5 Nov, 2025

September 2025 – Nature risk financial disclosures, California climate guidelines, Thailand consultation on ISSB adoption

Regulation is shaping the sustainability agenda and changing the way companies do business in different jurisdictions, but keeping pace with constant regulatory updates has become a mammoth task for businesses and investors. In this recurring series, S&P Global Sustainable1 presents key developments to sustainability regulations and standards from around the world.

In this month's update, we look at the Taskforce on Nature-related Financial Disclosures’ new guidelines for listed companies, guidance from California’s regulator on how companies should report climate disclosures and Thailand’s consultation on adoption of sustainability-related standards aligned with those of the International Sustainability Standards Board.

INTERNATIONAL

Parties ratify international treaty on marine biodiversity protection

The UN on Sept. 19 announced that an international treaty to protect marine biodiversity will enter into force now that it has received the required number of 60 ratifications from states. The agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction, or BBNJ Agreement, was adopted in June 2023 and is a legal instrument to protect marine life and ecosystems in the two-thirds of the ocean that lie beyond any country’s jurisdictions. The treaty allows nations to establish marine protected areas as a tool to help conservation, improve coordination between countries, preserve biodiversity and support developing countries. It also requires jurisdictions to develop standards and guidelines for conducting environmental impact assessments for economic activities in international seas. The treaty will come into force in January 2026.

TNFD releases guidance on nature-related financial disclosures

The Taskforce on Nature-related Financial Disclosures (TNFD), together with the Sustainable Stock Exchanges Initiative, on Sept. 30 published guidance on nature-related financial disclosures for stock exchanges and listed companies to help them identify, assess and disclose nature-related financial risks and opportunities. The guidance sets out the business case and key principles for disclosure. It also includes information on how stock exchanges and companies can align their practices with frameworks and guidance that support nature-related disclosures. It also steers exchanges and companies in how to implement processes to manage nature-related topics.

EUROPE

EU lawmakers adopt new rules to reduce textile and food waste

The European Parliament on Sept. 9 adopted new rules to prevent and reduce waste from food and textiles in the EU. The rules amend existing rules on waste and introduce binding food waste reduction targets. EU member states will be required to reduce food waste from processing and manufacturing by 10% compared to the annual average of food waste between 2021 and 2023. They will have to reduce the amount of food waste generated by retail, restaurants, food services and households by 30% per capita compared to the annual average between 2021 and 2023. Member states will be required to set up new extended producer responsibility (EPR), designed to make producers responsible for the full life cycle of their goods. EU and non-EU textile producers that make products available in the EU will have to cover the costs of their collection, sorting and recycling within 30 months of the new rules’ entry into force. The Council of the EU, composed of government ministers of the 27 EU member states, adopted the measures in June. The rules were published in the EU Official Journal on Sept. 26. EU countries have 20 months to incorporate the rules into national legislation.
 

European Commission publishes guidance on applying sustainable finance rules to the defense sector  

The European Commission on Sept. 15 published guidance for companies on how they should apply the EU’s sustainable finance framework and regulation like the Corporate Sustainability Due Diligence Directive (CSDDD) to the defense sector. It said due diligence requirements under the CSDDD do not extend to the activities of companies’ downstream business partners related to military products when the authorities of EU member states have authorized their export. The document also clarifies that the Sustainable Finance Disclosure Regulation covers the disclosure of four categories of controversial weapons, including biological weapons, chemical weapons, cluster munitions and anti-personnel mines and is in line with international conventions on prohibiting controversial weapons. The Commission also said companies operating in the defense sector can claim alignment with the EU Taxonomy for sustainable activities through investments in carbon-neutral transport and buildings.
 

UK regulator proposes amendments to sustainability-related reporting requirements

The Financial Conduct Authority on Sept. 10 proposed amendments to the UK’s Sustainability Disclosure Requirements (SDR) clarifying how investment firms may apply the rules and giving them more flexibility on publishing sustainability reports. The SDR is a disclosure framework for investment firms that has been phased in in the UK since 2024. Under the amendments, managers of index-tracking funds would be allowed to invest in assets according to an evidence-based standard that measures the sustainability of the asset. Under the current rule, managers are required to select assets, and the FCA said it had received feedback that the rule is challenging for index-tracking funds as fund managers do not select assets. The proposals would also allow investment firms to publish sustainability reports on specific products for a reporting period of less than 12 months, or for a time period during which neither a sustainability label nor sustainability terms were used. Under the current rule, investment firms are required to cover a reporting period of 12 months and to publish the report within 16 months after the manager first uses a sustainability label or sustainability-related term.

ASIA-PACIFIC

Chinese stock exchanges propose amendments to sustainability reporting guidelines

Shanghai Stock Exchange, Shenzhen Stock Exchange and Beijing Stock Exchange on Sept. 5 proposed amendments to their sustainability reporting guidelines, which would expand sustainability disclosures by certain listed companies to cover emissions related to pollution as well as energy and water use. Companies would be required to evaluate the risks and opportunities to their business from pollution-related emissions, including potential decline in revenues due to capacity constraints resulting from pollution control. They would be required to disclose risks and opportunities related to energy, such as material risks from a change in their energy mix from coal to gas, for example. In terms of water use, they would need to disclose on the impacts of asset values from drought or the risks of water contamination, among others.

Hong Kong financial regulator proposes updates to sustainable finance taxonomy

The Hong Kong Monetary Authority on Sept. 8 proposed expanding its sustainable finance taxonomy to include more sectors, adaptation objectives and transition measures. The proposals seek to expand the number of sectors covered in the taxonomy from four to six and would include manufacturing and information and communications technology. They would also add 13 new economic activities, bringing the total number of economic to 25. The enhanced taxonomy would include measures to support companies in the energy transition, including interim decarbonization targets. The regulator also said the proposed updates would include a new environmental objective, climate change adaptation, to address the financial costs related to physical risks and respond to the increasing frequency of extreme weather events.

Australian standard setter issues guidance on GHG disclosure requirements

The Australian Accounting Standards Board on Sept. 2 published guidelines on how companies should disclose their greenhouse gas emissions, according to the board’s climate-related disclosure standard, which is based on global sustainability standards. The guidance explains what steps companies need to take to meet requirements for disclosing material information about Scope 1, 2 and 3 emissions. It also underlines that companies are required to use both the GHG Protocol Corporate Standard for reporting Scope 1, 2 and 3 emissions and the GHG Protocol Corporate Value Chain Standard, which is only for Scope 3 emission disclosure. 
 

New Zealand standard setter proposes amendments on climate disclosures

New Zealand’s External Reporting Board (XRB), which establishes financial reporting standards, on Sept. 3 proposed amendments to its climate and assurance standards. 

The standard setter’s proposals include extending the exemption period for disclosure on Scope 3 emissions, which are those that occur up and down a company’s value chain. Companies would be permitted to start reporting on Scope 3 emissions four years after they start disclosing according to New Zealand’s climate standard. Currently they may start reporting Scope 3 emissions two years after they begin their disclosures. Furthermore, the XRB proposed to extend by two years an exemption on disclosing Scope 3 emissions from assurance to Dec. 31, 2027, from Dec. 31, 2025, currently.

Thailand’s securities regulator holds consultation on ISSB adoption

Thailand’s Securities and Exchange Commission on Sept. 22 launched a consultation on adoption of the International Sustainability Standards Board’s two sustainability-related disclosure standards. Under the proposals, companies listed on the Thailand's SET50 index, which includes the country’s 50 companies with the largest market capitalizations, would start reporting in 2027. Companies listed on the SET100 index would start reporting in 2028, while other listed companies would begin reporting in 2030. Real estate trusts and infrastructure funds would start reporting in 2031. For the first year of reporting, companies would be exempt from reporting on Scope 3 emissions and would only have to report on climate-related disclosures for the first year of reporting, according to the proposals. Companies would also have to disclose Scope 1 and Scope 2 emissions using the Greenhouse Gas Protocol or other international standards, the regulator said. It also said companies should provide limited assurance of emissions disclosures according to standards developed by the International Auditing and Assurance Standards Board or other international recognized assurance standards.

UNITED STATES AND CANADA 

California regulator issues guidance on climate-related risk disclosure rule 

The California Air Resources Board (CARB) on Sept. 2 issued further guidance on how companies should implement the state’s climate-related financial risk disclosure rule, requiring businesses operating in the state with more than $500 million in revenues to biennially disclose their climate-related financial risks and impacts as of Jan. 1, 2026. The guidance includes minimum requirements for disclosure. Companies subject to the rules may use one of three existing frameworks — the Task Force on Climate-related Financial Disclosures (TCFD), IFRS S2 Climate-related disclosures, or with a framework aligned with another regulated exchange, national government or other governmental entity — to prepare their disclosure reports. CARB also said companies would not be initially required to report on Scope 1, 2 and 3 emissions following stakeholder feedback about the challenges in gathering emissions data. The regulator also said it will open a public docket from Dec. 1, 2025, to July 1, 2026, for companies subject to the rule to post a publicly available link to their initial climate-related financial risk report. CARB on Sept. 24 also published a preliminary list of more than 4,000 entities that would be subject to the rules. The list does not reflect potential exemptions and includes active filings through 2022. CARB is seeking stakeholder feedback on the list.

This piece was published by S&P Global Sustainable1 and not by S&P Global Ratings, which is a separately managed division of S&P Global.

This list is not exhaustive, and information is current as of the publication date. If there are additional significant regulatory developments we should cover going forward, please reach out to Jennifer Laidlaw at jennifer.laidlaw@spglobal.com. We welcome feedback.

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