ESG Regulations — Narrower Than in 2025, and Still Built on One Inventory
“ESG regulation” is not one law. It is three kinds of law — corporate reporting, rules for investment products, and supply-chain due diligence — written separately in each jurisdiction. Which of them reach a company depends on where it is listed or does business and how large it is.
In 2026 nearly every one of them narrowed. The EU cut its reporting law to companies with more than 1,000 employees and over €450 million turnover, and its due-diligence law to more than 5,000 and €1.5 billion. The UK finalised its standards and then chose comply-or-explain over a mandate. The US Securities and Exchange Commission proposed withdrawing a climate rule that never took effect. Brazil made its ISSB requirement voluntary.
What did not narrow is the thing all of these rules ask for. Every one of them starts from a greenhouse gas inventory measured with the GHG Protocol, and most reach into suppliers through scope 3. Fewer companies must publish a report; the request for data still travels down the supply chain. This page sets out who must report, where and from when, as of 2 October 2026, and links to the full reference page for each rule.
ESG reporting requirements at a glance
If you only need to know what a rule asks of a company, start here. Each row is the requirement in force or adopted on 2 October 2026; the numbered sections below give the detail and the sources.
| Rule | Who must report | What, and assurance | When |
|---|---|---|---|
| EU CSRD | More than 1,000 employees and over €450m turnover; non-EU groups with over €450m EU turnover from 2028 | Scope 1, 2 and 3 (ESRS E1). Assurance: limited | Financial year 2027, reported in 2028 |
| UK listed companies (FCA) | Commercial, transition-category and secondary-listed issuers | UK SRS S2; scope 3 after one year. Say whether assurance was obtained | Periods from 1 January 2027 Comply or explain |
| UK large companies | More than 500 employees and over £500m turnover | Climate-related financial disclosures. No assurance required | In force since 2022 |
| UK SECR | Two of: £54m turnover, £27m balance sheet, 250 employees | Energy use and the emissions from it. No assurance required | In force; consultation planned |
| California SB 253 | US companies over $1bn revenue doing business in California | Scope 1 and 2; scope 3 from 2027. Assurance: limited in the statute, but CARB accepts 2026 reports without it; reasonable from 2030 | 10 November 2026 |
| California SB 261 | Over $500m revenue | Climate-risk report every two years | Enjoined |
| Australia AASB S2 | Groups 1–3 by revenue, assets and employees | Scope 1 and 2; scope 3 from year two. Assurance: phased to reasonable | Group 3 from 1 July 2027 |
| Japan SSBJ | Tokyo Prime Market, ¥3tn+ market value first | ISSB-based, scope 3 after relief. Assurance required from the year after reporting starts | Years ending 31 March 2027 |
| Singapore SGX | All listed companies | Scope 1 and 2; scope 3 for STI companies from FY2026. Assurance: scope 1 and 2 from FY2029 | In force since FY2025 |
| US federal (SEC) | — | None in force | Rescission proposed |
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1. Three kinds of ESG law
| Corporate disclosure | Financial products | Due diligence | |
|---|---|---|---|
| Requires | Publishing sustainability information, including emissions, with the annual report | Describing how funds treat sustainability; classifying green activity | Finding, preventing and fixing harm in operations and supply chains |
| Examples | CSRD, UK SRS, California SB 253, AASB S2, SSBJ | SFDR, EU Taxonomy, FCA SDR | EU CSDDD |
| Reaches | Large or listed companies, by size, listing or revenue | Asset managers, banks, insurers — and the companies that feed them data | Only the very largest companies |
| Built on | ESRS in the EU; IFRS S1 and S2 almost everywhere else | The regulation itself, plus company Taxonomy data | OECD and UN guidance on responsible business conduct |
Two standard families sit under almost all corporate disclosure law. The EU uses the European Sustainability Reporting Standards (ESRS). Nearly everyone else uses the ISSB’s IFRS S1 and IFRS S2, adopted nationally under local names. A regulation decides who reports and when; a standard decides what the report contains. Confusing the two is behind most wrong answers to “does this apply to us?”.
2. 2026 in one view
3. EU: the CSRD after Omnibus I
The Corporate Sustainability Reporting Directive was amended by Directive (EU) 2026/470, the first “Omnibus” simplification package. It was adopted on 24 February 2026, published in the Official Journal on 26 February and entered into force on 18 March 2026.
| Who | Test after Directive (EU) 2026/470 | From |
|---|---|---|
| EU company | More than €450 million net turnover and more than 1,000 employees on average. No balance-sheet test. | Financial years from 1 January 2027 |
| EU parent of a group | The same two thresholds, on a consolidated basis | Financial years from 1 January 2027 |
| Non-EU group | More than €450 million net turnover in the EU in each of the last two years, reported through an EU subsidiary or branch with more than €200 million turnover | Financial years from 1 January 2028 |
| Listed SMEs | Removed from scope | — |
- Companies that already reported. “Wave one” companies, reporting since financial year 2024, fall out from 2027 if they are below the new thresholds. Member states may exempt them for 2025 and 2026 as well; whether they do is a national choice.
- Assurance stays limited. The planned move to reasonable assurance was removed. The Commission must adopt limited-assurance standards by 1 July 2027.
- No sector standards. The power to adopt sector-specific ESRS was deleted; the Commission may issue guidance instead.
- A cap on supply-chain requests. A company with up to 1,000 employees may decline to provide more than the value chain cap, a list of the voluntary standard’s essential datapoints, when an in-scope customer asks, from financial year 2027. This “value-chain cap” is the first rule anywhere that limits how far a reporting duty is pushed onto suppliers.
- Transposition. Member states must transpose the CSRD changes by 19 March 2027. There is no official Commission tracker of progress yet, so this page gives no count.
Large undertakings that “exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year”.
4. EU: the ESRS, simplified
On 3 July 2026 the Commission adopted two delegated acts, both published in the Official Journal on 21 September 2026:
- Delegated Regulation (EU) 2026/1563 rewrites the ESRS. It enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027. For financial year 2026, companies may use the old ESRS, the revised ones, or the old ones with listed reliefs. The Commission cites EFRAG’s estimate that mandatory datapoints fall by 61%.
- Delegated Regulation (EU) 2026/1560 sets the standard for voluntary use by companies protected by the value-chain cap. It is what a smaller supplier answers to, and the cap itself applies from financial years beginning 1 January 2027. It builds on the EU’s earlier voluntary SME standard, the VSME.
What changed inside the climate standard is covered on our ESRS E1 page; how a company decides which topics to report is explained under double materiality.
5. EU: the Taxonomy
The EU Taxonomy classifies which economic activities count as environmentally sustainable. Companies within CSRD scope report the share of turnover, capital and operating expenditure that is Taxonomy-aligned. The Taxonomy Regulation itself was not amended by the Omnibus directive; it follows the CSRD, so the narrower CSRD scope carries straight through.
Delegated Regulation (EU) 2026/73 simplified the reporting from 1 January 2026, with the old rules still allowed for financial year 2025. Its main relief is a materiality threshold: a company may skip assessing activities that together make up less than 10% of turnover, with matching tests for capital and operating expenditure. Two further draft acts on the technical screening criteria were consulted on in spring 2026 and are not yet adopted.
6. EU: SFDR now, and SFDR 2.0
The Sustainable Finance Disclosure Regulation, Regulation (EU) 2019/2088, governs what asset managers, insurers and advisers disclose about sustainability. Its “Article 8” and “Article 9” product labels still apply.
Under the proposal, products in the sustainable and transition categories would need at least 70% of investments to meet the category’s criteria. The Commission proposed that it apply 18 months after entry into force; the Council’s mandate says 24. None of it applies until a final text is agreed and that period runs. Until then the current SFDR applies.
7. EU: the CSDDD
The Corporate Sustainability Due Diligence Directive was cut back by the same Omnibus directive.
| After Directive (EU) 2026/470 | |
|---|---|
| EU companies | More than 5,000 employees and more than €1.5 billion net worldwide turnover |
| Non-EU companies | More than €1.5 billion net turnover in the EU |
| Franchise route | EU royalties above €75 million and turnover above €275 million |
| Dates | Transposed by 26 July 2028; applies from 26 July 2029; Article 16 reporting from financial years beginning 1 January 2030 |
| Transition plan | Deleted Article 22 removed |
| Penalties | Capped at 3% of net worldwide turnover |
| Civil liability | The EU-wide liability regime was removed; liability now follows national law |
8. EU: the other instruments
| Instrument | What it does | Status |
|---|---|---|
| ESG Ratings Regulation (EU) 2024/3005 | Authorises and supervises ESG rating providers | Applies from 2 July 2026 |
| European Green Bond Standard (EU) 2023/2631 | A voluntary “EuGB” label for Taxonomy-aligned bonds | Applies from 21 December 2024 |
| Directive (EU) 2024/825 (EmpCo) | Bans generic green claims and offset-based product claims | Applies from 27 September 2026 |
| Green Claims Directive | Would have required claims to be verified in advance | Stalled Never adopted; not formally withdrawn |
9. United Kingdom
The UK has its own versions of the ISSB standards, UK SRS S1 and S2, published by the government on 25 February 2026 and available for voluntary use by any entity. They differ from IFRS S1 and S2 in a few deliberate ways: no effective date, no fixed time limit on the reliefs for scope 3 and non-climate topics, the SASB references softened from “shall” to “may”, and an explain requirement for financial institutions that do not report financed emissions.
On 30 September 2026 the Financial Conduct Authority published Policy Statement PS26/19. It had consulted on making climate reporting mandatory for listed companies. It chose instead “a comply or explain approach across all categories of disclosures”.
| FCA PS26/19 | |
|---|---|
| In scope | Listed commercial companies, transition-category issuers, non-equity and non-voting share issuers, and — added since the consultation — secondary-listed international companies and depositary-receipt issuers |
| Out of scope | Closed-ended investment funds, open-ended investment companies, shell companies |
| Basis | Comply or explain against UK SRS |
| From | Accounting periods beginning on or after 1 January 2027; first reports in 2028 |
| Reliefs | One year for scope 3; two years for the wider UK SRS S1 disclosures |
| Assurance | Not required; companies say whether they obtained it, from whom and at what level |
| Transition plans | Not required; companies say whether they have one and where |
| Replaces | The TCFD-aligned listing rule |
Three other UK duties are unchanged for now:
- Climate-related financial disclosure regulations (2022) still apply to companies with more than 500 employees and turnover above £500 million. A post-implementation review is due by spring 2027.
- SECR still applies to large companies (two of: £54 million turnover, £27 million balance sheet, 250 employees). Its 2026 review recommended keeping it with amendments, and the government plans a consultation on SECR and ESOS later in 2026.
- Private companies have no UK SRS requirement. Whether to add one is part of the government’s Modernising Corporate Reporting consultation, open until 30 November 2026.
10. United States: the federal picture
The SEC’s climate disclosure rule was adopted but never applied, and is now being withdrawn.
Two fund-side items are often confused with it. The SEC’s 2022 proposal for ESG disclosures by funds and advisers was formally withdrawn in June 2025. The amended Names Rule, which requires funds with ESG-type names to invest at least 80% accordingly, has compliance dates of 11 June 2026 for fund groups with $1 billion or more in net assets and 11 December 2026 for smaller groups.
11. United States: California
California’s two laws apply to US companies that do business in the state, wherever they are headquartered. Our California reference covers them in depth.
| SB 253 — emissions | SB 261 — climate risk | |
|---|---|---|
| Who | Annual revenue above $1 billion; CARB measures it as the lower of the two previous fiscal years | Annual revenue above $500 million |
| What | Scope 1 and 2 every year; scope 3 on a schedule CARB sets, from 2027 | A climate-risk report every two years, to TCFD or IFRS S2 |
| Status | In effect First report due 10 November 2026 | Enjoined Ninth Circuit order of 18 November 2025 |
| Assurance | Statute: limited from 2026, reasonable from 2030; scope 3 limited from 2030. CARB will accept 2026 reports without it | — |
| Penalty cap | $500,000 per reporting year | $50,000 per reporting year |
First, it comes from CARB’s regulation, which CARB resubmitted to California’s Office of Administrative Law on 21 September 2026 and which had not been approved on 2 October. CARB continues to state the date. Second, for 2026 only, companies may report the emissions data they already held or were collecting on 5 December 2024 — or file a statement that they held none. Scope 3 is not required in 2026.
For scope 3 from 2027, CARB staff proposed in July 2026 requiring five categories — purchased goods and services, fuel- and energy-related activities, waste, business travel and commuting — with the other ten voluntary. That is a proposal for a later regulation, not adopted law. Under the statute, scope 3 statements made in good faith are protected from penalties, and between 2027 and 2030 scope 3 penalties apply only for failing to file at all.
On SB 261, the Ninth Circuit heard argument on 9 January 2026 and had not ruled by 2 October. CARB’s position:
“In light of the Court’s order, CARB will not enforce Health and Safety Code section 38533 against covered entities for failing to post and submit reports by the January 1, 2026, statutory deadline.”
No other state has enacted a corporate climate disclosure law. New York’s bill (S9072A) passed the state Senate on 10 February 2026 and has not passed the Assembly; Colorado’s was postponed indefinitely in 2025.
12. The ISSB baseline
Outside the EU and the US, corporate disclosure law converges on the ISSB standards. On 18 August 2026 the IFRS Foundation said that “more than 45 jurisdictions are using ISSB Standards” and that “by 2027, companies in 18 jurisdictions will be issuing reports”. It publishes a profile of each jurisdiction’s adoption; 23 were online on 24 September 2026.
The standards themselves moved too. Amendments to IFRS S2 issued in December 2025, effective for periods beginning on or after 1 January 2027, let financial institutions limit scope 3 category 15 to financed emissions and give relief where a jurisdiction requires different GWP values. A national regime built on IFRS S2 usually inherits both its reliefs and its scope 3 requirement.
13. Eight more regimes
| Jurisdiction | Rule | Who, and from when | Basis |
|---|---|---|---|
| Australia | AASB S2 | Group 1 from 1 January 2025; Group 2 from 1 July 2026; Group 3 from 1 July 2027. Group 3 is two of: $50m revenue, $25m gross assets, 100 employees. Scope 3 from the second year | Mandatory |
| Japan | SSBJ standards | Tokyo Prime Market only, by five-year average market value: ¥3 trillion+ for years ending March 2027; ¥1 trillion+ March 2028; ¥500 billion+ March 2029 | Mandatory |
| Singapore | SGX climate rules | All listed: scope 1 and 2 from FY2025. Straits Times Index companies: full ISSB-based climate reporting from FY2025, scope 3 from FY2026. Other listed: FY2028 or FY2030 by size. Large private companies: FY2030 | Mandatory |
| Hong Kong | HKEX climate requirements | Main Board scope 1 and 2 mandatory; Hang Seng Composite LargeCap companies report in full from 1 January 2026. Full ISSB alignment for large publicly accountable entities targeted by 2028 | Mixed |
| Mainland China | SSE and SZSE guidelines | SSE 180, STAR 50, SZSE 100, ChiNext Index and dual-listed companies: first reports for 2025, published by 30 April 2026. The Ministry of Finance’s national standards are voluntary for now | Mixed |
| India | SEBI BRSR | Top 1,000 listed companies. Assurance or assessment of BRSR Core phases up to the top 1,000 in FY2026–27; value-chain disclosures voluntary | Mandatory |
| Canada | CSDS 1 and 2 | Voluntary. Securities regulators paused a mandatory rule on 23 April 2025. Federally regulated banks and insurers report under OSFI B-15, with scope 3 from fiscal 2028 | Banks only |
| Brazil | CVM Resolution 193 | Mandatory ISSB reporting repealed by CVM 244 (29 May 2026). Voluntary, but a company that opts in must continue for three years; non-reporters explain why from 2027 | Voluntary |
14. The dates that matter, 2026 to 2030
| Date | What happens |
|---|---|
| 10 Nov 2026 | California SB 253: first scope 1 and 2 reports (subject to OAL approval of CARB’s regulation). Revised ESRS enter into force |
| 30 Nov 2026 | UK: Modernising Corporate Reporting consultation closes |
| 1 Jan 2027 | EU: new CSRD scope, revised ESRS and value-chain cap apply. UK: SRS comply-or-explain periods begin. IFRS S2 amendments take effect |
| 19 Mar 2027 | EU: CSRD transposition deadline |
| 31 Mar 2027 | Japan: first year-end for the largest Prime Market companies |
| 1 Jul 2027 | Australia: Group 3 starts. EU: limited-assurance standards due |
| 1 Jan 2028 | EU: non-EU groups enter CSRD scope |
| 26 Jul 2028 | EU: CSDDD transposition deadline |
| 26 Jul 2029 | EU: CSDDD applies |
| 2030 | California: reasonable assurance for scope 1 and 2, limited for scope 3. Singapore: large private companies begin |
15. What every regime asks for
Underneath the differences, every corporate rule on this page asks for a greenhouse gas inventory measured in the GHG Protocol’s three scopes. Scope 1 and 2 are required wherever a rule applies. Scope 3 and assurance are where they part:
| Rule | Scope 3 | Assurance |
|---|---|---|
| EU CSRD / ESRS E1 | Required where material | Limited |
| UK SRS (FCA) | After one year, comply or explain | Disclose whether obtained |
| California SB 253 | From 2027, schedule set by CARB | Limited, then reasonable from 2030 |
| Australia AASB S2 | From the second year | Phased up to reasonable |
| Japan SSBJ | After first-year relief | From the year after reporting starts |
| Singapore | STI from FY2026; others voluntary for now | Scope 1 and 2 limited, from FY2029 |
Scope 3 is measured in other companies’ data, which is why a rule that applies to a large customer reaches its suppliers years before any rule applies to them directly. The assurance level decides how good that data has to be: limited assurance tolerates estimates with stated methods; reasonable assurance expects evidence.
16. Common errors
| Error | The position on 2 October 2026 |
|---|---|
| “CSRD applies from 250 employees” | That was the original test. Since Directive (EU) 2026/470 it is more than 1,000 employees and more than €450 million turnover, both required |
| “The SEC rule has been rescinded” | Rescission is proposed, not final. The rule never took effect either way |
| “UK climate reporting is now mandatory” | The FCA chose comply-or-explain. A listed company must report or explain why not |
| “The UK dropped climate reporting” | It dropped the mandate, not the requirement to report or explain |
| “SB 253 does not apply to us; we are not Californian” | It reaches any US company with over $1 billion revenue that does business in California |
| “SB 253 scope 3 has a safe harbour until 2030” | Good-faith scope 3 statements are protected with no end date; separately, 2027–2030 penalties apply only to non-filing |
| “SFDR Article 8 and 9 are gone” | They apply until SFDR 2.0 is agreed and its application period runs |
| “Brazil requires ISSB from 2026” | CVM 244 made it voluntary in May 2026 |
17. What to do now
- Map your obligations by entity, not by group. CSRD, SB 253 and the ISSB regimes each test a different legal entity against a different threshold. The obligation finder runs nine of them.
- Build the scope 1 and 2 inventory first. It is required by every regime on this page and it is the part you control.
- Screen scope 3 before anyone asks. A spend-based screen shows which categories matter; customers under CSRD, SB 253 or an ISSB regime will ask for those first.
- Record every factor’s source and vintage. Assurance, limited or reasonable, starts by tracing a number back to where it came from.
- Recheck the status dates. At least four of the rules on this page changed between May and September 2026, and SFDR 2.0, the SEC rescission, CARB’s regulation and the SB 261 appeal all await a decision.
18. How GreenCalculus implements this
GreenCalculus covers the measurement layer these regimes share: sourced emission factors, scope 1, 2 and 3 calculators with an audit trail, and per-regime pages for ESRS E1, IFRS S2, California, Australia, Japan and Singapore. The disclosure calculators work through each regime’s emissions requirements.
What we do not do: give legal advice or decide whether a particular company is in scope. Thresholds depend on consolidation, entity structure and national transposition choices that a page cannot see. Use this page and the obligation finder to narrow the question, and confirm the answer with counsel. We do not yet have reference pages for Hong Kong, mainland China, India or Brazil.
19. Frequently Asked Questions
It depends on where a company is listed or does business and how large it is. In the EU, the CSRD requires companies with more than 1,000 employees and over €450 million turnover to report scope 1, 2 and 3 emissions with limited assurance, from financial year 2027. UK listed companies report against UK SRS on a comply-or-explain basis from 2027. In the US, California’s SB 253 requires companies with over $1 billion revenue to report scope 1 and 2 emissions by 10 November 2026. ISSB-based rules apply in Australia, Japan and Singapore.
In the EU: the CSRD for corporate reporting, the EU Taxonomy, SFDR for investment products and the CSDDD for supply-chain due diligence. In the UK: UK SRS for listed companies on a comply-or-explain basis, the 2022 climate disclosure regulations and SECR. In the US: California’s SB 253 and SB 261, while the SEC’s federal rule is being withdrawn. Elsewhere: ISSB-based rules such as Australia’s AASB S2, Japan’s SSBJ standards and Singapore’s SGX rules. Status as of 2 October 2026.
EU companies, and EU parents of groups, with more than 1,000 employees on average and more than €450 million net turnover, for financial years from 1 January 2027. Non-EU groups with more than €450 million EU turnover follow from 2028. Listed SMEs were removed. The thresholds come from Directive (EU) 2026/470, which member states must transpose by 19 March 2027.
No. The SEC adopted a climate rule in March 2024, stayed it a month later, stopped defending it in court in March 2025 and proposed rescinding it on 29 May 2026. It never took effect. The live US obligation is California’s SB 253, which requires companies with over $1 billion revenue doing business in the state to report scope 1 and 2 emissions, with the first reports due 10 November 2026.
For listed companies it is comply-or-explain. The FCA’s Policy Statement PS26/19 of 30 September 2026 requires them to report against UK SRS for accounting periods beginning on or after 1 January 2027, or explain why not, with one year’s relief for scope 3 and two years for the wider S1 disclosures. Large companies also remain under the 2022 climate disclosure regulations and SECR.
A regulation is the law that says who must report and by when, such as the CSRD or SB 253. A standard sets out what the report contains, such as the ESRS or IFRS S2. Several regulations can point at one standard: Australia, Japan, Singapore and the UK all build on IFRS S1 and S2. The emissions figures inside all of them come from the GHG Protocol.
Rarely directly; every major rule targets large or listed companies. But large reporters must cover scope 3, which includes their suppliers, so small businesses are asked for emissions data anyway. In the EU, a company with up to 1,000 employees can decline requests that go beyond the value chain cap, the essential datapoints of the voluntary standard listed in Annex II of Delegated Regulation (EU) 2026/1560, from financial years beginning 1 January 2027.
Not yet. The Commission proposed a replacement in November 2025 with three product categories — sustainable, transition and ESG basics. The Council agreed its position in June 2026 and the European Parliament’s committee voted on 10 September 2026, but the two have not agreed a text. Until they do and the application period runs, the current SFDR, with its Article 8 and 9 disclosures, applies.
For breadth, the EU: no other jurisdiction combines corporate reporting, a classification system, fund disclosure and supply-chain due diligence. For emissions assurance, California and Australia go furthest, both moving to reasonable assurance. Japan and Australia make ISSB-based reporting a legal requirement, where the UK and Brazil leave it to comply-or-explain or choice.
Related References
- CSRD / ESRS E1 — the EU climate disclosure standard in full
- EU CSDDD — supply-chain due diligence
- EU Taxonomy Regulation — the classification behind green-share reporting
- IFRS S2 — the ISSB climate standard most regimes adopt
- California SB 253 and SB 261 — the live US obligation
- UK mandatory climate disclosures and SECR
- ESG reporting — what goes into a report
- Climate Disclosure Obligation Finder — which regimes reach a company
