Mainland China Publishes Draft Guidelines for Mandatory Sustainability Reporting

Stock Exchange
Type of Disclosure
Applicability
Timeline
Disclosure Requirements
Core Pillars
Shanghai Stock Exchange (SSE)
Combination of mandatory and voluntary disclosure
Mandatory: SSE 180 Index, STAR 50 Index, and dual-listed companies

Voluntary: Other listed companies
Publication of 2025 Sustainability Report before April 30, 2026
Environmental
1. Climate change
2. Pollution prevention and ecosystem protection
3. Resource utilization and circular economy

Social
1. Rural revitalization and social contribution
2. Innovation drive, suppliers, and customers
3. Employee management

Governance
1. Sustainable development-related governance mechanisms
2. Anti-bribery and unfair competition
The guidelines are centered around four pillars:
1. Governance
2. Strategy
3. Risk management
4. Metrics and targets
Shenzhen Stock Exchange (SZSE)
Mandatory: SZSE 100 Index, GEM Index, and dual-listed companies

Voluntary: Other listed companies
Beijing Stock Exchange (BSE)
Voluntary disclosure
Voluntary: Listed companies
Effective from the guideline issuance date

The ESG report disclosure rate of A-share listed companies has been increasing year by year. According to the Economic Daily, by the end of 2023, the 2022 ESG report disclosure rate of SSE-listed companies had reached 47%. However, despite the high disclosure rate, the lack of unified ESG disclosure standards resulted in disclosure incomparability across companies.

On February 8, 2024, in a landmark move, the three major stock markets in China – SSE, SZSE, and BSE – successively issued guidelines for sustainability reporting. With this announcement, it is expected that the overall quality and comparability of ESG information disclosure by A-share listed companies will improve significantly.

According to the new guidelines, information disclosure will include a combination of mandatory and voluntary disclosures. As of now, around 450 listed companies, accounting for 51% of the total market value of A-shares, will be included in the scope of mandatory reporting.

The companies subjected to mandatory disclosure will need to publish their FY2025 ESG report before April 30, 2026.

Notably, the guidelines require companies to adopt a double materiality approach to sustainability reporting, which includes reporting on both the financial impact of sustainability issues on the company, and the company’s impact on the environment and society. The requirement is distinctively aligned with the EU’s latest regulation (Corporate Sustainability Reporting Directive).

The overall disclosure framework of the guidelines is centered around the four core contents of ‘governance, strategy, risk management, and metrics and targets,’ which are consistent with the TCFD (Task Force on Climate-related Financial Disclosures) framework as well as ISSB (International Sustainability Standards Board) standards. Although the guidelines do not clearly state whether they are based on these international frameworks or others, we expect to see a certain level of alignment of the local ESG Disclosure requirements with the International Frameworks & Guidance.

Despite the high level of ESG disclosure by the listed companies, we expect these requirements to put a lot of pressure on them, with different levels of financial implications for companies that have not established effective sustainability management practices.

Contributors

Yulia Khisamova

Yulia Khisamova

Senior Consultant

Rachel Tang

Rachel Tang

Consultant

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