KOSPI-listed companies with consolidated total assets of 10 trillion won or more will enter sustainability information in their 2028 annual reports. Under the Financial Services Commission's final plan released this past July, 107 companies are covered, and including subsidiaries, 291 companies fall within the disclosure scope. The content to be entered is fiscal year 2027 (FY27) information. For the disclosure channel, the annual report under the Capital Markets Act was chosen instead of Korea Exchange disclosure.
The scope widens each year. In 2029 it expands to companies with consolidated total assets of 5 trillion won or more, and a plan to lower it to listed companies with 2 trillion won or more in 2030 is under review. At the 2 trillion won line, the coverage will reach roughly the level of the KOSPI 200, the Financial Services Commission explained.
Korea's implementation date is one year later than Japan's. Whether to expand will be decided after evaluating the disclosure situation over the two years of 2028 and 2029.
For the first three years after introduction, damages liability under the Capital Markets Act, administrative sanctions, and criminal punishment are comprehensively exempted across disclosure information. Intentional greenwashing is an exception, so damages liability and administrative sanctions remain in place. Third-party assurance applies from 2030, two years after mandatory disclosure begins. Scope 3 is deferred by three years for each group of companies, with the application date set at 2031 for companies with 10 trillion won or more, 2032 for those with 5 trillion won or more, and tentatively 2033 for those with 2 trillion won or more.
A little over two years remain until the first disclosure, and the liability exemption and Scope 3 deferral add three more years after that. Joining the two periods together makes the preparation deadline look like five years. The fiscal year 2027 data that will go into annual reports is generated over the course of next year.
Sustinvest held a seminar on strategies for responding to mandatory disclosure on August 19 at Tower 107 in Jung-gu, Seoul. Oh Seung-jae, the chief executive who delivered the keynote, said the three-year exemption and the deferral of third-party verification should not be read as grounds for relief. He defined the present as the "golden time" for structural improvement and presented 2026 and 2027 as the right moment for setting strategy and building foundations.
Oh divided corporate responses into two tracks. The compliance type, focused on meeting minimum disclosure standards, leans on estimates and secondary data, while the management-strategy-integrated type connects ESG risk management and corporate value enhancement as one. He cited as changes that subsidiary data must be gathered on a consolidated basis, that supply chain risk must be managed, that disclosure responsibility moves up to the board, and that the dual reporting framework of the annual report increases the workload for staff. Supply chain data runs into obstacles on both practical and legal grounds because there is no clear basis for compelling suppliers to submit it, and Oh pointed to the use of DX and AX technology as an alternative.
Government support measures were disclosed a day later at the 7th ESG Economy Forum held in Yeouido. The Ministry of Climate, Energy and Environment has been developing industry-specific Scope 3 calculation guidelines since 2023 and has completed guidance for seven industries including secondary batteries, semiconductors, and displays. Eight industries including automobiles and petroleum products follow.
The target date for research and development of a climate risk assessment system has been moved up from 2028 to 2027. It is an assessment tool that reflects disasters that actually recur in Korea, such as floods, droughts, and wildfires. The 12 high-emission industries designated by the government are provided with specialized consulting that bundles process improvement, greenhouse gas inventory construction, and the preparation of reduction pathways.
This past February, educational materials and a casebook comparing domestic and overseas disclosure standards were released, and they contain the criteria for determining how far to include emissions from affiliates and investee companies. The Ministry of Climate said it would broaden its support to include building a national carbon emissions database and training personnel.
Public indicators showing the actual state of the data companies hold are scarce. The Korea Industrial Complex Corporation has released material to the effect that the carbon data of companies facing disclosure and regulation remains under "solo management."
The direction of the 2 trillion won expansion in 2030 will be determined by the disclosure results over the two years of 2028 and 2029. Before that, the fiscal year 2027 books close. The emissions and supply chain information that will go into the first annual reports will be drawn from those books.
