When 100 executives and staff in charge of ESG disclosure were asked what was hardest, 63% pointed to measuring and gathering supplier data. That is the result of a survey the Korea Chamber of Commerce and Industry conducted among domestic companies. On the same day the survey was released, Vice Minister Kwon of the Financial Services Commission raised the possibility of widening the Scope 3 disclosure exemption to mid-sized and large companies in low-carbon industries.
Scope 3 is the emissions that arise outside a company's own fence. It covers the suppliers that deliver raw materials, the logistics that carry products, and the stage where consumers use and discard them. It is different in nature from Scope 1 and 2, which are finished once a company tallies its own smokestacks and electricity use.
The moment the counting boundary moves outside a company, the parties holding the data are scattered across dozens to hundreds of business partners. This is the point where the 63% named gathering supplier data as a difficulty.
The plan for applying ESG disclosure standards that the FSC released in July 2026 set the exemption requirement as the intersection of two conditions. A company is left out only if it is a small business and at the same time does not belong to a high-carbon emitting industry. Vice Minister Kwon's remarks pointed toward loosening the company-size condition within that intersection. The idea is to exclude a company in an industry with low emissions from the Scope 3 counting obligation even if it is large.
The larger a company in a low-carbon industry, the longer its supply chain. If that company does not count its Scope 3, a stretch emerges where no one adds up supplier emissions. Conversely, if counting is pushed through, the measurement burden comes down onto small and mid-sized suppliers that carry no disclosure obligation.
Where the line between low carbon and high carbon falls, and by what standard mid-sized and large companies will be divided, will emerge when the industry classification codes and the emissions baseline are released. That line determines the number of companies subject to disclosure.
There is one more device raised alongside it. It is the liability shield, the so-called safe harbor, under which a company that disclosed in good faith is not held responsible even if the figures later turn out to be wrong. Scope 3 is an item into which estimates and assumptions are mixed, so the figures often change later. If the obligation is piled on without the shield, companies either write conservatively or leave the space blank altogether.
In the private sector, movement has come in the verification field. The Digital ESG Alliance signed an agreement with the Korea ESG Management Development Institute to link verification and certification in ESG disclosure and supply chain carbon management. Under it, disclosure consulting and digital solution verification infrastructure are connected, and the two will also look together at new carbon neutrality businesses.
How effective the mandate turns out to be depends on how far along the supply chain emissions get onto someone's books. Widening the exemption increases the stretches that never reach the books, and narrowing it spreads the obligation to places that can hardly bear the cost of measurement. That scope will be set when the FSC releases the classification standard for low-carbon industries together with the liability shield requirements.
