Ahead of the first ESG disclosures in 2028, the Korean government has begun work on setting the scope of companies subject to mandatory disclosure. As of November 2026, two calendar years remain until the first disclosure year. Over the same period, the European Union (EU) processed legislation related to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), and in corporate practice in Korea, the electricity used by workplace AI and the emissions it generates have emerged as a new disclosure task.
Companies on the 2028 list must put in place an emissions calculation system and internal data management procedures within the remaining period, while companies outside the list gain correspondingly more time to prepare.
The two EU directives serve different purposes. The CSRD made ESG information disclosure mandatory for companies, and the CSDDD made companies responsible for due diligence on labor and environmental issues. The EU Council gave final approval on February 24 to legislation related to the two directives. If the approved text changed the timing of disclosure requirements or the number of companies covered, Korean companies with a large share of business in Europe will also need to rework their response schedules accordingly.
AI brought into the workplace is also a source of emissions.
AI models that companies use for work consume electricity each time they process a request, and the greenhouse gases released in generating that electricity affect the emissions items in ESG disclosures. Companies that use external AI services without running their own servers also need to determine the emissions from their usage. Which emissions category external service usage falls under may be interpreted differently depending on the applicable standard. A method of accounting is now needed that extends the boundary of emissions calculation, which had covered only in-house facilities, to the data centers of external providers.
The focus of disclosure work is also shifting. Compared with publishing a single sustainability report each year, the work of managing which source data each figure in the report was drawn from, and who revised it and when, has grown in weight. As values that must be obtained from external providers, such as AI electricity usage, increase, the scope of management spreads beyond the company. It is difficult for a single department in charge to handle.
What the Korean government is refining with 2028 in view is mandatory disclosure. The larger a company's sales in the European market, the more likely it will need to look at the items required by both systems together.
If the government sets a narrow scope, the number of companies disclosing in the first year will fall and each company will have more room to prepare. If the scope is broader, more companies will need to have emissions data, including workplace AI usage, in place before 2028. In either case, the reliability of the first disclosed figures depends on the level of data management behind them.
Disclosure departments may want to gather AI service usage records scattered across departments into a single ledger. Keeping usage periods and volumes on a monthly basis will allow them to plug in those values as soon as the government announces the scope and calculation method. The first disclosure is in 2028.
