Enhancing Sustainability Reporting for Listed Companies: Insights from PRC Guidelines by Gilly Hutchinson and Jennifer Wu

China Mandates Sustainability Reporting for listed Companies in Landmark Move

Beijing, China – September 30, 2025 – In a sweeping decision poised to reshape corporate accountability, the Shanghai, Shenzhen, and Beijing stock exchanges have jointly released extensive guidelines for corporate sustainability reporting. The move, finalized with the release of accompanying Compilation Guides on January 17, 2025, and subsequent draft amendments on september 5, 2025, signifies a pivotal moment in China’s commitment to Environmental, social, and Governance (ESG) standards.

New Regulations: A Three-Tiered Approach

The newly established framework mandates detailed disclosures related to sustainability performance for a specific cohort of publicly listed companies. These guidelines are structured around four core pillars: governance, strategy, impact, risk and prospect management, and metrics and targets – mirroring those utilized by the Task force on Climate-related Financial disclosures (TCFD) and the International Sustainability standards Board (ISSB).Significant revisions were recently proposed, supplementing three schedules to broaden the scope of required disclosures.

The application of these guidelines isn’t uniform. Companies continuously included in key indices – the SSE 180, STAR 50, shenzhen 100, or ChiNext Index – alongside those with dual listings in China and abroad, are required to publish sustainability reports. Other listed entities are encouraged to adopt voluntary reporting practices. The beijing Stock Exchange, catering primarily to smaller and medium-sized enterprises, currently adopts a purely voluntary approach to sustainability reporting.

Key Requirements and Materiality Assessments

The guidelines necessitate a thorough analysis of sustainability-related data, encompassing 21 specific topics. Corporations are expected to assess these topics in relation to their industry and operations, including identifying areas beyond the standard list that hold material significance. Companies must adhere to the principle of “double materiality,” considering both financial implications and broader societal and environmental impacts.

Concerning climate-related disclosures, the guidelines align with, yet differ from, ISSB’s IFRS S2. While mandating disclosure of Scope 1 and 2 greenhouse gas (GHG) emissions, the reporting of Scope 3 emissions remains encouraged but not required. Furthermore, scenario analysis for climate adaptation is recommended, rather than mandated, a divergence from the ISSB’s requirements.

Timeline for Implementation

The initial guidelines were enacted on May 1, 2024. Listed companies subject to mandatory disclosures are expected to submit their first reports for the 2025 fiscal year before April 30, 2026.The recent draft amendments to the Compilation Guides, open for public comment until September 19, 2025, indicate an ongoing refinement process to ensure comprehensive and effective reporting standards.

How These Guidelines Compare

Feature	PRC Guidelines	ISSB Standards
Materiality Focus	Double Materiality (Financial & impact)	Primarily Financial Materiality
Scope 3 Emissions	Encouraged Disclosure	Mandatory Disclosure
Scenario Analysis	Recommended	Required
Scope	Broader range of ESG topics	Currently focused on climate-related disclosures

Did You Know? China’s new sustainability reporting framework is designed to complement, not replace, existing voluntary frameworks, creating a layered approach to corporate duty.

pro Tip: Companies preparing for these reporting requirements should begin data collection and establish robust internal controls now to ensure a smooth and compliant reporting process.

The Ministry of Finance and other agencies are also developing the PRC Sustainability disclosure Standards (PRC SDS) modeled after ISSB guidelines, though currently these remain voluntary. The new guidelines share common principles with the PRC SDS, however they cover a broader range of topics than the ISSB standards and PRC SDS which are currently focused on climate-related issues.

The Future of Sustainability Reporting in China

Looking ahead, the exchanges anticipate providing further, more specific guidance on sustainability implementation and expanding the scope of mandatory disclosures. this evolution reflects a growing global trend toward greater corporate transparency and accountability in the face of escalating environmental and social challenges. Increased standardization and a wider adoption of ESG principles are predicted within the next few years, as investor pressure and regulatory oversight continue to intensify.

Frequently Asked Questions about China’s Sustainability Reporting

• What is the primary goal of these new sustainability reporting guidelines? To establish a standardized framework for publicly listed companies in China to disclose their environmental, social, and governance performance.
• Which companies are required to comply with the guidelines? Those included in major indices (SSE 180, STAR 50, Shenzhen 100, ChiNext) and companies dual-listed in China and abroad.
• what does “double materiality” mean in this context? It refers to considering both the financial impact of sustainability issues on the company and the company’s impact on society and the habitat.
• Are Scope 3 emissions disclosures mandatory? No, they are currently encouraged but not required.
• How do these guidelines compare to international standards like ISSB? They share common principles but differ in areas like Scope 3 emissions and the breadth of covered topics.
• What is the deadline for the first mandatory sustainability reports? April 30, 2026, for reports covering the 2025 fiscal year.
• Where can I find more information about the PRC Sustainability Disclosure Standards (PRC SDS)? Consult resources provided by the Ministry of Finance and related agencies.

What impact do you think these new regulations will have on attracting foreign investment to Chinese markets? share your thoughts in the comments below!

How does Hutchinson & Wu’s research suggest the PRC’s approach to sustainability reporting differs from traditional models?

Understanding the PRC Sustainability Reporting Landscape

Recent research by Gilly Hutchinson and jennifer Wu provides crucial insights into navigating the evolving landscape of sustainability reporting,particularly for listed companies operating within or connected to the People’s Republic of China (PRC). This article delves into key takeaways from their work, offering actionable guidance for improved ESG reporting, corporate social responsibility (CSR), and adherence to emerging sustainability standards. The PRC’s increasing focus on environmental protection, social equity, and good governance is driving meaningful changes in reporting expectations. Understanding these shifts is no longer optional – it’s vital for maintaining investor confidence and ensuring long-term business viability.

Key Findings from Hutchinson & Wu’s Research

Hutchinson and Wu’s analysis highlights several critical areas where PRC guidelines are pushing the boundaries of sustainability disclosure. These include:

* Expanded Scope of Reporting: The guidelines move beyond traditional environmental metrics to encompass a broader range of social and governance factors. This includes labor practices, supply chain management, and anti-corruption measures.

* Emphasis on Materiality: A core tenet of the PRC approach is identifying and reporting on material sustainability issues – those that have a significant impact on the company’s financial performance and stakeholder interests. This aligns with global best practices like those promoted by the Sustainability Accounting Standards Board (SASB) and the Global Reporting Initiative (GRI).

* Increased Focus on Supply chain Due Diligence: Companies are now expected to demonstrate robust due diligence processes to identify and mitigate sustainability risks within their supply chains. This is particularly relevant for sectors with complex global supply networks.

* Integration with Financial Reporting: The trend is towards integrating sustainability information into mainstream financial reports, rather than publishing separate sustainability reports.This signals a growing recognition that sustainability is intrinsically linked to financial performance.

* Alignment with National policies: Reporting requirements are increasingly tied to China’s national policies on climate change, pollution control, and social advancement. Understanding these policies is crucial for accurate and compliant reporting.

Navigating the Core Requirements: A Practical Guide

Successfully implementing these guidelines requires a systematic approach.Here’s a breakdown of key steps:

1. Materiality Assessment: Conduct a thorough materiality assessment to identify the most relevant sustainability issues for your business. Engage with stakeholders – investors, employees, customers, and local communities – to gain diverse perspectives.
2. data Collection & Management: Establish robust systems for collecting, managing, and verifying sustainability data. This may involve investing in new technologies or upgrading existing processes. ESG data management is becoming increasingly sophisticated.
3. Framework Selection: Choose a recognized sustainability reporting framework (GRI, SASB, TCFD – Task force on Climate-related Financial Disclosures) that aligns with your business and reporting requirements. Consider the specific needs of your stakeholders.
4. Reporting Process: Develop a clear and clear reporting process, ensuring that information is accurate, reliable, and comparable.
5. External Assurance: Seek external assurance of your sustainability report to enhance credibility and build trust with stakeholders. Sustainability assurance is gaining prominence.

Benefits of Enhanced Sustainability Reporting

Investing in robust sustainability reporting yields significant benefits:

* Improved Investor Relations: Investors are increasingly prioritizing ESG factors when making investment decisions.Transparent and extensive sustainability reporting can attract capital and improve valuation.

* Enhanced Brand Reputation: Demonstrating a commitment to sustainability can enhance brand reputation and build customer loyalty.

* Reduced Risk: Proactive identification and management of sustainability risks can mitigate potential financial and operational impacts.

* Increased Efficiency: Sustainability initiatives frequently enough lead to increased efficiency and cost savings.

* Access to New Markets: Meeting sustainability standards can open doors to new markets and opportunities.

Real-World Examples: Leading the Way in PRC Sustainability Reporting

Several PRC-listed companies are already demonstrating leadership in sustainability reporting. For exmaple:

* BYD: The electric vehicle manufacturer consistently publishes detailed sustainability reports aligned with international standards, showcasing its commitment to environmental protection and social responsibility.

* China mobile: The telecommunications giant integrates sustainability considerations into its core business strategy and reports on its progress against ambitious ESG targets.

* Ping An Insurance: The financial services company actively promotes sustainable finance and reports on its environmental and social impact investments.

These examples demonstrate that robust sustainability reporting is not only possible but also beneficial for businesses operating in the PRC.

Practical Tips for Implementation

* start Small: Don’t try to tackle everything at once. Begin with a focused materiality assessment and prioritize the most impactful issues.

* Seek Expert Advice: Engage with sustainability consultants or advisors to navigate the complexities of the PRC reporting landscape.

* Invest in Training: Provide training to employees on sustainability reporting requirements and best practices.

* Stay Updated: The PRC’s sustainability reporting landscape is constantly evolving. Stay informed about new regulations and guidelines.

* Benchmark Against Peers: compare your reporting practices to those of your peers to identify areas for improvement.