Calls are mounting to revise the mandatory start date and scope of the draft sustainability (ESG) disclosure roadmap released by the Financial Services Commission in February 2026. The draft would make disclosure mandatory from fiscal 2027 (disclosed in 2028) for KOSPI-listed companies with consolidated total assets of 30 trillion won or more and widen it in stages, with roughly 58 companies covered at the outset. The National Pension Service's National Pension Fund Management division submitted a written opinion on March 30, and the Democratic Party of Korea called for an upward revision at a closed-door party-government meeting on April 7. An FSC official said the final plan would be released late this month with no change to the schedule.
The shift in the threshold is clear when compared with the 2021 plan. The FSC plan at the time covered KOSPI-listed companies with total assets of 2 trillion won or more, making disclosure mandatory from 2025 and expanding it to all listed companies by 2030. The current draft raises the asset threshold to 30 trillion won and pushes back the start date. The design calls for operating the system as Korea Exchange disclosure in the early stage and converting it to statutory disclosure later.
The National Pension Service delivered its written opinion to the Financial Services Commission and the Korea Accounting Institute, among others, under the name of Fund Management Officer Suh Won-joo. The opinion called for moving the start date forward by one year to fiscal 2026 (disclosed in 2027) and widening the requirement to all KOSPI-listed companies with consolidated total assets of 2 trillion won or more. It also said the mandatory date for Scope 3, emissions across the value chain, should be moved up to around 2029. The draft grants Scope 3 a three-year grace period, applying it from 2031.
One of the grounds cited by the National Pension Service is the industry composition of the 58 companies covered. Of these, 29 are financial institutions, which it said means manufacturers facing large industrial transition risk are not sufficiently included. It also called for revising the "exception clause for less than 10% of assets and sales" that excludes small subsidiaries from coverage. The National Pension Service's domestic equity holdings stood at about 330 trillion won as of January 2026.
The National Pension Service's corporate engagement activity has expanded in recent years. According to its stewardship responsibility records released on March 31, the "dialogue with companies" program covered 158 listed companies in 2025, up 7.5% from 147 in 2024. The number of listed companies subject to shareholder activity on the grounds of "unforeseen concerns" rose 285%, from 13 in 2024 to 50 in 2025. Closed-door meetings rose from 11 in 2022, 12 in 2023 and 6 in 2024 to 69 covering 50 companies in 2025.
The ruling party's demands have also carried over into legislation. At the April 7 party-government meeting, Democratic Party lawmakers called for the immediate introduction of statutory disclosure without going through the exchange disclosure stage, expansion of coverage below 30 trillion won in assets, and a widening of scope to environmental (E) items beyond climate and to social (S) items. Rep. Park Sang-hyuk introduced an amendment to the Capital Markets Act that would widen coverage to companies with assets of 10 trillion won or more in 2028 (fiscal 2027), 2 trillion won or more in 2029, and 1 trillion won or more from 2030. Rep. Min Byoung-dug introduced an amendment on April 8 that would make ESG information from listed companies a statutory disclosure.
Accounts differ over how the draft was formed. One industry official claimed the draft was effectively prepared under the lead of the Ministry of Trade, Industry and Energy, and that the ministry proposed the delay and the narrowing of coverage. An FSC official said the draft was worked out in consultation with related ministries including the Ministry of Trade, Industry and Energy and the Ministry of Climate, Energy and Environment, and that it is not true that the trade ministry's views were given greater weight.
FSC Vice Chairman Kwon Dae-young said in February that the manufacturing-based industrial structure and conditions on the ground needed to be sufficiently reflected. In 2024, four business groups including the Korea Chamber of Commerce and Industry proposed a 2029 start date.
Criticism has also come from the National Assembly. At a March 31 plenary meeting of the National Policy Committee, Rep. Shin Jang-sik of the Rebuilding Korea Party said the draft was a step back from the Moon Jae-in government's plan, and at the April 6 interpellation session on the economy, Democratic Party Rep. Park Ji-hye said there are assessments that it lags behind global standards. Abroad, the EU has required disclosure from large companies under the CSRD since 2024, and the United Kingdom, Australia, Taiwan and China begin phased mandates from 2026. Japan is introducing statutory disclosure in 2027, and Singapore has applied mandatory disclosure to all listed companies since 2025.
The issues narrow to three. Whether to keep the asset threshold at 30 trillion won or lower it, whether to go through the exchange disclosure stage or move straight to statutory disclosure, and when to bring social and governance items and Scope 3 into the mandatory scope. The details of the final plan have not been settled, and it is scheduled for release late this month. With two amendments pending in the National Assembly, the discussion may move to the standing committee even after the government plan is out.
