The framework of the final sustainability disclosure standards has taken shape. The Korea Accounting Institute divided the system into Disclosure Standard No. 1 (general requirements) and No. 2 (climate-related disclosures), and confirmed a plan to reflect IFRS S1 and S2 in line with domestic conditions. The roadmap determining when and to which companies the standards will apply will not be confirmed until April. With the form of the standards and the implementation schedule separated by a two-month gap, the point at which the system's effectiveness can be gauged has been delayed by that much as well.
Pressure along the same lines also came from abroad. On February 5, 2026, the International Corporate Governance Network (ICGN) sent an open letter to the National Assembly ESG Forum, the Financial Services Commission and the Korea Accounting Institute, expressing support for the amendment to the Financial Investment Services and Capital Markets Act. The assets under management of institutional investors participating in the organization were presented at roughly 90 trillion dollars (about 125 quadrillion won), but the reference date for the calculation was not disclosed along with it.
The ICGN is an investor-led governance organization founded in 1995. More than 300 asset owners, asset managers and advisory firms in some 40 countries participate as members. The letter's demands ran in two directions. Promptly announce the ESG disclosure roadmap tied to the amendment, and put in place a system that provides sustainability information bundled with financial statements in a single report.
The letter also included a call to make the legal basis for disclosure obligations clear through an amendment to the Financial Investment Services and Capital Markets Act rather than placing it in exchange regulations. It came together with a recommendation to adopt the International Sustainability Standards Board (ISSB) standards. That is a point where it meets, in methodological terms, the domestic final draft grounded in IFRS S1 and S2.
Domestic discussions have run about two years since the public exposure draft of April 2024. The Korea Accounting Institute said it gathered corporate views through surveys and meetings in the interim, and put its efforts into easing practical burdens and improving the feasibility of implementation. Such considerations are reflected throughout the final draft. Data submitted to the Ministry of Environment and other relevant ministries can be reused as disclosure material, and a path was opened to exclude derivatives and other instruments when calculating financed emissions and to use the Korean Standard Industrial Classification (KSIC) in place of an international classification system.
Companies that disclose voluntarily are exempt from the obligation to issue a report at the same time as the settlement announcement. That means separate submission within the year becomes possible. Items with a high degree of calculation difficulty, such as Scope 3, will receive a preparation period again when they shift to mandatory disclosure.
Social indicators, on the other hand, were left out of the scope. No. 101, "additional disclosure items," which was to contain policy-oriented indicators such as worker accidents and the employment rate of people with disabilities, was left out of this round of standard-setting. It is a design that takes climate as its axis and puts the social area off until later.
The remaining point of contention is the Scope 3 timetable. The Financial Services Commission held the sixth meeting of the ESG Finance Task Force at the Korea Chamber of Commerce and Industry in Seoul, presided over by Vice Chairman Kwon Dae-young, where the business community's demand for exclusion on the grounds that supply chain emissions are difficult to measure in practice collided with the counterargument that leaving them out would reduce disclosure to a formality. The FSC took the position that it would include Scope 3 in the scope but would not set the starting point of application in the standards, instead reviewing a grace period in the roadmap discussions.
There is precedent for the schedule being pushed back. In its December 2025 work report, the FSC set the first quarter of 2026 as the point for preparing the standards and roadmap, then adjusted confirmation of the roadmap to April. Before that, it had presented a plan making companies with assets of 2 trillion won or more the first subjects in 2025 and expanding to all KOSPI-listed companies by 2030, then referred to the introduction timing only as "after 2026," citing the burden on business.
The clock outside is running faster than at home. The EU has been implementing sustainability disclosure since 2025, and Japan enters phased application beginning in June 2027. With the domestic application timing handed over to the roadmap, how the extent of the Scope 3 grace period is set will change both companies' preparation burden and the density of the information investors receive.
The next turning point is the end of this month. It has been announced as the point when the final draft and the draft roadmap will be released, but explanations of the format of the announcement and whether it will be finalized differ. Which companies disclose what from which fiscal year will emerge in the April roadmap. Until then, only the table of contents of the standards has been set.
