Introduction

Environmental, Social and Governance (ESG) reporting is rapidly becoming an important part of corporate reporting across the world.

However, there is no single global ESG reporting law that applies identically to every company.

Instead, countries are developing their own sustainability reporting frameworks through securities regulators, company law, stock exchanges, financial regulators and national sustainability standards.

At the international level, the International Sustainability Standards Board (ISSB) has established IFRS S1 and IFRS S2 as a global baseline for sustainability-related financial disclosures. Jurisdictions can adopt these standards directly, modify them, or develop local requirements designed to achieve similar outcomes.

As of 2026, countries including Australia, Brazil, Malaysia, Japan, Singapore and others have developed or are developing approaches based on the ISSB framework, while the European Union continues to operate its broader CSRD/ESRS system.

For multinational companies, exporters, investors, CFOs, Chartered Accountants and Cost and Management Accountants, understanding these differences is becoming essential.

1. Is ESG Reporting Mandatory Worldwide?

No.

ESG reporting is mandatory for certain entities in some jurisdictions, while other countries have voluntary or partially mandatory frameworks.

The most important factors are:

• Country of incorporation
• Listing status
• Market capitalisation
• Revenue
• Number of employees
• Industry
• Financial-sector status
• Assets under management
• Operations in foreign jurisdictions
• Supply-chain relationships

Therefore, a company should never assume that ESG reporting requirements are identical across countries.

2. What Is the ISSB?

The International Sustainability Standards Board developed:

• IFRS S1 – General Requirements for Disclosure of Sustainability-related Financial Information
• IFRS S2 – Climate-related Disclosures

The standards are designed to provide investors with information about sustainability-related risks and opportunities that could reasonably be expected to affect a company’s cash flows, access to finance or cost of capital.

IFRS S1 and S2 are effective internationally from 1 January 2024, but individual jurisdictions decide whether and when they become mandatory.

3. Why Is There No Single Global ESG Reporting System?

Countries have different:

• Legal systems
• Capital markets
• Environmental policies
• Investor requirements
• Corporate reporting traditions
• Economic structures
• Regulatory priorities

Consequently, the ISSB provides a global baseline, while governments and regulators can introduce additional requirements.

The IFRS Foundation specifically recognises that jurisdictions may phase in requirements, scale them according to company size and make jurisdiction-specific modifications.

4. ESG Reporting in India

India has developed a distinctive ESG reporting framework centred around SEBI’s Business Responsibility and Sustainability Reporting (BRSR) framework.

BRSR reporting is mandatory for the top 1,000 listed entities by market capitalisation.

India also introduced BRSR Core, which focuses on selected key ESG indicators and provides for a phased assurance framework.

India’s ESG reporting ecosystem also involves:

• Companies Act, 2013
• CSR provisions
• SEBI regulations
• Stock-exchange requirements
• Green finance
• Sustainable finance initiatives

The Indian framework is therefore broader than simply applying IFRS S1 and S2.

5. ESG Reporting in the European Union

The European Union has one of the world’s most comprehensive sustainability reporting systems.

The central legislation is the Corporate Sustainability Reporting Directive (CSRD), supported by the European Sustainability Reporting Standards (ESRS).

The framework covers:

• Climate change
• Pollution
• Water
• Biodiversity
• Circular economy
• Workforce
• Human rights
• Consumers
• Business conduct
• Governance

The EU framework uses the concept of double materiality, considering both financial materiality and a company’s impacts on people and the environment.

In 2026, the European Commission adopted revised ESRS designed to simplify sustainability reporting and reduce administrative burdens.

6. ESG Reporting in the United Kingdom

The UK has been developing a sustainability reporting framework based increasingly on the ISSB model.

The UK Sustainability Reporting Standards, or UK SRS, were published in February 2026.

In September 2026, the Financial Conduct Authority finalised rules for listed companies to report against UK SRS S1 and S2 using a comply-or-explain approach for accounting periods beginning on or after 1 January 2027.

The UK framework also includes existing requirements relating to:

• Climate-related disclosures
• Strategic reports
• Streamlined Energy and Carbon Reporting
• Sustainability-related financial information

7. ESG Reporting in the United States

The United States does not have one comprehensive federal ESG reporting law applicable to all companies.

The regulatory environment involves several authorities, including:

• Securities and Exchange Commission
• Federal Trade Commission
• State regulators
• Sector-specific regulators

The SEC adopted climate-related disclosure rules in 2024, but implementation and litigation developments have significantly affected their status.

Companies therefore need to distinguish between:

• Federal securities requirements
• State requirements
• Industry-specific requirements
• Voluntary ESG reporting
• Investor-driven disclosures

California is particularly important because of its climate disclosure legislation.

8. ESG Reporting in China

China is developing a national sustainability disclosure framework involving multiple regulators.

The 2024 Corporate Sustainability Disclosure Standards – Basic Standard (Trial) provides an important foundation.

China’s framework addresses:

• Governance
• Strategy
• Risk and opportunity management
• Metrics and targets

Chinese stock exchanges have also developed sustainability reporting requirements for listed companies.

China’s sustainability policy is closely connected with its national objectives of:

• Carbon peaking before 2030
• Carbon neutrality before 2060

9. ESG Reporting in Japan

Japan has been developing sustainability disclosure requirements with significant alignment to the ISSB framework.

The Sustainability Standards Board of Japan has developed Japanese sustainability disclosure standards based on ISSB Standards.

Japan’s framework particularly focuses on information useful to investors, including:

• Climate risks
• Opportunities
• Governance
• Strategy
• Risk management
• Metrics and targets

Japan is therefore an important example of how a major economy can build local requirements around an international sustainability baseline.

10. ESG Reporting in Australia

Australia has introduced mandatory climate-related financial disclosure requirements through its sustainability reporting reforms.

The Australian framework is closely aligned with the ISSB approach.

The regime is being phased in according to company size and other criteria.

Australian companies subject to the regime need to consider:

• Climate risks
• Climate opportunities
• Governance
• Strategy
• Risk management
• Metrics and targets
• Greenhouse gas emissions

The phased approach demonstrates an important global trend: large companies generally face requirements earlier than smaller companies.

11. ESG Reporting in Singapore

Singapore has developed sustainability reporting requirements through the Singapore Exchange and national sustainability initiatives.

Singapore is also moving toward an ISSB-aligned reporting framework.

Its approach includes:

• Climate-related disclosures
• Sustainability reporting
• Scope 1 and Scope 2 emissions
• Scope 3 considerations
• Assurance
• Phased implementation

Singapore has also established a roadmap for external limited assurance of Scope 1 and Scope 2 emissions, with phased application beginning with listed companies from financial years commencing on or after 1 January 2029.

12. ESG Reporting in Malaysia

Malaysia has adopted an ISSB-based approach through its National Sustainability Reporting Framework (NSRF).

Bursa Malaysia has introduced phased sustainability reporting requirements.

The framework is being implemented in groups based on company characteristics and size.

Important areas include:

• Climate disclosure
• Scope 1
• Scope 2
• Scope 3
• Sustainability statements
• Performance indicators
• Assurance

Malaysia is therefore one of the leading examples of an emerging-market jurisdiction adopting an ISSB-aligned reporting architecture.

13. ESG Reporting in Canada

Canada does not currently have one universal mandatory ESG reporting regime for every company.

However, sustainability disclosure developments involve:

• Canadian Securities Administrators
• Office of the Superintendent of Financial Institutions
• Canadian Sustainability Standards Board

The Canadian Sustainability Disclosure Standards are designed to align closely with ISSB Standards.

Financial institutions also face specific climate-related expectations.

Therefore, Canadian companies need to distinguish between general corporate reporting requirements and sector-specific requirements.

14. ESG Reporting in New Zealand

New Zealand has a mandatory climate-related disclosure regime for specified large entities known as Climate Reporting Entities.

The framework is established under the Financial Markets Conduct Act and supported by standards issued by the External Reporting Board.

The regime is based around:

1. Governance
2. Strategy
3. Risk management
4. Metrics and targets

The New Zealand framework demonstrates that mandatory sustainability reporting can initially focus specifically on climate-related financial disclosures, rather than requiring comprehensive ESG reporting.

15. ESG Reporting in South Korea

South Korea is developing sustainability disclosure requirements with increasing alignment to the ISSB framework.

The country is considering phased implementation based on company characteristics.

Expected areas include:

• Climate risks
• Sustainability-related financial information
• Governance
• Strategy
• Metrics
• Targets

South Korea is part of the group of jurisdictions continuing to develop their local ISSB-related approaches.

16. ESG Reporting in Brazil

Brazil is an important example of a country moving toward ISSB-aligned sustainability reporting.

Brazil has adopted a regulatory approach incorporating IFRS Sustainability Disclosure Standards.

The Brazilian framework is relevant particularly for listed companies and capital-market participants.

This demonstrates the increasing influence of ISSB across emerging markets.

17. ESG Reporting in Hong Kong

Hong Kong has introduced sustainability disclosure requirements based substantially on the ISSB framework.

The Hong Kong Stock Exchange has developed climate-related disclosure requirements for listed issuers.

The framework focuses on:

• Governance
• Strategy
• Risk management
• Metrics and targets
• Climate-related risks
• Opportunities

Hong Kong’s position as an international financial centre makes its sustainability reporting framework particularly relevant for multinational businesses.

18. ESG Reporting in Switzerland

Switzerland has developed sustainability and climate-related reporting requirements through its corporate law and regulatory framework.

The country is also considering further developments relating to international sustainability standards.

Swiss companies with international operations may also face reporting obligations through their EU or other foreign activities.

19. ESG Reporting in the Middle East

Middle Eastern jurisdictions are increasingly developing sustainability disclosure frameworks.

Countries and financial centres such as:

• UAE
• Saudi Arabia
• Qatar
• Bahrain
• Abu Dhabi
• Dubai

are increasing their focus on:

• Climate risk
• Sustainable finance
• Green bonds
• ESG investment
• Corporate sustainability

Financial centres in the region are particularly important because international investors increasingly require comparable sustainability information.

20. ESG Reporting in Africa

African countries are also developing sustainability reporting requirements.

Several jurisdictions are considering or adopting ISSB-aligned frameworks.

The growing importance of:

• Mining
• Energy
• Agriculture
• Infrastructure
• Natural resources
• Financial services

makes ESG reporting increasingly relevant to African economies.

For companies operating internationally, country-specific reporting requirements should therefore be monitored carefully.

21. What ESG Information Is Common Across Countries?

Although regulations differ, many frameworks require similar information.

Common categories include:

Governance

• Board oversight
• Management responsibility
• ESG expertise
• Internal controls

Strategy

• ESG risks
• ESG opportunities
• Business-model implications
• Transition plans

Risk Management

• Identification
• Assessment
• Mitigation
• Monitoring

Metrics and Targets

• GHG emissions
• Energy
• Water
• Waste
• Workforce
• Safety
• Diversity
• ESG targets

22. Is Scope 3 Reporting Becoming Important Globally?

Yes.

Scope 3 represents indirect greenhouse gas emissions across the value chain.

It can include:

• Purchased goods
• Transportation
• Business travel
• Employee commuting
• Use of sold products
• End-of-life treatment
• Investments

However, the mandatory timing and extent of Scope 3 reporting differ significantly between jurisdictions.

Some countries provide transition reliefs or phase in Scope 3 requirements.

Companies with international supply chains should therefore prepare for increasing Scope 3 data requests even when their own domestic law does not yet require complete Scope 3 reporting.

23. What Is the Difference Between ESG and Climate Reporting?

ESG is broader than climate reporting.

Climate reporting

Primarily focuses on:

• GHG emissions
• Climate risks
• Climate opportunities
• Transition plans
• Resilience
• Climate targets

ESG reporting

Can additionally cover:

• Employees
• Human rights
• Diversity
• Customer issues
• Supply chains
• Biodiversity
• Water
• Waste
• Business ethics
• Anti-corruption
• Governance

Some jurisdictions initially mandate climate reporting and may later expand sustainability requirements.

24. What Is Double Materiality?

Double materiality is particularly important in the EU.

It considers two perspectives:

Financial materiality

How sustainability matters can affect the company’s financial position, performance, cash flows, access to finance or cost of capital.

Impact materiality

How the company’s activities affect:

• People
• Environment
• Communities
• Workers
• Natural resources

This differs from the investor-focused approach of ISSB, which is primarily designed to provide information useful to investors.

25. Are ESG Reports Required to Be Assured?

Assurance requirements vary by country.

Some jurisdictions require assurance over specific ESG information.

Others are introducing assurance gradually.

The ISSB itself does not mandate assurance; assurance requirements are determined by individual jurisdictions.

Companies should therefore monitor:

• Assurance level
• Scope of assurance
• Eligible assurance providers
• Applicable standards
• Effective dates

The global direction is toward stronger reliability of sustainability information.

26. How Are Multinational Companies Affected?

A multinational company may need to comply with multiple frameworks simultaneously.

For example, an Indian company may have:

• Indian BRSR obligations
• EU reporting exposure through an EU subsidiary
• Customer ESG questionnaires from international buyers
• Bank sustainability-data requirements
• ISSB-aligned investor reporting

Therefore, multinational companies should build a central ESG data architecture rather than preparing each country’s report independently.

27. Why Should Indian Exporters Care About Global ESG Rules?

An Indian company may not directly fall under a foreign reporting law.

However, its customers may.

For example, an Indian supplier to a European multinational may receive requests for:

• Carbon emissions
• Energy consumption
• Water usage
• Employee data
• Human-rights information
• Supply-chain policies
• Climate targets

This creates an indirect ESG reporting requirement through the value chain.

Therefore, ESG is becoming relevant even for companies outside the direct regulatory perimeter.

28. What Should MSMEs Do?

MSMEs should not wait until a customer makes a formal ESG data request.

They can begin by maintaining:

• Electricity consumption
• Fuel consumption
• Renewable energy
• Waste data
• Water consumption
• Employee data
• Workplace safety
• Supplier information
• Basic governance policies

A simple ESG data register can become extremely valuable when large customers request sustainability information.

29. What Should CFOs Do in 2026?

CFOs should treat ESG reporting as a data and control project, not simply a sustainability communication exercise.

Key actions include:

1. Identify applicable jurisdictions.
2. Determine reporting scope.
3. Map regulatory requirements.
4. Identify ESG data owners.
5. Establish reporting controls.
6. Define ESG KPIs.
7. Document methodologies.
8. Assess data gaps.
9. Prepare for assurance.
10. Integrate ESG into financial planning.

30. What Is the Role of CA and CMA Professionals?

The global expansion of ESG reporting creates significant opportunities for finance professionals.

Chartered Accountants

Can contribute to:

• ESG assurance
• Internal controls
• Reporting
• Risk management
• Governance
• Compliance
• Sustainability-related financial disclosures

Cost and Management Accountants

Can contribute to:

• Carbon costing
• Environmental management accounting
• Resource efficiency
• Cost-benefit analysis
• ESG budgeting
• KPI development
• Internal carbon pricing
• Sustainability performance measurement

ESG is therefore becoming an important extension of traditional finance and management accounting.

31. What Is the Future of Global ESG Reporting?

The direction of travel is clear: greater comparability, stronger data and increasing regulatory integration.

The ISSB is becoming an important global baseline, while countries retain the ability to introduce local requirements.

The future is likely to involve:

• ISSB-aligned standards
• Digital ESG reporting
• Greater assurance
• More Scope 3 information
• Supply-chain reporting
• Climate transition plans
• ESG data controls
• Increasing regulatory scrutiny

However, implementation will continue to differ by jurisdiction.

32. Global ESG Reporting Comparison

33. What Should Companies Do Now?

A company preparing for global ESG requirements should follow a practical roadmap.

Phase 1 – Regulatory Mapping

Identify every country where the company:

• Operates
• Is listed
• Has subsidiaries
• Has major customers
• Has financing arrangements

Phase 2 – ESG Gap Assessment

Compare current information with applicable reporting requirements.

Phase 3 – Data Architecture

Create systems for:

• Emissions
• Energy
• Water
• Waste
• Workforce
• Governance
• Supply chain

Phase 4 – Internal Controls

Establish:

• Data owners
• Approval procedures
• Evidence requirements
• Review controls
• Documentation

Phase 5 – Reporting

Prepare disclosures using the applicable jurisdictional framework.

Phase 6 – Assurance

Prepare ESG information for independent review or assurance where required.

34. Global ESG Reporting Checklist for 2026

Companies should ask:

• Which ESG regulations apply to us?
• Are we listed?
• What is our market capitalisation?
• What is our revenue?
• How many employees do we have?
• Do we operate in the EU?
• Do we have UK reporting exposure?
• Do we have U.S. state-level exposure?
• Are we part of an international supply chain?
• Do our customers require Scope 3 data?
• Are our ESG disclosures subject to assurance?
• Are our ESG targets measurable?
• Can we substantiate every material ESG claim?

Conclusion

ESG reporting in 2026 is no longer a single global reporting exercise.

It is a multi-jurisdictional regulatory and business requirement that varies according to company size, listing status, industry, geography and value-chain relationships.

The most important global development is the emergence of the ISSB Standards as a common baseline for sustainability-related financial disclosures. However, jurisdictions continue to develop their own approaches, including additional requirements, different effective dates, assurance rules and reporting scopes.

For businesses, the key lesson is simple:

Do not prepare ESG reporting only when a regulation becomes mandatory.

Build the data, governance, controls and expertise now.

For CFOs, Chartered Accountants and Cost and Management Accountants, this creates a major professional opportunity. ESG reporting is increasingly moving from a specialist sustainability function into the mainstream of finance, risk management, corporate reporting and strategic decision-making.

The companies that build reliable ESG information systems today will be better prepared for the increasingly connected global reporting environment of tomorrow.

The Worldonomics Times – ESG Knowledge Series