Legislative debate on shifting sustainability disclosure from voluntary to legally mandatory continues in the National Assembly. In November 2025, Rep. Kang Hoon-sik of the Democratic Party of Korea and nine others introduced an amendment to the Capital Markets Act mandating sustainability disclosure, and the office of Rep. Min Byoung-dug of the same party is preparing a separate amendment. An official at Rep. Min's office said on January 20, 2026 that the plan was to introduce it as early as that week, but the actual introduction and bill number have not been announced.
Rep. Kang's bill was introduced first. Along with mandatory disclosure, it stipulates the setting of targets such as climate strategy and mandatory external assurance of disclosed items. It also includes report submission, a safe harbor provision for deficient disclosure, and fines for violations, with details delegated to presidential decree. It also contains a provision deferring legal liability for Scope 3 greenhouse gas emissions disclosure for the first year of disclosure only.
Rep. Min's office described the amendment it is preparing as encouraging participation through incentives rather than regulatory compulsion. It said starting directly as a statutory disclosure from the point the system takes effect is the office's own position, and that whether to go through exchange disclosure first is under discussion. The specific form of the incentives cannot be confirmed because the text of the bill has not been released.
Forecasts on the timing of implementation were also offered. Kim Jong-dae, professor emeritus at Inha University, said on January 21, 2026 at the Korea Environmental Industry and Technology Institute's 34th ESG ON Seminar that a government roadmap was likely to emerge within the first half of 2026. His forecast is that the Korea Sustainability Standards Board (KSSB) climate disclosure standards will acquire legal binding force through the Capital Markets Act amendment, and that the requirement will apply from 2028 centered on large companies with assets of 2 trillion won or 5 trillion won or more. With the two asset thresholds cited together, the fixed threshold has not been specified.
On Scope 3, Prof. Kim said deferral was likely but that it would not be scrapped, and explained that the EU is about the only jurisdiction currently requiring it. On the EU's moves to ease regulation, he noted these amount to a partial reduction in the number of companies covered and in data points.
Apart from the domestic debate, overseas regulation has already passed through to the practical burden on Korean companies. The EU Corporate Sustainability Reporting Directive (CSRD) requires large companies to disclose ESG information across the supply chain and requires external audit of that data. The Carbon Border Adjustment Mechanism (CBAM) has been in effect since 2026, and importers must report and verify the embedded emissions of volumes exported to the EU. The battery regulation, which entered into force in 2023, applies in stages from 2027 and includes the attachment of a battery passport carrying information on composition, manufacturing process, carbon emissions and recycling.
In the parts supply chain the demands are more direct. Automakers are requiring data on carbon emissions, energy use, and human rights and safety from parts suppliers, treating Scope 3 emissions arising in the supply chain as one of the criteria they look at when making purchasing decisions. The online seminar the Korean Foundation for Quality (KMR) held on January 20, 2026 for auto parts suppliers on responding to global supply chain ESG assessments also connects to this trend.
However the system is designed, the basis for emissions figures remains a separate issue. Disclosed greenhouse gas emissions often rely on an estimation method that multiplies activity data by an emission factor rather than on direct measurement. The usual practice has settled into direct measurement for Scope 1, calculation based on electricity consumption for Scope 2, and estimation or omission for Scope 3. That is why recommendations have been made to disclose the calculation standards, the source of emission factors, the measurement method and whether external verification was carried out.
The response task commonly pointed to is the data management system. Integrated management covering subsidiaries, worksites and partner firms, risk analysis systems and specialist staff, and internal activity data collection systems are each mentioned. Once the legal mandate is confirmed, companies subject to disclosure will have to leave data in a form that can be assured.
Two points to watch hang on two timings. One is how the asset threshold and starting year are settled in the government roadmap expected in the first half of 2026, and the other is what form the Scope 3 deferral takes in the text of the law. What companies have to build up in the meantime is measurement records that hold up under verification.
