The draft roadmap for mandatory ESG (sustainability) disclosure that the Financial Services Commission released on Feb. 25, 2026 is understood to be set to close its comment period at the end of this month and enter the finalization process in April. The draft makes KOSPI-listed companies with consolidated total assets of 30 trillion won or more the first covered group in 2028 (fiscal 2027), and includes a step widening coverage to those with 10 trillion won or more in 2029. The National Assembly, civic groups and climate think tanks have called for a full revision, saying the threshold is too high, and a survey of companies found requests for a grace period on grounds of insufficient preparation. With about a month left before the finalization deadline, the roadmap is under two opposing pressures at once.
The draft's implementation method is also among the points at issue. Instead of going straight to statutory disclosure through business reports, it is a two-stage design that starts with Korea Exchange disclosure and later moves to statutory disclosure. Scope 3 emissions are deferred three years from the first disclosure date and become mandatory from 2031 (fiscal 2030).
On March 26, at the National Assembly's press center, the Democratic Party of Korea's climate action lawmakers' group "Bisang," National Assembly ESG Forum co-chair Rep. Min Byoung-dug, the Korea Sustainability Investing Forum, the Green Transition Institute, Plan 1.5 and the youth climate group Big Wave held a joint press conference. They argued that the draft falls behind international trends in all four areas of disclosure timing, disclosure coverage, disclosure channels and Scope 3. Rep. Yum Tae-young of the Democratic Party of Korea also spoke at the press conference.
The participating organizations based their case on a comparison of the number of companies covered. There are 58 KOSPI-listed companies with consolidated total assets of 30 trillion won or more, and financial institutions account for 29 of them. In Japan, about 172 companies are covered in 2027 (FY26), the first year of disclosure, and about 343 the following year, while in China about 458 companies are covered in the first year of mandatory disclosure. Lee Jong-oh, secretary general of the Korea Sustainability Investing Forum, said that major countries will complete their planned disclosure by 2030, while Korea will widen coverage to all KOSPI-listed companies only in 2033 (FY32) at the earliest.
As an alternative, they presented a two-stage plan that would begin with about 223 KOSPI-listed companies with consolidated total assets of 2 trillion won or more, and, if acceptability is an obstacle, take about 156 companies with 5 trillion won or more as the starting point. Five trillion won is the threshold the Fair Trade Commission uses when designating business groups subject to disclosure. The grounds for the calculation presented alongside it were a 67% rate of sustainability report publication, a 62.3% CDP response rate, and 174 companies covered by the emissions trading scheme and the target management scheme. The participating organizations called for shortening the exchange disclosure period to one year, cutting the Scope 3 deferral to one year in line with the ISSB recommendation, and making third-party assurance mandatory.
Set out by country, the grace period is none in the EU, one year in the UK, Australia and Japan, three years in Canada, 180 days to one year in the U.S. state of California, and one year under the ISSB recommendation. Scope 3 accounts for an average of 75-80% of a company's total greenhouse gas emissions. The number of domestic companies reporting Scope 3 to CDP rose to 127 in 2023, 158 in 2024 and 222 in 2025, but they are understood to have calculated and reported an average of eight of the 15 categories.
The survey on the corporate side shows a different picture. In the "Survey on ESG Disclosure Preparedness" conducted by the Federation of Korean Industries among KOSPI-listed companies with assets of 10 trillion won or more but less than 30 trillion won, 70.4% said they could be ready in time for the 2029 mandate. On the Scope 3 item, by contrast, 48.1% named 2032 and 51.9% named 2033 or later as the point at which they could comply, and in manufacturing 66.7% asked for a grace period. Suppliers' capacity to measure emissions and the reliability of the data were named as difficulties.
Organizational conditions are also reflected in the responses. Of all responding companies, 55.6% handle the work as an extra duty without dedicated ESG staff, and in manufacturing the figure is slightly higher at 58.3%. The KSSB standards require companies to describe the grounds for their assessments along with the figures, and to state the fact and the reason when they omit disclosure because there is no material climate risk or opportunity information, so staffing requirements could become a heavier burden as the implementation date approaches.
In conclusion, the debate splits along two axes. The demand to lower the threshold and increase the number of companies covered, and the responses saying Scope 3 compliance is difficult even at the current threshold, are directed at the same roadmap. The views of the National Assembly and civic groups are understood to have been conveyed to the presidential office as well, but how far the FSC will reflect the revision demands remains unsettled.
Interpretations also differ over how the schedule after the 2029 expansion is written in the draft. Depending on whether it stops at 10 trillion won or more or continues to all listed companies, the premise behind the 2033 projection changes. The comment period closes at the end of this month and the final plan comes out in April.
