The Corporate Sustainability Disclosure Standard No. 1 – Climate (Trial) was jointly released on December 19, 2025, by nine central government agencies, including the Ministry of Finance and the Ministry of Ecology and Environment.
The standard is based on the ISSB's IFRS S2 Climate-related Disclosures, and although it uses the same fundamental framework—governance, strategy, risk and opportunity management, measurements, and targets—the particular disclosure criteria have been modified to take China's unique circumstances into account.
The standard makes it clear that businesses may choose to voluntarily embrace it before the requirements and scope of implementation are established. China is anticipated to broaden the scope of application over time, moving from voluntary to required disclosure, from large firms to SMEs, and from listed to non-listed corporations.
Key Contents
Governance, strategy, risk and opportunity management, and measurements and targets are the four areas in which the standard establishes requirements.
Section I: Governance
The disclosure goals and specifications for climate-related governance are outlined in this section, including:
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Authorities or people in charge
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Information about management
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Integrated governance information disclosure
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Requirements for third-party assurance disclosure
Section II: Approach
This section outlines the disclosure goals for climate-related strategies and mandates that businesses reveal:
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Details on the hazards and opportunities associated with climate change
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How such considerations affect company strategy and decision‑making
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Financial effects, both present and anticipated
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Evaluations of climate resilience
Section III: Opportunity and Risk Management
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Disclosure goals for managing climate-related risks and opportunities are outlined in this section and include:
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How businesses recognize, evaluate, and handle climate-related risks and opportunities
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The degree to which these processes are integrated into overall risk management
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Requirements for related disclosure
Section IV: Metrics and Targets
This section details:
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Overall industry metrics
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Metrics unique to a given industry
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Climate-related objectives
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Methods for determining greenhouse gas emissions
Differences from IFRS S2
Although the Chinese standard matches closely with IFRS S2 in terms of the underlying framework, numerous important variances exist.
Impact on Climate: Additional Disclosure Requirement
The Chinese standard mandates disclosure of how a company's operations affect the climate, even while IFRS S2 concentrates on the effects of climate-related risks on a company's financial situation.
Adjustments to Disclosure Content
GHG calculation methodologies:
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While the Chinese standard stresses adhering to calculating rules and recommendations produced or recognized by Chinese authorities, IFRS S2 advises adopting the GHG Protocol.
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Transactions involving carbon allowances: The Chinese standard includes disclosure requirements for the exchange and payment of carbon emission allowances.
Treatment of Scope 3 Emissions
A first-year exemption for Scope 3 disclosure is offered by IFRS S2.
The Chinese standard does not include such an exemption. Nonetheless, a business may reveal its greenhouse gas management strategy if it is unable to compute Scope 3 emissions in spite of reasonable attempts.
Plans for Future Implementation
A spokesman of the Ministry of Finance's Accounting Department outlined the future implementation strategy at a news conference:
Until the implementation scope and standards are established, businesses are free to adopt the climate disclosure standard, which is now positioned as a trial document.
In the future, the government intends to:
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Implement the standard on a pilot basis
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Expand the scope gradually from large corporations to SMEs, from listed to non-listed organizations, from qualitative to quantitative requirements, and from optional to required disclosure.
