Issues in the design of the system are surfacing one after another around the draft 'ESG Disclosure Institutionalization Plan' that the Financial Services Commission released on Feb. 25, 2026. The draft would require listed companies with total consolidated assets of 30 trillion won or more to make sustainability disclosures from 2028. The government plans to finalize the roadmap after gathering opinions through this month, and last week alone, ahead of the deadline, the National Human Rights Commission of Korea issued an opinion and a bill was introduced in the National Assembly.
The Human Rights Commission delivered its opinion to the FSC chairman on March 31. It calls for moving the mandatory start forward by one year from 2028 to 2027, and for beginning coverage with companies whose total consolidated assets are 10 trillion won or more. It also called for human rights indicators to be included in the disclosure standards so that disclosure of human rights information becomes mandatory, and for the schedule for mandating the social (S) area to be spelled out in concrete terms. Items calling for the timing of the shift to statutory disclosure to be made clear and for support measures for small and mid-sized companies to be prepared were also included.
The draft's 30 trillion won asset threshold is a point that several groups have taken aim at simultaneously. Solidarity for Economic Reform (경제개혁연대) submitted an opinion the same day proposing that the threshold be lowered to 5 trillion won. Since the draft was released, the number of companies covered at the outset has been cited variously as an estimated 59 companies, about 50-60 companies, and 7% of KOSPI-listed companies, and a confirmed tally has yet to be published.
Devices that narrow the scope of coverage are also in the draft. Subsidiaries whose assets or sales fall short of 10% on a consolidated basis are allowed to be left out of consolidation in the first year of disclosure. The first year's disclosure will be conducted on a trial basis, and comparative disclosure against the previous year's figures becomes possible from 2029. About half of the companies above the 30 trillion won threshold are in the financial industry, and some steel and chemical companies fall outside the mandate.
On emissions items, the Scope 3 grace period is at issue. The draft grants three years while ISSB S2, the international standard, sets one year, leaving a gap of two years. The Human Rights Commission called for this period to be shortened in consideration of the international standard. From climate and civic groups came the claim that 70-80% of corporate emissions come from Scope 3, and on March 26 at the National Assembly Communication Hall, the lawmakers' climate action group Bisang, the Korea Sustainability Investing Forum, the Green Transition Institute, Plan 1.5 and Big Wave held a press conference criticizing the draft.
The legislative method is a separate axis. The draft set out a path of operating disclosure under exchange rules in the early stage and then moving to statutory disclosure under the Capital Markets Act, but it does not say when the move will take place. The FSC's position is that it will decide the transition point after the opinion-gathering ends. It has been pointed out that under the current exchange system, even when a disclosure error occurs, only the exchange's internal sanctions are waived while civil and criminal liability remains as it is.
Rep. Park Sang-hyuk of the Democratic Party of Korea (Gimpo B, Gyeonggi Province) was the lead sponsor of a partial amendment to the Capital Markets Act (bill number 2217852) introduced on March 30. It would make it a statutory requirement to include sustainability matters in business reports, and would have the FSC set standards that take international consistency into account so that a disclosure and third-party assurance system is put in place. A provision that lets the FSC set the assurance standards while assurance work may be entrusted to private corporations and organizations was also included. Coverage would begin in 2028 with companies whose total consolidated assets are 10 trillion won or more and widen in stages to those of 1 trillion won or more, with the timing for companies below 1 trillion won left to the enforcement decree.
Measures easing corporate liability were included as well. A safe harbor would be introduced to grant permanent exemption from criminal liability, and in the first two business years after introduction, civil liability and fines would be waived where there is no intent. In the accounting field, there is precedent in which the expansion of auditor designation and periodic designation were introduced in the wake of the 2015 Daewoo Shipbuilding & Marine Engineering case and the 2018 Samsung Biologics case, so the supervisory design of the assurance system may be discussed next.
From the corporate side came remarks pointing to the burden created by putting off implementation. Kim Hun-tae, head of Posco Holdings' sustainability management office, said companies and related institutions have gone through uncertainty as disclosure standards and the roadmap have been postponed again and again, and gave the view that an approach of implementing first, even with a limited scope, and supplementing it afterward is realistic. The claim that the United Kingdom, Japan and Australia are introducing Scope 3 in stages or running it alongside voluntary disclosure was also raised, and the details of each country's system require separate confirmation.
Overseas schedules are also cited as a variable. Taiwan will implement sustainability disclosure as statutory disclosure in 2026 and Japan in 2027, and 37 major jurisdictions including Singapore and Hong Kong are pursuing legislation in line with ISSB standards. The EU and Australia introduced related systems in 2025. Under the domestic draft, the first disclosure would take place in 2028, so the debate over international consistency could shake the timing provisions of the final roadmap along with it.
The FSC also presented a plan to expand the existing 420 trillion won in transition finance into 790 trillion won in climate finance covering both green and transition, and to allocate more than half of the newly supplied climate finance to the provinces and more than 70% to small and mid-sized companies. ESG disclosure was taken up at the 'Fourth Productive Finance Grand Transformation Meeting'.
When the final roadmap comes out, the start date, the asset threshold, the Scope 3 grace period and the timing of the shift to statutory disclosure will all be revealed at once. Depending on where the line is drawn among 30 trillion won, 10 trillion won and 5 trillion won, the range of companies that have to prepare for the first disclosure in 2028 changes. The deadline for gathering opinions is this month.
