The Global ESG Map in 2026: Who Requires What

The converging baseline

One organising fact is more useful than any other: a common technical standard now exists and is spreading.

The ISSB issued IFRS S1 and S2 in June 2023, consolidating the Climate Disclosure Standards Board and the Value Reporting Foundation, which had itself absorbed SASB. Adoption counts differ by source. The ISSB Chair stated in May 2026 that 43 or 44 jurisdictions were adopting, against 30 a year earlier, while the IFRS Foundation's own published figure was 36 as at June 2025. The Foundation counts jurisdictions that have adopted and those finalising steps to adopt as a single figure, so the two counts are not measuring the same thing.

The ISSB binds nobody by itself. It issues standards that jurisdictions choose to adopt, adapt or mandate. What makes it significant is the breadth of that adoption, and the fact that jurisdictions adopting it are doing so with local modification rather than local reinvention.

Europe: simplifying reporting, holding the border

The European Union built the most prescriptive regime in the world and has spent eighteen months trimming it.

What was cut. Omnibus I, Directive (EU) 2026/470, in force from 18 March 2026, raised the CSRD threshold for EU companies to more than 1,000 employees and above €450 million net turnover, leaving a separate third-country test with no employee limb that turns on €450 million generated within the Union, and narrowed the CSDDD to EU companies above 5,000 employees and €1.5 billion net worldwide turnover. Due diligence transposition moved to 26 July 2028, with first application on 26 July 2029.

What was kept. The conditions attached to goods entering the market. The Deforestation Regulation applies from 30 December 2026 despite two postponements. The EU Forced Labour Regulation, Regulation (EU) 2024/3015, applies from 14 December 2027 with no size threshold at all.

What is converging. The revised ESRS, adopted by the Commission on 3 July 2026 as C(2026) 5010 final and applying to financial years beginning on or after 1 January 2027, cut mandatory datapoints by 61 per cent, remove all voluntary datapoints, and reframe the standards as a fair presentation framework closer to the ISSB approach. The act had not yet appeared in the Official Journal at this review date, so it should be cited by its C-number.

For an Indian exporter, the European position is best summarised as: fewer of your customers must report, but the rules governing whether your goods may enter are unchanged or tightening.

The United States: two agendas moving in opposite directions

This is where the "global trend" framing breaks down most visibly.

Climate disclosure is retreating. The Securities and Exchange Commission adopted a climate disclosure rule in March 2024. It was litigated and stayed. In March 2025 the Commission ended its legal defence. On 29 May 2026 it proposed rescission, published in the Federal Register on 3 June 2026, with the comment period closing on 3 August 2026. The rule has not been finally rescinded.

Forced labour enforcement is expanding. On 31 July 2026 the Department of Homeland Security added 43 companies to the UFLPA Entity List with effect from 3 August 2026, taking it to 187 entities. That is a 30 per cent increase and the largest single expansion since the Act came into force. More than 24,300 shipments worth close to a billion dollars have been denied entry since enactment.

The same administration, in the same week, retreated on disclosure and expanded import enforcement by nearly a third. An Indian exporter tracking "US ESG policy" as a single variable will forecast badly.

Several American states also pursue their own requirements, which can differ from and occasionally conflict with the federal position.

The United Kingdom: consolidating on the ISSB

The United Kingdom has stayed on the tightening path at a measured pace and is the clearest example of the convergence thesis.

On the corporate side, the government published UK Sustainability Reporting Standards, endorsed and ISSB-aligned versions of IFRS S1 and S2, on 25 February 2026 for voluntary use. The Financial Conduct Authority has consulted on making them mandatory for listed companies from 1 January 2027.

On the financial services side, the Sustainability Disclosure Requirements regime operates with an anti-greenwashing rule and fund labelling categories, and moved into fuller enforcement through 2025 and 2026.

Separately, the Modern Slavery Act is being reformed. Provisions in the Immigration and Asylum Bill, introduced 30 June 2026 and through second reading on 13 July 2026, would make statement content mandatory and introduce penalties of up to 1 per cent of turnover or £1 million, whichever is higher.

Asia-Pacific: the adoption story

This is the part of the map that receives least attention in Western commentary and matters most to the convergence argument.

Japan. The Sustainability Standards Board of Japan finalised its first standards in March 2025, functionally aligned with IFRS S1 and S2. That is the agreed formulation and it matters: there has been no equivalence determination, and the Japanese standards make structural changes, including splitting the ISSB's general standard into separate general and application standards. The Financial Services Agency finalised a Cabinet Office Order in February 2026 making application legally mandatory on the phased basis below. They are voluntary for fiscal years ending March 2026 and become mandatory for the largest Prime Market listed companies from the fiscal year ending March 2027, with phased extension across the rest of the Prime Market through FY2028 and FY2029.

Singapore. The headline that circulates, mandatory ISSB-aligned reporting for large caps from FY2025, is now only a fragment of the position. On 25 August 2025 the accounting regulator and the exchange regulator deferred most of the timetable.

What survived for FY2025 is Scope 1 and Scope 2 reporting, mandatory for all listed issuers. Almost everything else moved:

• Scope 3 applies from FY2026 only to Straits Times Index constituents. For other listed issuers it remains voluntary until further notice. The FY2028 date for non-STI issuers at or above S$1 billion, and FY2030 below that, carries ISSB-based disclosure generally rather than Scope 3.
• External limited assurance on Scope 1 and 2, originally FY2027, is deferred to FY2032, verified against ACRA and SGX RegCo. An earlier FY2029 date for listed issuers generally does not survive that check and is not relied on here.

The regulators cited economic uncertainty and uneven readiness. Singapore also has no finalised local standards: a consultation on drafts opened on 27 July 2026. Anyone still describing Singapore as an early and complete adopter is working from the pre-August 2025 position.

Hong Kong. The obligation started earlier than most summaries suggest. Under the exchange's ESG Reporting Code, for financial years commencing on or after 1 January 2025, Scope 1 and Scope 2 reporting is mandatory for Main Board and GEM issuers, with the broader climate requirements applying to Main Board issuers on a comply-or-explain basis and voluntarily for GEM.

1 January 2026 is not the start date. It is when Hang Seng Composite LargeCap Index constituents move to full mandatory reporting of the complete climate requirements including Scope 3.

The 2028 reference that appears in commentary is an outer limit from the government's policy roadmap rather than a settled rollout date, with a further exchange consultation expected before then.

Australia. Climate-related disclosure aligned to IFRS S2 is mandated for large entities on a three-group phase-in, and the framing matters. Group 1 obligations attach to reporting periods beginning on or after 1 January 2025, which means the first reports were lodged during 2026, not 2025; by early May 2026 some 259 first reports had been lodged with the corporate regulator. Group 2 starts for periods beginning from 1 July 2026 and Group 3 from 1 July 2027.

Group membership turns on meeting at least two of three size tests, on consolidated revenue, consolidated gross assets and employee numbers, with separate routes capturing large asset owners and entities already reporting under the national greenhouse and energy reporting scheme regardless of size.

China. Describing China as having no mandatory timeline is true only of the national standards, and misleading about what actually binds companies today.

The exchange rules already bite. Guidelines issued by the Shanghai and Shenzhen exchanges, effective 1 May 2024, required constituents of specified indices and companies dual-listed in China and abroad to publish a sustainability report for calendar year 2025 by 30 April 2026. That deadline has passed. Reporting indicates the guidelines reach some 457 listed companies accounting for around two thirds of national emissions.

The national framework is separate and still phasing. The finance ministry has set out a basic standard, with specific standards and implementation guidance to follow. Its own terminology describes the standards as aligned or connected with the international baseline rather than based on it, which is a deliberately weaker formulation. China is adopting the technical architecture while setting its own pace and its own vocabulary.

India. The outlier in this group. India has a mandatory sustainability reporting regime in the BRSR and a live compliance carbon market, but has not adopted IFRS S1 and S2. Its framework overlaps with the ISSB standards without matching them.

India's position, stated plainly

Against this map, India sits in an unusual place worth naming precisely.

More advanced than most on mandatory reporting. The BRSR has been compulsory for the top 1,000 listed entities since FY2022 to 2023, with assurance or assessment of BRSR Core phasing up to the top 1,000 by FY2026 to 2027. Many jurisdictions adopting the ISSB standards are only now reaching mandatory status.

More advanced than most on carbon pricing. The Carbon Credit Trading Scheme has notified binding intensity targets for seven of nine hard-to-abate sectors, with roughly 490 obligated entities carrying binding obligations and the first compliance filing having fallen due on 31 July 2026.

Behind on interoperability. Because India has not adopted IFRS S1 and S2, an Indian multinational reporting under BRSR still faces a separate exercise to satisfy ISSB-aligned demands from foreign investors or listings.

That combination, ahead on obligation and behind on interoperability, is why formal India-ISSB alignment is the single development most worth watching.

What an Indian company should take from the map

Build to the ISSB baseline. It is the standard toward which the largest number of jurisdictions is converging, including the entire Asia-Pacific group that competes with India for the same capital. It is also where the ESRS is heading.

Track agendas, not jurisdictions. The United States demonstrates that climate disclosure and forced labour enforcement can move in opposite directions in the same week. Monitoring "US policy" as one variable produces wrong conclusions.

Distinguish reporting rules from market-access rules. Europe cut the first and kept the second. An exporter cares far more about the second.

Do not assume a rollback is global. Japan, Singapore, Hong Kong and Australia are all moving toward mandatory ISSB-aligned reporting on published timetables while European reporting scope contracts.

Frequently asked questions

Is there a single global ESG standard? No. There is a converging technical baseline in the ISSB standards, adopted by a growing number of jurisdictions, laid over jurisdictions that differ substantially in what they mandate and when. On the count, the ISSB Chair stated in May 2026 that 43 or 44 jurisdictions were adopting, against 30 a year earlier, while the IFRS Foundation's own published figure was 36 as at June 2025.

What did the EU change in 2026? Omnibus I, in force from 18 March 2026, raised the CSRD threshold for EU companies to more than 1,000 employees and above €450 million net turnover, with a separate third-country test that has no employee limb, narrowed the CSDDD, and moved due diligence transposition to 26 July 2028 with first application on 26 July 2029.

Has the US rescinded its climate disclosure rule? No. Rescission was proposed on 29 May 2026 and published in the Federal Register on 3 June 2026, with the comment period closing on 3 August 2026. The rule has not been finally rescinded.

Is US ESG enforcement weakening? Not uniformly. Federal climate disclosure is retreating while forced labour import enforcement expanded 30 per cent in a single announcement in July 2026.

What is the UK requiring? UK Sustainability Reporting Standards, ISSB-aligned, published 25 February 2026 for voluntary use, with the Financial Conduct Authority consulting on mandating them for listed companies from 1 January 2027. The SDR regime applies in financial services.

When does Japan's regime become mandatory? The Sustainability Standards Board of Japan finalised standards functionally aligned with IFRS S1 and S2 in March 2025. That is the agreed formulation: no equivalence determination has been made, and the Japanese standards make structural changes. They are voluntary for fiscal years ending March 2026 and mandatory for the largest Prime Market companies from the fiscal year ending March 2027.

What is required in Singapore? Climate reporting on a comply-or-explain basis from 2024 for all listed companies. The headline that mandatory ISSB-aligned reporting begins for large caps in FY2025 is only a fragment of the position after the 25 August 2025 deferral: all listed issuers report Scope 1 and 2 from financial years commencing on or after 1 January 2025, STI constituents keep ISSB-based disclosure from FY2025 and Scope 3 from FY2026, non-STI issuers at or above S$1 billion move to FY2028 and below that to FY2030, and Scope 3 stays voluntary for non-STI issuers until further notice.

What about Hong Kong and Australia? Hong Kong made Scope 1 and 2 mandatory for all issuers, LargeCap, other Main Board and GEM alike, for financial years commencing on or after 1 January 2025. LargeCap issuers move to the full climate requirements, including Scope 3, for financial years commencing on or after 1 January 2026. January 2026 is not the start date. Australia has mandated climate-related disclosure for large entities. Group 1 obligations attach to reporting periods beginning on or after 1 January 2025, so the first reports were lodged during 2026, not 2025.

Has India adopted the ISSB standards? No. India has a mandatory reporting regime in the BRSR and a live carbon market, but has not formally adopted IFRS S1 and S2.

Which standard should an Indian company build towards? The ISSB baseline, because it is where the largest number of jurisdictions is converging and where the European standards are heading, with BRSR Core specifics added for Indian filing.