Global ESG Disclosures Timeline

NOAM

Disclosure

Who it affects

When

(US)
Cali AB 1305

CA businesses claiming net zero, carbon neutrality, or major GHG cuts via voluntary offsets, and companies selling or marketing such offsets in CA

Date for the first disclosure is January 1, 2025, then updated annually

(US)
Cali SB 261*
climate-related financial risk report

Companies with > $500M in revenue doing business in CATCFD aligned climate-related financial risk   

Report: Jan 1st, 2026 (reporting on FY 2025)

(US)
SEC
SRCs - S1 & 2, Gov, Risk - AF/NAFs - S3 Disclosure & S1 & 2 (Ltd Assurance)

SRC - Smaller Reporting Company 
AF/NAF - Accelerated/Non-Accelerated Filer

SRCs: 2026 – Scopes 1 & 2, Gov, Risk (reporting on FY 2025)
AFs/NAFs - Scope 3 + Ltd Assur (Scopes 1&2) (reporting on FY 2025)

(MEXICO)
IFRS - First Report

Issuers listed on Mexican stock markets

First report: 2026 (reporting on FY 2025)

(CANADA)
CSDS 1 & 2

Voluntary, public are expected and large private are highly encouraged.Companies are encouraged to report on governance, strategy, risk management, and metrics for sustainability (CSDS 1) and climate-related risks and GHG emissions (Scope 1, 2 & 3) (CSDS 2).

In place Dec. 2024 - Voluntary, due annually with financial reporting

(MEXICO)
NIS B-1 & NIS A-1

Entities that prepare their financial statements in accordance with Mexican GAAP

For issuers: first mandatory report due in 2026 ((reporting on FY 2025), For private companies: Disclosure of Scope 3 (IBSO 3) and sustainable investment (IBSO 6)

(US)
Cali SB 253 Scope 1 & 2

Companies with > $1B revenue doing business in CA

Scope 1 & 2: 2026 (reporting on FY 2025)

(CANADA)
B-15 Scope 1 & 2

Small FRFIs

Federally regulated financial institutions

Scope 1, 2, climate-related risks: Smaller FRFIs ≤180 days of 2025 fiscal year end

MEA

(UAE)
ADX Guidance

1- ADX-listed companies: Required to issue detailed ESG reports.
2- Public Joint Stock Companies: Under SCA rules, all PJSCs listed on ADX must publish a sustainability report.

Released 2025 - technically voluntary but highly expectedAnnual reports must be filed within 90 days of the financial year-end

(SAUDI ARABIA)
CMA Guidelines approval

Issuers of debt instruments (domestic and foreign issuers issuing into the Saudi market) that want to label instruments as green, social, sustainable or sustainability-linked

Approved mid 2025, CMA's first effort in the transition from voluntary to mandatory ESG disclosures for listed companies

(UAE)
Climate Law

All entities in UAE (public and private, incl. free zones)

Deadline May 30, 2026* Fines of AED 50,000 - 2M for non-compliance after May 30, 2026

EU

(EU)
EU Taxonomy Wave 1

CSRD-reporting companies + financial market players

Fully adopted for Wave 1 companies (those formerly under NFRD) - 2026 (reporting on FY 2025)

(UK)
SDR

1. Firms managing retail investment products
2. UK UCITS Management Companies, UK AIFMs, and UK MiFID firms
3. Distributors like platforms and financial advisers
*Firms with > £50 bn AUM must provide both Ongoing Disclosures & Sustainability Entity Reports; £5–50 bn AUM only need the latter

Firms £5 bn - £50 bn AUM: Dec. 2nd, 2026

APAC

(HONG KONG)
HKSDS

Listed (HKEX) Companies
Large Cap Issuers

1. Listed companies (HKEX): 2026 (reporting on FY 2025)
2. Large Cap Issuers: 2026 (reporting on FY 2025)

NOAM

Disclosure

Who it affects

When

(US)
ILLINOIS

Entities with >$1B in revenue who do business in the state of Illinois

Phased implementation starting Jan 1st, 2027

(US)
NY CCAA SCOPE 1 & 2

Companies with >$1B in revenue who do business in the state of New York.This means operating a branch office, a loan production office, a representative office, or a bona fide office in NY State

Scope 1 & 2 : 2027 (reporting on FY 2026)

(US)
NY STATE GHG

Large emitters operating in NY state:
-Facilities emitting ≥10,000 MT CO₂e/year- Fuel suppliers
-Waste haulers/transporters emitting ≥10,000 MT CO₂e/year
-Electric power entities
-Agricultural lime and fertilizer suppliers
-Facilities with anaerobic digestion/liquid waste storage generating ≥10,000 MT CO₂/year

2027 (first reports will cover FY 2026 emissions data)Scope 3 reporting requirements are expected to be phased in at a later stage

(US)
SEC
LAFs: S1 & 2 (Reasonable Assurance)

LAFs - Large Accelerated Filers

LAFs - 2027 – Reason Assur (Scopes 1&2) (reporting FY 2026)

(MEXICO)
IFRS - Assurance

Issuers listed on Mexican stock markets

Assurance: 2027 (reporting on FY 2026)

(MEXICO)
NIS B-1 & NIS A-1

Entities that prepare their financial statements in accordance with Mexican GAAP

Limited Assurance: 2027 (reporting on FY 2026)

(US)
Cali SB 253

Scope 3

Companies with > $1B revenue doing business in CA

Scope 3: 2027 (reporting on FY 2026)

MEA

(QATAR)
National Disclosure Framework

Expected reporting for S1&2

All listed companies and some non-listed companies

Scope 1 & Scope 2 (emissions, risks, and opportunities) disclosure is required starting in 2027 and 2028, unclear on exact timelines and phases.

(QATAR)
QCB & QFC Sustainable Finance Framework

Firms operating within the QFC free-zone (including banks, insurers and other authorised firms) and particularly those designated as “Category A” firms (typically higher-impact financial institutions) and any firm designated by the Regulatory Authority

These rules apply to financial years beginning on or after January 1, 2026 + the first mandatory sustainability reports are expected to be published in 2027

EU

(UK)
UK SRS

UK listed companies (especially those already subject to TCFD-aligned reporting requirements)

FY 2027, reports expected in 2028  (Climate-related information (UK SRS S2), one-year transition relief for Scope 3 data and non-climate sustainability topics (UK SRS S1); after, “comply or explain” basis)

APAC

(JAPAN)
Potential SSBJ reporting

Companies listed on the Prime Market of the Tokyo Stock Exchange (TSE) (large market-cap issuers)

FY Mar 2027: ≥ ¥3 T mkt cap

Disclosure

Who it affects

When

NOAM

(US)
NY CCAA Scope 3

Companies with >$1B in revenue who do business in the state of New York. This means operating a branch office, a loan production office, a representative office, or a bona fide office in NY State

2028: Scope 3 (reporting FY2026)

(US)
SEC

AF/NAFs: Reasonable Assurance (S1 & 2)

AF/NAFs - Accelerated/Non-Accelerated Filer (AF/NAF)

2028 – Reasonable Assur (Scopes 1&2) (reporting on FY 2027)

(MEXICO)
IFRS - Reasonable Assurance

Issuers listed on Mexican stock markets

Reasonable assurance: 2028 (reporting on FY 2027)

(MEXICO)
NIS B-1 & NIS A-1

Entities that prepare their financial statements in accordance with Mexican GAAP

Reasonable Assurance: 2028 (reporting on FY 2027)

(CANADA)
B-15: Scope 3

Federally regulated financial institutions

Scope 3: fiscal year 2028

EU

EU Taxonomy

CSRD-reporting companies + financial market players

For non Wave 1 companies, it follows CSRD Wave timelines

(EU)
CSRD - Europe (ESRS)

Listed EU companies with ≥ 500 employees (Wave 1)EU companies (incl. non-EU companies listed in Europe, and EU subsidiaries of non-EU companies) meeting both ≥ 1,000 employees & ≥ €450m turnover

EU: 2028 (reporting on FY 2027) ongoing (simplified ESRS)

APAC

(JAPAN)
Potential SSBJ reporting

Companies listed on the Prime Market of the Tokyo Stock Exchange (TSE) (large market-cap issuers)

FY Mar 2028: ≥ ¥1 T mkt cap

(AUSTRALIA)
ASRS

Meeting 2/3 criteria: 
>100 employees
>$50M Revenue
>$25M assets

2028 (reporting on FY 2027)

Disclosure

Who it affects

When

MEA

(QATAR)
National Disclosure Framework

Expected reporting for Scope 3

All listed companies and some non-listed companies

Scope 3 reporting becomes mandatory from 2029

EU

EU Taxonomy

CSRD-reporting companies + financial market players

For non Wave 1 companies, it follows CSRD Wave timelines

(EU)
CSRD - Non - Europe

Non-EU companies (ultimate parents)
≥ €200 million revenue generated by EU subsidiary/branch
≥ €450 million revenue in the EU
≥ €450m net turnover in the EU

Non-EU: 2029 (reporting on FY 2028) ongoing (simplified ESRS, or equivalent standards or “non-EU ESRS”)

(EU)
CSDDD

Large EU corporations with both
≥ 5,000 employees &
≥ €1.5bn turnover
Non-EU companies above the same turnover threshold in the EU

The due diligence directive will only apply from July 2029 for all businesses within its scope.

APAC

(JAPAN)
Potential SSBJ reporting*

Companies listed on the Prime Market of the Tokyo Stock Exchange (TSE) (large market-cap issuers)

FY Mar 2029: ≥ ¥500 B mkt cap
Others: 2030s onward

(HONG KONG)
HKSDS

Large non-listed financial institutions (banks, insurers, asset managers)

Full adoption for large PAEs: 2029 (reporting on FY 2028)

Disclosure

Who it affects

When

NOAM

(CANADA)
B-15:

Off-balance sheet AUM emissions

Federally regulated financial institutions

Off-balance sheet AUM emissions: fiscal year 2029