Quick Guide: Key Sustainability Disclosure Regimes: PRC sustainability reporting guidelines for listed companies

The Shanghai Stock Exchange (“SSE”), Shenzhen Stock Exchange (“SZSE”) and Beijing Stock Exchange (“BSE”) issued their respective Guidelines on Corporate Sustainability  Reporting (the “Guidelines”) on 12 April 2024.  The Guidelines are recognised to be a milestone in laying out China’s first set of mandatory sustainability reporting requirements for public listed companies.

To implement the Guidelines and to provide more detailed instructions and requirements with respect to the sustainability reporting of listed companies, the SSE, SZSE and BSE released their respective Guides for the Compilation of Sustainability Reports (the “Compilation Guides”) on 17 January 2025. Draft amendments to the Compilation Guides were introduced by the three exchanges for public comments on 5 September 2025. Compared to the existing Compilation Guides, the draft amendments supplement three schedules, providing guidance on sustainability reporting for three additional disclosure topics stipulated under the Guidelines.

Together, the Guidelines and the Compilation Guides form China’s current regime on sustainability reporting for listed companies.

For the SSE and SZSE, a combination of mandatory and voluntary disclosures is adopted. 

Only the following listed companies are mandated to prepare and disclose their sustainability report: 

• Companies continuously included in the SSE 180 Index, STAR 50 Index, Shenzhen 100 Index, or ChiNext Index during the reporting term; and 
• Companies dual-listed in the PRC and abroad. 

The Guidelines further encourage other companies listed on the SSE and SZSE to voluntarily prepare and disclose their sustainability report.

For the BSE, only voluntary disclosure is adopted, as the BSE primarily targets small and medium-sized enterprises with limited disclosure capabilities.

The Guidelines were issued on 12 April 2024 and came into effect from 1 May 2024. 

Listed companies subject to mandatory disclosure requirements should produce their first sustainability report for 2025 before 30 April 2026. 

The Compilation Guides were issued and came into effect on 17 January 2025.

The draft amendments to the Compilation Guides were issued for public comment on 5 September 2025, with the consultation period ending on 19 September 2025.

Guidelines

• The Guidelines require listed companies to disclose and analyse their sustainability-related information around four core pillars similar to those used by the Task Force on Climate-related Financial Disclosures (“TCFD”) and ISSB: governance, strategy, impact, risk and opportunity management (under the TCFD and ISSB, this pillar is referred to as “risk management”) and metrics and targets.
• The Guidelines set out 21 covered topics that companies should consider for disclosure. Companies should benchmark these topics against their industry sector and business operations and determine what to cover, while also identifying topics that are not stipulated under the Guidelines but which companies determine also meet the double materiality standard. In principle, all covered topics set out in the Guidelines should be presented in the reports unless an explanation is provided for excluding certain topics. 
• In terms of climate-related disclosure, the Guidelines differ from the ISSB’s climate-related disclosures (IFRS S2) in several respects. While the Guidelines make it mandatory to disclose Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions, they only encourage, rather than require, the disclosure of Scope 3 GHG emissions. In addition, under the Guidelines, scenario analysis is only encouraged but not mandatory for listed companies’ climate adaption assessment. By contrast, IFRS S2 requires companies to use scenario analysis for their climate resilience assessment.

Compilation Guides 

• The Compilation Guides do not require additional mandatory disclosures. Listed companies are encouraged to follow the Compilation Guides as they see fit.
• The Compilation Guides elaborate on the methods for identifying material topics, outline the key focuses of disclosure, provide a framework and sample texts for sustainability reports, and explain how to interpret the standards. They also specifically stipulate the assessment and calculation methods for climate change-related indices. 
• Further guidance on the disclosure of pollutant emission, energy utilization, and water utilization will follow once the draft amendments to the Compilation Guides are finalised.

The Guidelines adopt the concept of what is typically referred to as “double materiality”, covering both financial and impact materiality, which is in essence different from the focus on financial materiality under the ISSB standards. 

As per the Guidelines, disclosure of issues meeting the “financial materiality” threshold will need to cover the four core pillars (i.e. governance, strategy, impact, risk and opportunity management, and metrics and targets), whereas disclosure of issues meeting the “impact materiality” do not have to follow this format and only need to be in line with the requirements for specific topics set out in the Guidelines as applicable.

The Ministry of Finance (“MoF”), together with other eight ministries, established a cross-agency working group in China. This group formulated the PRC Sustainability Disclosure Standards (the “PRC SDS”) that is based on the ISSB’s IFRS S1 and IFRS S2. Disclosing under the PRC SDS is currently only voluntary. 

The PRC Sustainability Reporting Guidelines for Listed Companies share many principles with the PRC SDS, including the framework of four pillars and adoption of the double materiality principle. 

The topics covered by the Guidelines go beyond climate-related topics to other issues related to the environment, society and sustainability corporate governance, while the ISSB standards and the PRC SDS currently each include only one set of specific standards focusing on climate-related topics (i.e. IFRS S2 and draft Sustainability Disclosure Standards for Business Enterprises No.1 - Climate (Trial)).

For more details on the PRC SDS, please see our Quick Guide on the PRC Sustainability Disclosure Standards (PRC SDS).

The Guidelines incorporate fundamental principles similar to IFRS S1, including the four pillars as the framework for disclosure, and mandate the disclosure for climate-related physical risks, transition risks, and climate-related opportunities, similar to IFRS S2.

However, as mentioned above, the Guidelines differ from IFRS S2 in several respects in terms of climate-related disclosure. In addition, the Guidelines cover a broader range of topics beyond climate-related issues, which  may challenge the interoperability for reports prepared under the Guidelines with those prepared under the ISSB standards. 

Guidelines

• Guidelines No. 14 of Shanghai Stock Exchange for Self-Regulation of Listed Companies — Sustainability Report (Trial) (in Chinese) (SSE courtesy translation: Translation) 
• Guidelines No. 17 for Self-Regulation of Listed Companies — Sustainability Reporting (Trial) (in Chinese)
• Continuous Supervisory Guidelines No. 11 for Companies Listed on Beijing Stock Exchange — Sustainability Report (Trial) (in Chinese)

Compilation Guides

• Guide No.4 for Self-Regulatory Supervision on Listed Companies of the SSE — Compilation of Sustainable Development Reports (in Chinese)
• Guide No.13 for Self-Regulatory Supervision on Listed Companies of the SSE STAR Market — Compilation of Sustainable Development Reports (in Chinese)
• Self-Regulatory Guidance No. 3 for Companies Listed on Shenzhen Stock Exchange — Preparation of Sustainability Report & Self-Regulatory Guidance No. 3 for Companies Listed on the ChiNext Market of Shenzhen Stock Exchange — Preparation of Sustainability Report (in Chinese)
• Guide for Companies Listed on Beijing Stock Exchange—Preparation of Sustainability Report (in Chinese)

Draft Amendment to the Compilation Guides

• Notice on Soliciting Public Comments on Three New Guides for Listed Companies on Compilation of Sustainable Development Reports (in Chinese) (SSE courtesy translation: Translation) 
• Notice on Soliciting Public Comments for Revising the Self-Regulatory Guidance No. 3 for Companies Listed on Shenzhen Stock Exchange—Preparation of Sustainability Report and the Self-Regulatory Guidance No. 3 for Companies Listed on the ChiNext Market of Shenzhen Stock Exchange—Preparation of Sustainability Report (in Chinese) (SZSE courtesy translation: Translation)
• Notice on Soliciting Public Comments for Revising the Guide for Companies Listed on Beijing Stock Exchange—Preparation of Sustainability Report (in Chinese, BSE courtesy translation included)

• Quick Guide on the PRC Sustainability Disclosure Standards (PRC SDS)
• Quick Guide on the ISSB standards