and remain publicly accessible for at least ten years. Presently, no audit or assurance is required for an entity's non-financial ESG reporting.
The United States: Key US ESG Regulations
The United States is also in the process of transitioning ESG disclosure from voluntary, market-led reporting to a regulatory-driven scheme, principally led by a variety of evolving state laws and standards like California's SB 253 and SB 261 climate disclosure laws.
The United States is unusual among major economies in that its federal climate disclosure requirement has moved backwards while its state-level requirements have moved forwards. Understanding the current position means separating the two.
The SEC adopted its climate-related disclosure rules, The Enhancement and Standardization of Climate-Related Disclosures for Investors, in March 2024. Those rules were stayed shortly afterwards in the face of litigation and never took effect - no company has ever been required to report under them.
On 29 May 2026, the Commission voted to propose rescinding the rules in their entirety. The proposal was published in the Federal Register on 3 June 2026 as Rescission of Climate-Related Disclosure Rules (SEC file number S7-2026-19), with a public comment period closing 3 August 2026. The Commission would need to vote again before any rescission is final, so a final rule is unlikely before late 2026 or early 2027.
What this means practically: there is currently no federal US climate disclosure mandate, and the most likely outcome is that there will not be one in the near term. US companies looking for their binding obligation should look to California, and to non-US regimes that capture them through subsidiaries or value chain relationships. Read our full analysis of the SEC climate disclosure rules and what replaced them.
Beyond the SEC, the United States continues to build an ecosystem of ESG-related laws and regulations - principally at the state level. This includes:
Federal and National
- California SB 253 & SB 261: In 2023, California enacted the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261)—the laws that succeeded an earlier proposal (SB 260) that did not pass. SB 253 applies to large U.S. entities doing business in California (including public and private companies above a $1 billion annual revenue threshold) and requires annual public disclosure of Scope 1, 2, and 3 greenhouse gas (GHG) emissions, publication via a CARB-administered registry, and phased third-party assurance. SB 261 applies above a $500 million revenue threshold and requires biennial reporting on climate-related financial risk, aligned with the Task Force on Climate-related Financial Disclosures (TCFD) or an equivalent framework. Implementation dates and regulatory detail have been revised through follow-on legislation (including SB 219); covered companies should rely on California Air Resources Board (CARB) rules and monitor litigation that may affect enforcement timelines
- The Inflation Reduction Act: While not explicitly an "ESG" regulation, the act is a landmark initiative to invest in domestic climate resilience and energy production, particularly renewable energy. The law, as passed, will raise $738 billion and authorize $391 billion in spending on energy and climate change, the largest investment into addressing climate change in US history
- The Uyghur Forced Labor Prevention Act: This 2022 law prohibits imports into the United States of products, goods, and materials that are produced using forced labor in the Xinjiang region of China
- US Department of Labor Ruling on ESG Investment Factors: This ruling amends and clarifies the Employee Retirement Income Security Act of 1974 (ERISA)'s fiduciary duties related to the selection of plan investments that incorporate ESG goals and strategies. This ruling, which begins to take effect February 1, 2023, recognizes that ESG factors may be relevant to the risk-return analysis of potential US Department of Labor (DOL) investments, which could allow more ESG investment from US retirement funds and plans
- The Federal Supplier Climate Risks and Resilience Rule: A proposed rule to amend the Federal Acquisition Regulation to require federal government contractors who receive over $7.5 million in federal contract obligations in the prior federal fiscal year to disclose their GHG emissions and climate-related financial risks and set science-based emissions reduction targets
- NASDAQ board diversity reporting: In 2021, the SEC approved a NASDAQ provision that requires NASDAQ-listed companies to have, or explain why they do not have, at least two diverse board directors. The rules also require reporting on overall board composition, demographics, and diversity. The rule remains in effect, but is currently the target of litigation seeking to overturn it
At the state level, dozens of states have enacted requirements to enhance diversity on corporate boards, address climate change, and incentivize corporate climate, ESG, and sustainability investment and prioritization.
State
- California SB 253 & SB 261: The Climate Corporate Data Accountability Act (SB 253) and Climate-Related Financial Risk Act (SB 261) require large companies doing business in California to disclose Scope 1, 2, and 3 GHG emissions (SB 253, with assurance) and biennial climate-related financial risk (SB 261, TCFD-aligned), under CARB regulations. For revenue thresholds, dates, and compliance detail, use our California SB 253 & SB 261 guide and our walkthrough of SB 253 reporting requirements. With the federal rule in retreat, California is now the operative US climate disclosure regime for most large companies
- California's Plastic Pollution & Reduction Law (SB 54): In 2022, California Governor Gavin Newsom signed a law into effect that impacts any business that uses or sells single-use plastic. If it achieves its goals, the Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) could help eliminate approximately 23 million tons of single-use plastics throughout the next 10 years. It’s considered the most comprehensive and ambitious plastic reduction law in the United States to date
- New York's Climate Leadership and Community Protection Act (Climate Act or CLCPA): On December 19, 2022, New York State's Climate Action Council (Council) approved a New York State Climate Action Council Scoping Plan to fund and implement the CLCPA. The Plan outlines actions needed for New York to achieve 70% renewable energy by 2030; 100% zero-emission electricity by 2040; a 40% reduction in statewide greenhouse gas emissions from 1990 levels by 2030, an 85% reduction from 1990 levels by 2050; and net-zero emissions by 2050. The plan also identifies a variety of regulatory and legal changes, market mechanisms, and technologies essential to achieving these directives, including a tax on large-scale corporate pollution
However, on the other side of the political divide, certain states like Florida and Texas have adopted new prohibitions on state agencies and pension funds from doing business with investment entities like BlackRock who use ESG factors in their capital allocation decisions.
United Kingdom: Key UK ESG Regulations
The United Kingdom requires specific company-level disclosures from large UK entities within their annual financial reporting, energy use, carbon footprint, and greenhouse gas (GHG) emissions. Moreover, the UK is currently developing a broader and more comprehensive set of climate, ESG, and sustainability regulations for companies, investment entities, and government agencies
Alongside the EU, the UK is currently one of the most dynamic ESG regulatory jurisdictions. The most significant recent development is the arrival of the UK's own ISSB-based reporting standards.
On 25 February 2026, the Department for Business and Trade (DBT) published the final UK Sustainability Reporting Standards: UK SRS S1 (general requirements for disclosure of sustainability-related financial information) and UK SRS S2 (climate-related disclosures). These are the UK-endorsed versions of the ISSB's IFRS S1 and IFRS S2, following a consultation on exposure drafts that ran from June to September 2025.
The standards are currently voluntary and available for use by any entity that chooses to apply them. Separately, on 30 January 2026 the Financial Conduct Authority (FCA) consulted on amending the UK Listing Rules to require certain listed companies to report against UK SRS for accounting periods beginning on or after 1 January 2027. Roughly 515 UK-listed companies would be captured by the climate requirements under UK SRS S2. That consultation closed on 20 March 2026, with a final policy statement expected in autumn 2026.
Read our detailed guide to the UK Sustainability Reporting Standards for scope, timing, and how UK SRS interacts with existing SECR and TCFD obligations.
Alongside UK SRS, major UK ESG regulations include:
- Streamlined Energy and Carbon Reporting (SECR) - Requires large UK companies to disclose their energy use, carbon footprint, and greenhouse gas (GHG) emissions in their annual financial reporting
- Financial Conduct Authority TCFD Reporting (FCA CRFD) - The UK Financial Conduct Authority (FCA) requires companies with UK-listed shares or deposit receipts, as well as FCA-regulated asset managers and asset owners to complete mandatory annual Task Force for Climate-Related Financial Disclosure (TCFD)-aligned climate disclosure reporting
- Department for Business, Energy, and Industrial Strategy Climate-Related Financial Disclosure (BEIS CFRD) - The UK Department for Business, Energy, and Industrial Strategy (BEIS) requires UK-registered companies (public or private) with over 500+ employees or £500M+ in annual revenue to also complete annual sustainability and climate-related disclosure reporting, based around TCFD
- Sustainability Disclosure Requirements (SDR) - A package of measures aimed at reducing greenwashing and unifying UK sustainability reporting. This includes sustainable investment labels, disclosure requirements, and restrictions on the use of sustainability-related terms in product naming and marketing
- Energy Savings Opportunity Scheme (ESOS) - A mandatory energy assessment scheme for organisations in the UK that meet the qualification criteria which must be carried out every 4 years. These assessments are audits of energy used by their buildings, industrial processes, and transport to identify cost-effective energy saving measures
Learn more about current UK ESG and sustainability laws and regulations, or read our guide to SECR carbon reporting compliance.
Other Jurisdictions to Track
Beyond the regimes covered in detail above, a number of other markets have adopted or are phasing in ISSB-based sustainability reporting requirements. If your organisation has subsidiaries, listings, or major suppliers in any of these jurisdictions, they are worth monitoring:
- South Korea - the Korea Sustainability Standards Board published the Korean Sustainability Disclosure Standards (KSDS 1 and KSDS 2), based on IFRS S1 and S2, in February 2026. Under the Financial Services Commission roadmap, mandatory reporting begins with companies holding more than KRW 10 trillion in assets in 2028, expanding to companies above KRW 5 trillion a year later
- Malaysia - the National Sustainability Reporting Framework (NSRF) phases ISSB-based reporting in by group: Main Market issuers with market capitalisation of RM2 billion and above from 2025, other Main Market issuers from 2026, and ACE Market issuers plus large non-listed companies from 2027
- New Zealand - one of the first countries in the world to mandate climate-related disclosures. In October 2025 the government significantly narrowed the regime, raising the listed-company threshold from NZ$60 million to NZ$1 billion in market capitalisation and removing managed investment scheme managers, reducing the number of climate reporting entities from around 164 to roughly 76
- Türkiye - the Turkish Sustainability Reporting Standards (TSRS) were published in December 2023 and became mandatory for companies and financial institutions above the specified thresholds from 1 January 2024. Those thresholds were raised significantly in January 2026, narrowing the number of entities in scope
- Taiwan - the Financial Supervisory Commission published a roadmap in August 2023 for Taiwan-listed entities to align with IFRS S1 and S2, with adoption from 2026
The common thread across all of these is the ISSB's IFRS S1 and S2. Even where local implementation differs on thresholds, timing, and assurance, the underlying data model is converging - which means a well-built ESG data collection process generally transfers across jurisdictions with less rework than the number of distinct regimes would suggest.
The Growing Role and Importance of ESG Regulations
Until recently, in many countries and jurisdictions, ESG and sustainability reporting were voluntary, market-led responses. The rise in global ESG regulations has led to increased compliance exposure, obligations, and risks for international companies. That direction of travel is no longer uniform, however: 2025 and 2026 saw the EU narrow CSRD scope through Omnibus I, the SEC propose rescinding its climate rule outright, Brazil revoke its mandatory ISSB regime, Canada pause its climate disclosure rule, and New Zealand cut its reporting population by more than half - while Australia, Hong Kong, Japan, and China moved in the opposite direction and brought mandatory regimes into force.
The practical implication for multinational organisations is that "are we in scope?" is now a question that has to be re-asked periodically, per jurisdiction, rather than answered once. It is also why building reporting capability around the underlying data - rather than around a single regulation's output format - has proven to be the more durable investment.
However, despite the challenges many of these new regulations are creating for unprepared and underinvested companies, ESG laws and regulations serve many important functions:
- Ensuring good corporate and ESG governance: Governance laws and regulations help make sure companies and organizations operate transparently and ethically, with a focus on long-term value creation. They also help to protect investors and other stakeholders from fraud and other forms of misconduct
- Environmental protection: Environmental laws and regulations help to protect the natural resources and ecosystems that support life on earth and mitigate all the social and economic harms of climate change. Reducing pollution, conserving biodiversity, and addressing climate risks are all long-term net positives for economic prosperity and shareholder value creation
- Upholding and protecting human rights: ESG social laws and regulations help ensure that all members of society have access to basic human needs and rights, such as housing, healthcare, education, and fair wages. They also help promote diversity, equity, and inclusion in the workplace, which have been proven to be ROI-positive for stronger ESG performers
- Creating level competitive playing fields and promoting positive industry collaboration: ESG laws and regulations help make sure all companies and organizations are held to the same standards, instead of environmental and social harms merely being shifted to less-regulated markets. Moreover, as law-makers are recognizing the importance of sector-specific sustainability collaboration, we expect to see anti-trust regulations reduced in ESG-related areas where cross-company cooperation can unlock new value
- Promoting sustainable product innovation and business transformation: Data and studies consistently show that strong ESG performers have a lower cost of capital, lower market volatility, and better category sales growth in many consumer segments compared to poor ESG performers. ESG implementation and integration present an opportunity for organizations to become more operationally efficient, improve resource usage (and re-use), and ultimately develop a stronger, more resilient, and more diverse company culture and value chain
Overall, ESG regulations play an important role in sustainable economic development, protecting the environment and human rights, and ensuring all companies operate in a responsible and ethical manner with sound risk controls. All in, it's hard to argue those developments don't convey significant economic and social benefit.
A Few Helpful ESG Regulatory Reporting Recommendations and Observations
Your Next Steps With ESG Regulatory Compliance
As you can tell from the length of this brief alone, there are a lot of major new ESG laws taking effect in recent and future years. In fairness, all these regulations can feel very complex and daunting. However, from a positive perspective:
- Most of these laws are being phased in over several years
- Most governments recognize they are collectively at the forefront of a global economic sustainable transition, and regulators are looking to help companies successfully adopt and implement these changes
- There's plenty of time to implement the necessary measures, standards, process changes, and reporting capabilities to keep pace - particularly for organizations who are proactive and already investing in these areas (or starting soon)
- There are lots of existing market resources to help organizations and investors track, manage, and report around these changes more efficiently and effectively, including Brightest's software and services
For organizations in the early stages of their ESG regulatory compliance journey, we have a few general recommendations, additional reading, and suggested next steps:
Materiality assessment - The principle of Materiality is embedded in many of these new ESG regulations, particularly the concept of double materiality. Materiality essentially asks and attempts to answer a fundamental question: what are the most important (re: material) climate, ESG, and sustainability risks and considerations for a business or investment? If your organization hasn't already done so, a materiality assessment can help determine what your top ESG opportunities, risks, and priorities should be in relation to regulatory and investor ESG reporting. In turn, this can help clarify where to focus, what to prioritize, and what aspects of pending or forthcoming ESG regulations matter most to you.
Understand these ESG laws and regulations in depth - A full, in-depth breakdown of each ESG regulation is outside the scope of this piece, but it is critical that, if your organization meets specific compliance, disclosure, and/or due diligence criteria, you work with your leadership, directors, legal counsel, auditors, and other stakeholders to understand your organization's specific timeline and obligations under each law.
ESG data systems and process - While this might go without saying, in order to track ESG compliance and communicate your organization's mandatory climate and ESG disclosures, you need to be able to prepare them with high degrees of accuracy and transparency. Your materiality process can help guide you toward the main ESG themes you may need to focus on for disclosure. Where does that data and information exist today in your organization, and how will you access, collect, and aggregate it? Many organizations start their ESG reporting with relatively simple spreadsheets, surveys, and documents, but things can get complex fast - particularly for larger companies. If you're an organization with a medium-to-large or complex environmental footprint, you likely need dedicated sustainability reporting and data management software, like the kind we design here at Brightest to help organizations stay ESG compliant. Ongoing report archiving, version control, and governance are also important to think about, since you'll be reporting under one or several of these regulatory standards every year.
Further reading - Our free guides to starting an ESG reporting program, ESG data collection, and ESG reporting strategy provide additional, detailed guidance and insights on how to aproach ESG compliance and report performance. Or, if you're ready to up-level your ESG management and data maturity, please contact us for a free assement or demo of Brightest's intelligent, award-winning ESG software platform.
Disclaimer: the information provided in this overview is a best-effort attempt to summarize the key terms and provisions of ESG regulations in major economic and financial markets. It is not intended to be exhaustive or fully comprehensive. Despite our best efforts, it may contain errors or ommissions. Please consult your legal counsel and local regulatory institutions for the latest guidance and ESG regulatory requirements. If you have any suggestions on how to improve this piece for accuracy, or see a law or provision that is incorrect or out of date, please contact us here.