The China Securities Regulatory Commission (CSRC) has made a unified deployment, and these listed companies must publish ESG reports

Under the unified deployment of the China Securities Regulatory Commission, the Shanghai and Shenzhen North Stock Exchanges respectively issued a report on the "Sustainability Reporting Guidelines" (hereinafter referred to as the "Sustainability Reporting Guidelines" on February 8.guidelinesListed companies that are required to disclose their Sustainability Reports should publish their 2025 Sustainability Reports by April 30, 2026.

The Sustainability Disclosure Guidelines, also known as:ESGThe report adopts a combination of mandatory disclosure and voluntary disclosure, establishes a sustainable development information disclosure framework for listed companies, strengthens carbon emissions-related disclosure requirements, and clarifies environmental, social and corporate governance disclosure topics.

Industry insiders accept theBrokerage ChinaAccording to the "Sustainable Development Information Disclosure Guidelines", it is intended to practice "green finance", one of the five major articles of financial power, urge listed companies to better implement the new development concept while pursuing profits, and guide listed companies to more comprehensively reveal the results of improving sustainable development capabilities, which will help outstanding listed companies that attach importance to sustainable development stand out.

A combination of mandatory and voluntary, with a clear scope of disclosure

The rules are set to fully consider the development stage and disclosure capabilities of listed companies, and promote the speed of sustainable information disclosure in a rhythmic, step-by-step and differentiated manner through a combination of mandatory and voluntary disclosure.

In terms of disclosure entities, the SSE has clarified that companies that continue to be included in the sample of the SSE 180 and STAR 50 Index, as well as companies listed at home and abroad at the same time, should disclose the Sustainability Report, and encourage other listed companies to do so voluntarily. In terms of disclosure topics, disclosure requirements are set for different topics according to the levels of mandatory disclosure, non-disclosure is interpretation, guided disclosure and encouraged disclosure.

The Shenzhen Stock Exchange has clarified that companies that continue to be included in the SZSE 100 and ChiNext index samples during the reporting period, as well as companies listed at home and abroad, should disclose their Sustainability Reports, and encourage other listed companies to do so voluntarily. The Sustainability Report shall be disclosed at the same time as the annual report after being deliberated and approved by the Board of Directors, and the subject and period of the report shall be consistent with the annual report.

At the same time, the Shenzhen Stock Exchange requires listed companies to identify whether each issue has a significant impact on the value of the enterprise (financial materiality) and whether the performance of the enterprise on the corresponding issue will have a significant impact on the economy, society and environment (impact materiality) in the topics set out in the Sustainability Report, taking into account the characteristics of the industry and business in which it operates, and explain the process of analyzing the materiality of the issues.

The Beijing Stock Exchange, taking into account the characteristics of the development stage of innovative small and medium-sized enterprises, does not make mandatory disclosure provisions for the "Sustainability Report", and encourages companies to "do what they can". In addition, mitigation measures are in place to balance information quality and cost control.

Statistics show that since 2023, a total of about 1,700 listed companies have disclosed sustainability-related reports, a new high, and 3,161 companies have disclosed the measures they have taken to reduce carbon emissions and their effects, accounting for more than 60% of all listed companies. According to the Organisation for Economic Co-operation and Development (OECD)OECDAccording to statistics, this proportion is at the leading level in the world's major capital markets. In particular, 648 listed companies have disclosed their carbon emissions to varying degrees, of which nearly 500 have disclosed their Scope 1 and Scope 2 carbon emissions in detail, taking a key step from qualitative to quantitative disclosure.

Establish a sustainability information disclosure framework for listed companies

Industry insiders said that sustainable development is a common issue facing the world, but the level of development and resource endowment of countries vary greatly, and the priorities of various countries are different. From the perspective of relevant international rules, the current focus is generally on issues such as climate change and biodiversity. In the early stage of China's sustainable development disclosure, it focused on environmental pollution, poverty alleviation, rural revitalization and other issues that better reflect China's national conditions. In recent years, the issue of carbon reduction has been added, reflecting domestic concerns about the above issues. In the process of establishing sustainable development disclosure rules, it is necessary to take into account both commonality and individuality, and to look at both international consensus and what domestic concerns are, so as to form a plan that can strive for greater consensus on the basis of China's national conditions.

The sustainability issues disclosed by the SSE are both financially and impact-significant. According to the Sustainability Disclosure Guidelines, listed companies should analyze and disclose the topics to be disclosed around the four core contents of governance, strategy, impact, risk and opportunity management, indicators and targets, so that investors and stakeholders can fully understand the actions taken by listed companies to address and manage sustainability-related impacts, risks and opportunities.

In addition, the Shanghai and Shenzhen Stock Exchanges have also strengthened the disclosure requirements related to carbon emissions, and listed companies should further disclose matters such as climate adaptation, transformation plans, total greenhouse gas emissions, emission reduction measures, and carbon emissions-related opportunities in addition to disclosing relevant governance and strategies for climate change in accordance with the four core contents.

Tian Lihui, dean of the Institute of Financial Development of Nankai University, said that the comprehensive reform of the registration system has been rolled out in the whole market, and the information disclosure as the core of the registration system is becoming more and more important.

Clarify environmental, social, and corporate governance disclosure issues

The Sustainability Disclosure Guidelines also clarify environmental, social, and corporate governance disclosure issues.

In the chapter on environmental information disclosure, the Shanghai and Shenzhen Stock Exchanges have set up important topics such as ecosystems and biodiversity, circular economy, etc., and put forward disclosure requirements for important environmental issues such as climate change and pollution prevention. According to the requirements, in addition to disclosing climate change-related governance, strategies, impacts, risk and opportunity management, indicators and targets, etc., listed companies should further disclose matters such as climate adaptation, transition plans, total greenhouse gas emissions, emission reduction measures, and carbon emissions-related opportunities.

In addition to addressing climate change issues, the environmental information disclosure section also sets up topics such as pollutants, wastes, ecosystems and biodiversity, environmental incidents and penalties, etc., and listed companies should disclose relevant information in accordance with the provisions of the Guidelines for Sustainable Development Information Disclosure based on whether they are environmental information disclosure enterprises or the significant impact of their production and operation on the environment.

In the chapter on social information disclosure, the exchange has set up a number of important topics such as rural revitalization, innovation-driven, science and technology ethics, supply chain security, and equal treatment of small and medium-sized enterprises. It also requires listed companies to disclose the impacts, risks and opportunities involved in the relevant issues, the specific measures taken by the company, and the specific results achieved in accordance with the Sustainability Information Disclosure Guidelines.

In the chapter on corporate governance information disclosure, the Exchange further puts forward practical and disclosure requirements for sustainable development governance, clarifying that listed companies should actively integrate sustainable development concepts and specific measures into various systems and processes of corporate governance, further improve and improve corporate governance mechanisms, and disclose corporate governance structures, internal systems, control measures and procedures established in accordance with different issues and importances. In addition, information related to anti-corruption, anti-bribery, and anti-unfair competition shall also be disclosed.

The establishment of ESG system indicators should not ignore the value of globalization and international standards, but also consider the actual situation and capabilities of China's listed companies. "Enterprises should do what they can to disclose ESG information, and they should not neglect their main business for the sake of rating. Tian Lihui said.

The transitional arrangements and mitigation measures are clear

According to the transitional arrangement, listed companies that require mandatory disclosure on the Shanghai and Shenzhen Stock Exchanges should publish their 2025 Sustainability Reports by 30 April 2026. In the first reporting period, listed companies are not required to disclose the year-on-year changes in relevant indicators, and can make qualitative disclosures and explain the reasons for indicators that are difficult to disclose quantitatively, and in the 2025 and 2026 reporting periods, if it is difficult for the disclosing entity to quantitatively disclose the impact of sustainability-related risks and opportunities on the current financial position, it can only make qualitative disclosures.

The Shanghai and Shenzhen Stock Exchanges said that they will continue to enrich and improve the sustainable development rule system, product system and service system in accordance with the unified deployment of the China Securities Regulatory Commission, and promote the formation of a high-quality green and sustainable financial market ecology. The Beijing Stock Exchange also made it clear that it will give full play to the market function of the "main position", deepen the concept of sustainable development, accelerate the improvement of market construction results, promote innovative small and medium-sized enterprises to thoroughly implement the new development concept, actively green transformation, and actively contribute to the construction of a new development pattern and high-quality development.