The Financial Services Commission released a sustainability disclosure roadmap on February 25, 2026. KOSPI-listed companies with consolidated total assets of 30 trillion won or more will carry ESG disclosure obligations from 2028, based on the 2027 business year. Scope 3, which refers to emissions across the value chain, will be deferred for three years. Disclosure will run first as exchange disclosure and then move to statutory disclosure once the system settles in, with safe harbor allowed for forward-looking disclosures.
On March 4, a week after the announcement, Rep. Park Sang-hyuk of the Democratic Party of Korea (Gimpo B, Gyeonggi) and Seoul National University's Center for Environmental and Energy Law and Policy held a forum titled "Sustainability Disclosure Roadmap, Improvement Measures for the Korea Premium and International Alignment" at Conference Room 4 of the National Assembly Members' Office Building. Common ground formed on phased mandatory application, the Scope 3 deferral, and introducing exchange disclosure first. Differences remained over the method of transition to statutory disclosure, cost burdens, and the asset size threshold.
How far to widen the scope of application is the starting point of the calculation. According to an analysis by Hwang Jung-hwan, head of Kim & Chang's Sustainability Disclosure Advisory Center, 58 companies have consolidated assets of 30 trillion won or more, 105 have 10 trillion won or more, 165 have 5 trillion won or more, 281 have 2 trillion won or more, and 451 have 1 trillion won or more. As of 2025, 67% of companies with assets of 2 trillion won or more issued sustainability management reports, and widening the range to 1 trillion won or more brings the issuance rate down to at least 41%. On the investor side, calls were raised to expand the coverage to 2 trillion won or more so that comparison across industries is possible.
The length of the expansion period is also a point of discussion. Hwang noted that the release of the roadmap was about four years late, and assessed that the release itself has the effect of reducing uncertainty in the market. At the same time, he pointed out that if the phased expansion period runs long, a gap in learning effects will widen between companies that began disclosure early and those that join later, which can lead to differences in competitiveness. The introduction schedules in many countries are set at around three years, and the fact that the EU began applying its rules to large companies first is cited as a point of comparison.
Demands are specific when it comes to the legal form of the safe harbor provision. Lee Woong-hee, standing member of the Korea Accounting Institute, said the civil and criminal liability issue is resolved only when the safe harbor provision is placed within statutory disclosure under the Financial Investment Services and Capital Markets Act. Jeon Yoon-jae, head of KB Financial Group's ESG Strategy Department, said a safe harbor clause is needed because climate disclosure contains forward-looking estimates such as scenario analysis. Choi Yong-hwan, head of the ESG research team at NH-Amundi Asset Management, said the exchange disclosure approach could drift into checkbox-style disclosure that fills only the formal requirements.
Lee Min-kyung, professor of law at Sungshin Women's University, proposed disclosure integrated with financial reporting within the business report under the Financial Investment Services and Capital Markets Act, mandatory third-party assurance and the establishment of its legal basis, and exemption from civil and administrative liability and exclusion of criminal punishment in the early stage of introduction. The authorities' official position on mandatory third-party assurance has not been settled.
On the corporate side, a seminar on response strategies timed to the finalization of the KSSB climate disclosure standard was held on March 6. The KSSB climate disclosure standard requires disclosure of climate-related risks and opportunities.
The items that must be settled in the time remaining before the first disclosures in 2028 are clear. They are the timing and requirements for moving from exchange disclosure to statutory disclosure, the years of application by asset threshold for the stage after 30 trillion won, and the legal provision that will contain the safe harbor for forward-looking figures. Until the three are confirmed, companies outside the 58 will have to set the scope of their preparations on their own.
