CEO Brief

Compliance-Led ESG Reporting - A Global Perspective.

Executive Headline

We have analysed 20 jurisdictions covering the G20 and major economic blocs. ESG reporting is now mandatory or in phased implementation across every one of them. ISSB is becoming the de facto global baseline. The question is no longer whether disclosure is required - it is whether your reporting infrastructure can serve multiple jurisdictions at once.

Jurisdictions analysed across G20 and major economic blocs

100%

Have mandatory or phased ESG reporting in force or adopted

Reference ISSB standards - the emerging global baseline

Reference TCFD - foundation for most climate disclosure

2025-26

Peak activation year - most phased regimes enter force

The Shift - What Is Changing

ESG disclosure has crossed a threshold. Every jurisdiction in our analysis - from the EU to India to California - now has a mandatory or formally adopted ESG reporting regime. The era of voluntary disclosure is over as a sufficient response. What is emerging in its place is a compliance-led global reporting environment where the underlying frameworks are converging on ISSB, the assurance expectations are rising, and the cost of maintaining separate reporting stacks for each jurisdiction is becoming unsustainable.

Why It Matters - Business Impact

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No safe harbour remains

Every G20 jurisdiction now has ESG reporting obligations. Multinationals operating across the EU, US, UK, Australia, Japan, and India face overlapping requirements that cannot be managed as separate compliance projects without significant duplication.

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ISSB is winning

13 of 20 jurisdictions reference ISSB standards. Australia, Canada, Japan, South Africa, Singapore, and the UK are all adopting ISSB-aligned frameworks. Companies that build to ISSB S1 and S2 will cover the majority of their global compliance requirements from a single baseline.

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2025-2026 is the activation window

The majority of phased regimes - Australia, Canada, US, California, Korea, China - move into first reporting cycles in 2025 and 2026. For multinationals, this is not a future planning item. The data collection and assurance infrastructure needs to exist now.

Business Exposure

Type	Exposure
Risk	Multinationals with EU, US, UK, and Asia-Pacific operations face 4 to 6 overlapping disclosure regimes simultaneously by 2026. Managing these independently creates duplication of effort, inconsistent data definitions, and gaps that surface under assurance.
Risk	CSRD sets the most demanding standard globally on scope and assurance. EU-listed or EU-operating companies that build to CSRD will substantially satisfy other jurisdictions. Companies that build to lesser standards and then attempt to layer CSRD on top face a far more complex rebuild.
Opportunity	Building to ISSB S1 and S2 as the global baseline - with CSRD-compliant ESRS as the EU layer - gives multinationals a single data architecture that serves the majority of their global reporting obligations. This is the most capital-efficient compliance path available.
Opportunity	Companies with credible, assured global ESG disclosures gain access to sustainability-linked capital markets and preferred supplier status in jurisdictions where procurement increasingly requires Scope 3 data from suppliers.

Leadership Lens

›Have we mapped every jurisdiction we operate in against the 20 reporting regimes in this analysis - and identified which apply to our entities?
›Is our ESG reporting infrastructure built on ISSB as the global baseline, or are we maintaining separate data stacks per jurisdiction?
›For our US and Asia-Pacific entities, are 2025-2026 first reporting cycles funded and resourced - or still being treated as future planning items?
›Does our Scope 3 data quality meet the supplier disclosure expectations of our largest customers in EU and UK regulated markets?

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Key Takeaway

The global ESG reporting landscape has converged faster than most companies planned for. ISSB is the emerging spine. CSRD is the most demanding layer. Companies that build once to the highest applicable standard - and use that infrastructure globally - will spend less and disclose more than those managing each jurisdiction separately.

↑ Back to summary

Section 1 The Global Landscape - Status by Jurisdiction

In force now

Adopted / phased in

Existing environmental reporting only

Gold ring = sub-national

Section 2 Framework Convergence - ISSB Is the Emerging Spine

ISSB S1 / S2

13 / 20

TCFD

12 / 20

GRI

8 / 20

ESRS

1 / 20

ISSB as global baseline

Australia, Canada, Japan, South Africa, Singapore, UK, Nigeria, and others are all adopting ISSB-aligned local standards. Building to ISSB S1 and S2 covers the majority of climate disclosure requirements globally from a single data architecture.

TCFD as the foundation

TCFD underpins most climate-specific disclosure requirements. It is now embedded in ISSB S2, ESRS E1, and numerous national frameworks. TCFD alignment is effectively a prerequisite for any climate disclosure regime, not a voluntary add-on.

GRI for social and governance

GRI remains widely referenced for social and governance disclosures, particularly where ISSB S1 broader sustainability topics are in scope. Eight jurisdictions reference GRI alongside ISSB or TCFD.

ESRS as EU-specific layer

ESRS is mandatory for CSRD-in-scope entities only. Outside the EU, it is referenced for interoperability mapping. Companies that build to ESRS will find ISSB coverage largely included - but the reverse is not true.

Section 3 Full Jurisdiction Register

Jurisdiction	Regulation	Status	First Year	Framework	Notes
European Union	CSRD / ESRS	In force	FY 2024 Wave 1	ESRS; ISSB mapping	Most demanding global standard on scope and assurance. Three waves through FY2026.
United Kingdom	SDR / TCFD	In force	FY 2022-23	ISSB-aligned; TCFD	FCA Sustainability Disclosure Requirements. ISSB adoption underway via UK SRS.
India	BRSR	In force	FY 2022-23	GRI; ISSB mapping	SEBI mandated for listed companies. BRSR Core with assurance for top 150 companies.
South Africa	JSE sustainability reporting	In force	Pre-2024	ISSB; GRI; TCFD	King IV governance framework underpins disclosure. ISSB S1 and S2 adoption expected.
Indonesia	OJK sustainability reporting	In force	Pre-2024	GRI; local standards	OJK Regulation 51 on sustainable finance reporting.
Brazil	CVM sustainability reporting	In force	Pre-2024	GRI; TCFD	B3 exchange ESG reporting and CVM Instrução 480 disclosure requirements.
Argentina	CNV ESG disclosure	In force	Pre-2024	GRI; TCFD	Securities regulator disclosure rules for listed entities.
Mexico	CNBV / BMV sustainability	In force	Pre-2024	GRI; TCFD	BMV exchange and CNBV regulator requirements. TCFD-referenced disclosures.
Saudi Arabia	CMA / Tadawul ESG	In force	Current	GRI; ISSB piloting	Tadawul ESG disclosure guidelines. Vision 2030 sustainability agenda driving adoption.
Russia	ESG disclosure framework	In force	Pre-2024	Local framework	Ministry of Economic Development ESG guidelines. Diverging from ISSB post-2022.
Turkey	CMB sustainability reporting	In force	FY 2022-23	GRI; TCFD	Capital Markets Board requirements for listed companies. ISSB adoption under review.
Australia	ASRS / AASB climate reporting	Phased in	FY 2025-26	ISSB S1 & S2; AASB	ASRS 1 and 2 are ISSB-aligned. Mandatory for large listed entities from FY2025-26.
Japan	SSBJ sustainability standards	Phased in	FY 2023-24	ISSB S1 & S2; TCFD	SSBJ issued ISSB-aligned standards. Prime Market listed companies reporting from FY2023.
China	CSDS (CSDSD)	Phased in	FY 2025	Local framework; ISSB reference	CSRC and SSE/SZSE sustainability disclosure standards. ISSB-informed but China-specific.
South Korea	K-ESG / sustainability regime	Phased in	FY 2025-26	ISSB-aligned; GRI	FSC mandatory disclosure roadmap. Large caps first from 2025, all KOSPI from 2030.
Canada	CSA climate disclosure	Phased in	~FY 2025	ISSB S1 & S2; TCFD	CSA proposed national instrument. ISSB-based. Provinces implementing independently.
United States (federal)	SEC climate disclosure rules	Phased in	FY 2025 large filers	TCFD; ISSB reference	SEC rules scaled back post-legal challenges. Scope 3 removed. Materiality-based.
California	SB 253 / SB 261	Phased in	FY 2026	GHG Protocol; TCFD	SB 253 requires Scope 1-3 GHG reporting for $1B+ revenue companies doing business in California.
New York	NY GHG Reporting Rule	Phased in	~FY 2025	GHG Protocol	Part 253 facility-level GHG reporting. Expanding scope under Climate Act.
Texas	Environmental reporting	In force	Existing	EPA / state framework	No unified ESG mandate. Environmental reporting through EPA and TCEQ. Diverges from ESG trend.

Section 4 Foresight - What Changes

Now	EU Wave 1 companies are reporting under CSRD. India, South Africa, Brazil, and several G20 markets already have established reporting regimes. Japan's SSBJ standards are producing first ISSB-aligned reports. The compliance baseline is set - the question is quality, assurance, and integration.
12 months	Australia, Canada, South Korea, China, California, and New York all enter first formal reporting cycles in FY2025-26. The SEC climate rules, though scaled back, apply to large accelerated filers. CSRD extends to Wave 2 mid-size companies. The volume of companies in scope globally more than doubles.
3 to 5 years	ISSB-aligned frameworks will be operational in the majority of G20 jurisdictions. Cross-border data comparability will improve as ISSB becomes the common language. Assurance expectations will tighten globally following the CSRD limited assurance model. Companies that have not built audit-ready ESG data infrastructure will face simultaneous pressure across multiple jurisdictions.

Section 5 Inaction - Consequences

Companies that continue to treat ESG reporting as a voluntary or jurisdiction-by-jurisdiction exercise will find the cost of remediation growing as the number of active regimes multiplies. The window for building shared infrastructure - one data model serving ISSB, CSRD, and national adaptations simultaneously - is open now. Multinationals that miss this window will rebuild separately for each jurisdiction under time pressure and at significantly higher cost. The assurance expectations embedded in CSRD will increasingly migrate to other jurisdictions. Companies without audit-ready ESG data will face qualified opinions in multiple markets simultaneously.

Section 6 Board & Leadership Actions

Horizon	Action
Now	Map every jurisdiction in your operating and listing footprint against the 20 regimes in this analysis. Identify which apply to which entities, which have 2025-2026 first reporting dates, and which share data requirements that can be served from a single source.
Now	Confirm that your ESG data architecture is being built to ISSB S1 and S2 as the global baseline. Where CSRD also applies, confirm the ESRS layer is mapped onto the ISSB foundation - not managed as a separate workstream.
6 months	For US entities: assess SEC climate rule applicability and California SB 253 scope. SB 253 requires Scope 1-3 reporting for all companies with over USD 1 billion in revenue doing business in California - regardless of where they are headquartered or listed.
6 months	For Asia-Pacific entities: initiate ISSB S1 and S2 gap assessment against current disclosure practices in Japan, Australia, and South Korea. First reporting cycles are live or imminent. Data collection needs to be running now.
12 months	Commission a global assurance readiness review. CSRD limited assurance is the most developed model globally - but the expectation of third-party verification is spreading. Companies with audit-trail-capable ESG data systems across all jurisdictions will have a structural advantage as assurance becomes the norm rather than the exception.

Sources

Aurie's Knowledge Hub ESG Reporting Regulation Global analysis. IFRS Foundation ISSB adoption tracker. EFRAG ESRS technical guidance. SEC climate disclosure rules (2024). ASIC / AASB ASRS 1 and 2 standards. FSA Japan SSBJ standards. SEBI BRSR Core framework. California SB 253 and SB 261 statutory text. CSA proposed national instrument 51-107. FSC South Korea sustainability disclosure roadmap. CSRC / SSE / SZSE CSDS framework. FCA SDR policy statement. All status and framework references current as of mid-2026.