A guide to international ESG regulations by jurisdiction

Last updated – 1 February 2022

ESG regulations are government standards for ESG actions or disclosures. While the ESG space is largely unregulated, legal requirements are coming into place in different countries, at different paces.

European Union

Sustainable Finance Disclosure Regulation (SFDR)

EU Taxonomy Regulation Article 8 Delegated Act

In development: Corporate Sustainability Reporting Directive (CSRD)

Regulatory body: European Commission (EC)

United Kingdom

In development: Sustainability Disclosure Requirements (SDR) and Investment Labels

In development: Diversity and Inclusion on Company Boards and Executive Committees

In development: Climate-related Disclosure Requirements

Regulatory body: Financial Conduct Authority (FCA)

United States

In development: Climate Disclosures for Public Companies

Regulatory body: Securities and Exchange Commission (SEC)

In development: Climate-related Financial Risks and Insurers

Regulatory body: US Federal Insurance Office (FIO)

In development: California – Climate Corporate Accountability Act (CCAA)

Regulatory Body: California Secretary of State Office

In development: New York – Fashion Sustainability and Social Accountability Act (FSSAA)

Regulatory body: New York State Department of Law

Australia

Prudential Practice Guidance on Climate Change and Financial Risks

Regulatory body: Australian Prudential Regulation Authority

Brazil

Management and Disclosure of Social, Environmental and Climate Risks

Regulatory body: Central Bank of Brazil (BCB)

In development: Circular on providing for the requirements for sustainability, to be observed by companies, insurance companies, open supplementary pensions (EACPCs) capitalisation companies and local reinsurers.

Regulatory body: Superintendent of Private Insurance (Susep)

Canada

In development: ESG-related Investment Disclosure for Funds

In development: Climate-related Disclosures for Listed Issuers

Regulatory body: Canadian Securities Administrator (CSA)

Chile

Sustainability and Corporate Governance Requirements in Annual Reports

Regulatory body: Financial Market Commission of Chile (CMF)

China

ESG-related Amendments to the Disclosure Rules Applicable to Listed Companies

Regulatory body: China Securities Regulatory Commission

Germany

Supply Chain Act

Regulatory body: Federal Office for Economic Affairs and Export Controls (BAFA)

Hong Kong

In development: Green and Sustainable Finance Strategy (Climate-related Disclosures)

Regulatory body: Hong Kong Securities and Future Commission (SFC), Hong Kong Monetary Authority (HKMA)

Japan

Revisions of Corporate Governance Code

In development: Mandatory TCFD reporting for prime segment listed companies

Regulatory body: Japan Financial Services Agency (FSA)

New Zealand

In development: Mandatory TCFD Reporting

Regulatory body: External Reporting Board New Zealand (XRB)

Singapore

Environmental Risk Management for Asset Managers, Banks and Insurers

Regulatory body: Monetary Authority of Singapore (MAS)

South Korea

In development: Mandatory ESG Report Disclosure

Regulatory body: Financial Services Commission of South Korea (FSC)

Switzerland

Articles 964a-964c, 964j-964l of the Code of Obligations

Regulatory body: Federal Audit Oversight Authority (FAOA)