Suppose there is a staff member who has been told to gather electricity consumption figures from forty suppliers. The first problem he runs into is not whether the regulation is right or wrong. It is which month's bills to collect and in what units, and what to use to fill in the gaps. While the debate over mandatory disclosure has circled in place for years, the wall facing practitioners has stood in this shape.
The outline of the system has been drawn down to its bold lines. The final version of the disclosure roadmap has been put together, an amendment to the Capital Markets Act has been introduced, and even a clause imposing criminal penalties for false disclosure has come onto the discussion table. The date of introduction has been put forward as 2028.
So what should the remaining period be used for? It should be used to build verification infrastructure and data systems.
The reasoning of those who point to the burden is not a light one. Asking a mid-sized manufacturer with a staff of about ten to assign a separate person to calculate emissions is far from reality. External verification costs go out every year, and there is no enforcement power behind obtaining data from suppliers.
There are also concerns that once a criminal penalty clause is attached, companies may lean toward conservatively inflating their figures rather than taking the risk of writing down a wrong value. This concern cannot be called groundless.
But a delay does not remove that burden. It only pushes it back. Even if the preparation period is extended by two years, verification bodies do not increase on their own, and suppliers' record formats do not become uniform on their own. If time is bought and nothing is built, the same appeals will be repeated when the new deadline arrives.
Conversely, the time spent from now on accumulates like compound interest. The calculation form created in the first year is used again the following year. The data request cycle once aligned with suppliers rolls on unchanged the next year. Considering that training verifiers takes no short amount of time, developing people is itself an item pressed by the deadline.
The question of whether one supports or opposes the mandate was valid before the outline of the system took shape. Who will help small and mid-sized suppliers submit their data, and in what way? By when and to what level will the qualifications and the number of verification bodies be brought into line? Where will the scope of the criminal penalty clause be drawn between intent and error?
The remaining period comes to less than eighteen quarters. What that time is filled with will determine whether the form of the first report in 2028 is left blank or filled with figures that have grounds behind them.
