ESG Roadmap Announcement Delayed from Early This Month... Diverging Views on Timing and Scope

Timing and Scope of Mandatory Disclosure Remain Unclear
Early Adoption by Ministries vs. Corporate Readiness
Concerns Over "Undermining Policy Credibility"

The announcement of the ESG (Environmental, Social, and Governance) disclosure roadmap, originally scheduled for early this month, has been postponed due to disagreements among related ministries. While the Ministry of Climate, Energy and Environment, which is responsible for responding to the climate crisis, is pushing for early adoption, the Ministry of Trade, Industry and Energy and the Financial Services Commission argue that companies need sufficient preparation time, taking into account their ability to adapt.

According to interviews with the Ministry of Climate, Energy and Environment, Korea Exchange, and other related organizations on February 3, the Financial Services Commission had initially planned to release the ESG disclosure roadmap in early February. However, it decided to delay the announcement, citing the need for coordination among ministries. The exact date for the roadmap release has not yet been determined. The Financial Services Commission is aiming to announce the roadmap within the first quarter of this year, and the matter was also included in the presidential work report conducted in December 2025. An official from the Ministry of Climate, Energy and Environment stated, "The schedule, which initially targeted an announcement in early February, has been changed," adding, "The Financial Services Commission is coordinating the details to be included in the roadmap through discussions with related ministries such as the Ministry of Trade, Industry and Energy."

Previously, in its 2021 ESG disclosure roadmap, the Financial Services Commission had announced plans to gradually mandate ESG disclosures starting in 2025. However, in October 2023, considering the ESG disclosure timelines of major countries, it postponed the mandatory implementation to after 2026, stating that the specific implementation date would be determined through consultations with related ministries. To this end, the Financial Services Commission conducted a stakeholder feedback process from May to August 2024, targeting business groups and institutional investors. At that time, companies generally agreed on the need for climate-related disclosures but expressed concerns about the scope of disclosure, the level of greenhouse gas emissions calculation, the increased disclosure burden, and potential litigation risks following disclosure.

The timing for mandatory ESG disclosures remains uncertain. This is due to ongoing disagreements among ministries. The Ministry of Climate, Energy and Environment maintains that early adoption of the disclosure system is necessary for responding to the climate crisis and for international cooperation. In contrast, the Ministry of Trade, Industry and Energy and the Financial Services Commission both emphasize the need to allow companies enough time to establish proper disclosure systems. In particular, the business community has consistently argued that the introduction of the roadmap should be delayed so that companies have time to improve their internal data management and disclosure systems.

An official from the Korea Listed Companies Association stated, "The core of the roadmap is not 'when,' but 'what will be disclosed,'" adding, "Currently, the specific contents and application methods of the disclosure are still being discussed in general terms, and there is a consensus among both the industrial sector and the financial authorities that companies should be given sufficient preparation time."

The main issues currently under discussion are the timing of the disclosure introduction and the scope of companies subject to it. If the Financial Services Commission decides to accelerate the introduction, it is considering selecting one of the years 2027, 2028, or 2029, with a strong possibility of reducing the number of companies required to disclose. Conversely, if the introduction is delayed, expanding the scope of companies subject to disclosure is being discussed. The disclosure method itself has not been finalized either. There are ongoing discussions on whether the disclosure should be a statutory disclosure or a disclosure to the Financial Supervisory Service.

As the announcement of the roadmap continues to be delayed, concerns among global institutional investors are growing. The Asia Investor Group on Climate Change (AIGCC) has pointed out that repeated delays in the announcement of Korea's ESG disclosure roadmap could undermine policy credibility. Previously, in November 2024, the AIGCC, which has more than 70 member countries including sovereign wealth funds, sent an open letter to the Financial Services Commission of Korea together with global asset management firms, urging the swift finalization and announcement of the mandatory ESG disclosure roadmap. An AIGCC official noted, "The announcement was initially mentioned for the end of 2024, then pushed to the first half of 2025, then again to the end of 2025, and nothing has been finalized yet," highlighting the ongoing policy uncertainty.