Major domestic manufacturers and the four petrochemical companies completed their sustainability reports for the first half of 2026, while the Financial Services Commission's release of the final sustainability disclosure roadmap passed its scheduled date of June 30, 2026. The announcement was put on hold after the party-government consultation was canceled. Key issues such as the scope and method of disclosure, whether to shift to statutory disclosure, and the extent of the Scope 3 grace period remain unsettled.
In 2026, the roadmap's release date moved from the first quarter to after April, then to the end of June, and even that end-of-June schedule was not met. Measured by announcement date, it is the fourth change in six months. No new schedule has been presented.
While the system stalled, corporate reporting cycles ran as usual. A sustainability report is a voluntary document that discloses ESG performance and risks alongside financial results each year, and it does not constitute a legally mandated disclosure. Samsung Electronics issued its "2026 Sustainability Report" on June 26, 2026, disclosing its strategy and performance across the three areas of environment, society and governance. Major manufacturers including SK hynix and Hyundai Motor also published reports this year.
The petrochemical sector completed its publication process by the end of June. According to filings registered with the Financial Supervisory Service's DART electronic disclosure system through July 2, 2026, all four companies, including Lotte Chemical, Kumho Petrochemical and Hanwha Solutions, disclosed that they had submitted their reports, with LG Chem last on June 30. LG Chem's chief executive is Kim Dong-chun, and Kumho Petrochemical's chief executive is Baek Jong-hoon.
The four companies' reports commonly listed as business risks the oversupply of commodity petrochemicals stemming from large-scale capacity expansion in China, cost competition driven by the realignment of global supply chains, and the spread of national-first policies in major overseas markets.
The breadth of the unsettled issues is evident in the differences between the draft and what has since become known. The order of application set out in the draft covered KOSPI-listed companies with consolidated total assets of 30 trillion won or more in the first year, then expanded to companies with 10 trillion won or more the following year, with 2028 as the starting year. Yet the final version is said to include a plan that would impose statutory disclosure obligations on KOSPI-listed companies with 10 trillion won or more from 2028, the first year of implementation. Which version is final has not been officially confirmed.
Two accounts also diverge on the disclosure channel. The draft took a phased approach, beginning operation with exchange disclosure and reviewing a shift to statutory disclosure once the system settled, while the final version fixes statutory disclosure from the point of implementation. The same goes for Scope 3. The draft set 2031 as the starting year, taking into account the time needed to build the basis for calculating and estimating emissions, but accounts related to the final version mention only the possibility of maintaining a three-year grace period, leaving the year unspecified.
For companies, these differences determine the scope and cost of preparation. The 30 trillion won threshold and the 10 trillion won threshold produce different groups of covered companies, and exchange disclosure and statutory disclosure do not carry the same level of verification and liability. As in the case of SKC, which strengthened supply chain risk management by upgrading its double materiality assessment, some companies are overhauling their disclosure systems without waiting for the rules to be finalized.
For now, the issue is when the party-government consultation resumes and when the final version follows. Given the time remaining until 2028, cited as the first year of implementation, the later the rules are finalized, the less time companies have to respond. In the meantime, voluntary reports continue to come out each year, and the data they contain may not carry over intact to mandatory disclosure.
