ESG reporting compliance in 2025: A global guide
Which ESG reporting regulations does your company have to comply with this year? Read CSO Futures’ comprehensive global guide to find your way through the sustainability reporting maze in 2025.
ESG disclosures are a source of headache for many Chief Sustainability Officers and their teams. CSO Futures’ goal is to support the sustainability community, so we have scanned global regulatory news to offer this comprehensive guide of recent, new and upcoming disclosure requirements – along with the who, what, how and when of each regulation.
Note that this guidance does not include mandatory greenhouse gas reporting that has been in place for several years for industrial facilities and heavy emitters (such as the EPA and California’s GHG reporting programmes and the EU Emissions Trading Scheme).
We’ve organised the following by jurisdiction and in alphabetical order.
Australia
2025 is the first year of implementation of Australia’s mandatory sustainability disclosures, with the first reports due in 2026.
Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024
The law was passed in September 2024, effectively amending the Corporations Act 2001 (Cth) and the Australian Securities and Investments Commission (ASIC) Act 2001 to mandate sustainability disclosures among large Australian companies.
Who has to comply this year
The first group having to start collecting sustainability data for reporting this year is comprised of entities meeting at least two of three criteria:
- Consolidated revenue of A$500 million or more
- Consolidated gross assets of A$1 billion or more
- 500 employees or more
What to report
The regulation’s main requirement is the disclosure of a ‘climate statement’ which includes
- material climate-related financial risks and opportunities;
- climate-related metrics and targets for the financial year, including Scope 1 and 2 greenhouse gas emissions (Scope 3 disclosures will become mandatory in the second reporting year)
- any information about the entity’s governance, strategy, or risk management in relation to these risks, opportunities, metrics and targets.
How to report
Reports must be prepared according to the Australian Accounting Standards Board (AASB) S1 and S2 standards, and submitted to ASIC along with the entity’s financial report and directors report, as part of the annual reports.
2025 ASIC sustainability disclosure deadlines
No report due in 2025. The first reports for the 2025 period will have to be submitted by 31 March 2026.
European Union
Corporate Sustainability Reporting Directive (CSRD)
The European Union’s flagship sustainability reporting directive came into force on January 1 2023, with the very first reports due this year.
Who has to comply this year?
The approximately 11,000 companies that were subject to CSRD’s predecessor, the Non-Financial Reporting Directive (NFRD) – namely large listed companies, banks and insurance companies ('public interest entities') with more than 500 employees – started applying the new rules in 2024, and are due to publish their first CSRD reports in 2025.
This year, CSRD will also start to apply to large enterprises that meet any two of the following criteria:
- 250+ employees
- €50+ million in net turnover
- €25+ million in assets
These will have to collect data for reporting across the year 2025, in order to produce their first reports in 2026.
For more information, see the European Commission’s Frequently Asked Questions on the implementation of CSRD.
What to report
CSRD reporting requirements are comprehensive, and include a double materiality assessment, any environmental, social and governance-related strategies and risks, KPIs and targets set by companies, disclosures on sustainability governance and due diligence, as well as the way companies manage their climate and ESG risks.
For more information on how this applies to you, see the CSRD legislation.
How to report
All CSRD reports must be produced according to the European Sustainability Reporting Standards (ESRS), with sustainability information to be externally assured and integrated into annual financial reports.
2025 CSRD reporting deadlines
31 March 2025
Companies should refer to their country’s implementing legislation for specific requirements and reporting deadlines. As of December 20, 2024, 18 EU member states have already transposed CSRD into national law, eight have introduced legislation that has yet to be approved, and four are yet to start consultations (see Rope & Gray’s monthly CSRD transposition tracker).
Penalties for non-compliance
Penalties vary from member state to member state: in France for example, corporate directors could be forced to pay up to €75,000 and go to jail for up to five years if they do not present the information necessary for external auditors to certify their CSRD-aligned reports, or if they obstruct their work in any way.
Carbon Border Adjustment Mechanism (CBAM)
This is the last transitional year for the EU’s Carbon Border Adjustment Mechanism, which aims to level the playing field between European producers subjected to its carbon tax (known as the EU Emissions Trading Scheme or ETS) and non-EU exporters.
Since last year, companies under CBAM’s scope have been required to report on the embedded emissions on their non-EU imported goods. From January 2026, they will have to pay a carbon tax on these emissions, aligned with the EU ETS price.
Who has to comply this year?
European importers of electricity, iron and steel, cement, aluminium, fertilisers and hydrogen products from non-EU countries, including the UK.
What to report
Quarterly CBAM reports must include:
• the total quantity of each type of CBAM good;
• the actual total embedded emissions;
• the total indirect emissions;
• the carbon price due in a country of origin for the embedded emissions in the imported goods (including its relevant precursors where applicable), taking into account any rebate or other form of compensation available.
More information about what to report and how to collect the relevant data from supply chains is available in this CSO Futures deep dive on CBAM.
How to report
Registered importers can submit their reports on the CBAM Transitional Registry, which also offers a manual and templates for submissions.
2025 CBAM reporting deadlines
31 January 2025 (for Q4 2024)
30 April 2025 (for Q1 2025)
31 July 2025 (for Q2 2025)
31 October 2025 (for Q3 2025)
Penalties for non-compliance
Penalties range from €10 to €50 per tonne of unreported emissions.
EU Deforestation Regulation
The EU’s Deforestation Regulation (EUDR) was postponed by one year at the end of 2024, bringing the implementation deadline to December 31, 2025.
Who has to comply this year
Large and medium companies selling palm oil, cattle, soy, coffee, cocoa, timber, rubber, and products derived from these commodities on the EU market (such as beef, furniture, or chocolate) – including commodity traders, wholesalers, supermarkets and retail chains.
What to report
Companies in scope must demonstrate that they have implemented a due diligence system to collect information from suppliers and assess and mitigate deforestation risks in their supply chains.
How to report
Companies have to submit due diligence statements through the deforestation registry created by the European Commission.
2025 EU Deforestation Regulation Deadline
31 December 2025
Hong Kong
The Hong Kong Institute of Certified Public Accountants (HKICPA) issued the final Hong Kong sustainability disclosure standards, fully aligned with the ISSB standards, in December 2024. As of January 1, 2025, main board issuers on the Hong Kong Stock Exchange are expected to disclose against these requirements on a “comply or explain” basis.
Who has to comply this year
Main board issuers on the Hong Kong Stock Exchange (HKEX).
What to report
Reporting requirements under HKFRS S1 and HKFRS S2 are fully aligned with the International Sustainability Standard Board’s (ISSB) IFRS S1 and IFRS S2 standards on sustainability-related and climate-related financial disclosures respectively.
How to report
Companies are expected to publish their sustainability disclosures alongside financial statements and for the same reporting periods. See HKFRS S1 and HKFRS S1 manuals for further details.
2025 HKEX sustainability reporting deadlines
From 1 January 2025. Reports to be published at the same time as financial statements.
Mexico
The Latin American country introduced mandatory sustainability reporting requirements in 2024, which come into effect in 2025.
The regulation is called ‘Normas de Información de Sostenibilidad’ or sustainability reporting standard, and goes from being voluntary to being mandatory this year.
Who has to comply this year
The law applies to all private companies that publish financial statements under Mexico’s financial reporting standards (but not those listed on the stock exchange).
What to report
Disclosures include 30 different metrics across environmental, social and governance topis, such as:
- Scope 1 and 2 emissions (Scope 3 from 2026)
- Energy consumption, including renewable energy
- Water consumption
- Waste generation
- Gender representation on boards.
How to report
Companies are expected to include sustainability disclosures in the footnotes of their financial statements.
2025 Mexico sustainability reporting deadlines
From 1 January 2025. Reports to be published at the same time as financial statements.
Singapore
The Accounting and Corporate Regulatory Authority (ACRA) of Singapore approved new mandatory sustainability disclosure requirements for companies listed on the Singapore Stock Exchange (SGX) in early 2024.
Who has to comply this year
All SGX-listed issuers. (Large non-listed companies will also have to report, but from 2027.)
What to report
Listed companies must report Scope 1 and 2 emissions in line with the ISSB’s IFRS S2 standard this year. Scope 3 reporting will become mandatory next year.
How to report
Reports must be submitted to ACRA along with financial statements.
2025 Singapore sustainability reporting deadlines
From 1 January 2025. Reports to be published at the same time as financial statements.
Switzerland
Switzerland’s Ordinance on Climate Disclosures has been mandating companies to disclose TCFD-aligned climate related risks since 2024.
Who has to comply this year
Public companies, banks, and insurance companies with at least 500 employees and at least CHF 20 million in total assets, or more than CHF 40 million in turnover.
What to report
Disclosures should be aligned with the recommendations of the Taskforce on Climate-Related Financial Disclosures (TCFD) and include climate-related governance, strategy, risk management and metrics and targets. Companies should also disclose a climate transition plan aligned with Swiss climate goals.
The Federal Council recently launched a consultation to align the ordinance to European sustainability reporting regulations, so new reporting requirements are expected to be implemented from 2026.
How to report
Reports must be published on companies’ websites in a machine-readable format, once a year.
United States
SEC climate disclosure rule
With President Trump taking office on January 21 and a new Securities and Exchange Commission chair vocally opposed to climate disclosures, it’s unlikely that wide-ranging mandatory ESG reporting will be implemented at the federal level over the next four years.
However, US companies that do business in the EU need to start preparing to comply with CSRD requirements, which will start applying to them from 2026.
California Voluntary Carbon Market Disclosures (AB 1305)
This new law adopted in 2023 requires companies that market, sell and/or purchase carbon offsets from the voluntary carbon market to disclose these transactions, with the first reports due this year.
Who has to comply this year
- All entities that market or sell voluntary carbon offsets in California (both public and private, domestic and foreign companies)
- Organisations operating in California that purchase offsets on the voluntary carbon market and make climate claims based on those offsets (such as ‘net zero’ or ‘carbon-neutral’)
- Organisations operating in California that make climate-related emissions claims, even if they do not purchase carbon offsets
What to report
Reporting requirements depend on the type of organisation listed above.
The first category (those who sell or market carbon offsets) have to disclose the location, name and durability of the projects issuing the carbon offsets sold; whether they use independent third-party verification; and any other details around accountability measures used to verify the carbon credits.
The second category (those who make claims based on their offset purchases) have to disclose the name of the carbon offset seller, the carbon credit registry or programme, project ID number, offset project type and other details, as well as the methodology used to estimate emissions reductions/removal benefits, and whether independent third-party verification is included.
The third category (organisations that make climate-related claims) have to disclose information on the method used to substantiate their claims and whether those claims have been verified by an independent third party.
How to report
All the required information has to be posted on the reporting company’s website.
2025 AB 1305 reporting deadlines
1 January 2025
Penalties for non-compliance
Fines of up to US$2,500 a day per violation, not to exceed US$500,000. More information is available in the legislation text.
Preparing for 2026
Many jurisdictions recently passed mandatory sustainability disclosure requirements for companies, which are due to be implemented in 2026 – so companies in these jurisdictions would do well to use 2025 to prepare for compliance.
They include several ISSB-aligned requirements for public (and sometimes private) companies such as:
- Brazil’s CVM Resolution 193
- Canada’s CSDS 1 and 2, which are likely to be made mandatory over the course of this year
- California’s SB 219
- China’s mandatory sustainability disclosures trial (for companies in the SSE 180 Index, Shenzhen Stock Exchange 100 Index and GEM Index as well as those listed simultaneously in Chinese and foreign stock exchanges)
- India’s Disclosure framework on climate-related financial risks, (draft introduced in 2024)
- Japan’s Sustainability Disclosure Standards
- The UK’s Sustainability Reporting Standards (currently in consultation)
Member discussion