ESG Disclosure Clock No. 1: who must report under ISSB-based rules, and from when

The ESG Disclosure Clock tracks, regime by regime, which companies in emerging markets must publish sustainability disclosures and from which reporting period. This first edition covers the 18 emerging and frontier jurisdictions among the 23 that the IFRS Foundation had profiled on its use-by-jurisdiction page by 24 September, all of which build on the International Sustainability Standards Board's IFRS S1 and IFRS S2, plus the EU's reach into non-EU groups. Dates are the first annual period that must comply. Several profiles are dated 12 June 2025 and may not reflect later changes; the national texts remain binding.

Already in force

• Bangladesh: banks and finance companies regulated by Bangladesh Bank, from financial years starting in January 2024 (profile).
• Türkiye: listed companies, financial institutions and other companies exceeding two of three thresholds (TRY 500 million in assets, TRY 1 billion in sales, 250 staff) in two consecutive periods, from 1 January 2024, with banks in scope regardless of size, according to the oversight authority KGK's guidance.
• Sri Lanka: the 100 largest companies on the Colombo exchange from 1 January 2025, Main Board companies from 2026, other listed companies from 2027, and non-listed companies with turnover above Rs10bn from 2028 (profile).
• Malaysia: Main Market issuers with a market value of MYR2bn or more report on climate from 1 January 2025 and in full from 2027; other Main Market issuers on climate from 2026 and in full from 2028; ACE Market companies and non-listed firms with revenue of MYR2bn or more on climate from 2027 and in full from 2030 (profile).
• Pakistan: listed companies meeting two of three tests (turnover above Rs25bn, more than 1,000 employees, assets above Rs12.5bn) from periods beginning on 1 July 2025; a second cohort at half those levels from 1 July 2026; all other listed companies and licensed public-interest companies from 1 July 2027 (profile).
• Zambia and Tanzania: publicly accountable entities in Zambia, and public interest and public sector entities in Tanzania, from 1 January 2025 (Zambia, Tanzania profiles).
• Rwanda: listed companies and Tier I financial institutions began an initial phase in 2025 and reach the full standards in 2027; utilities and smaller financial institutions reach them in 2028, and other large entities in 2029 (profile).
• Mexico: listed issuers other than financial institutions, states and municipalities, for the 2025 financial year, reported in 2026 (profile).

Starting with 2026 periods

• Philippines: companies listed on the Philippine Stock Exchange with a market value above PHP50bn from 1 January 2026, those between PHP3bn and PHP50bn from 2027, and the rest, plus issuers listing only debt, from 2028 (profile).
• Qatar: listed entities regulated by the QFMA, banks and insurers regulated by the central bank, and Category A firms in the Qatar Financial Centre, from 1 January 2026 (profile).
• Jordan: companies in the ASE20 index must apply the climate requirements to 2026 periods, published in 2027 (profile).
• Brazil: publicly held companies from financial years beginning on 1 January 2026, and the leaders of the largest banking conglomerates (segments S1 and S2) under National Monetary Council and central bank rules on the same date; the profile carries a caveat that CVM Resolution 244 of 29 May 2026 altered parts of the regime (profile).

2027 and later

• Kenya: public interest entities, including all listed companies, from 1 January 2027; large private companies from 2028; small and medium-sized firms from 2029 (profile).
• Ghana: listed companies, banks, insurers, public limited companies and named sectors such as upstream oil and gas, mining, cement and non-renewable power generation from 1 January 2027; most other companies from 2028 (profile).
• Chile: entities supervised by the Financial Market Commission for periods starting in 2027, reported in 2028, a year later than first planned (profile, updated 8 September).
• Nigeria: public interest entities, including listed companies, from 1 January 2028; small and medium-sized entities from 2030 (profile).
• Zimbabwe: listed companies, state enterprises and high environmental impact entities from 1 January 2028, with full compliance by 2031; a second category from 2029 and a third from 2030 (profile, updated 24 September).
• EU reach: the CSRD's chapter on third-country undertakings applies to financial years from 1 January 2028 (Directive (EU) 2022/2464). Since February it catches only groups with EU turnover above EUR 450 million in each of the last two years, through EU subsidiaries or branches with turnover above EUR 200 million, under Directive (EU) 2026/470.

On these profiles, the next 1 January brings first mandatory periods in Kenya, Ghana, Chile and for the second Philippine tier, and full ISSB reporting for Malaysia's largest issuers and Rwanda's first group. Corrections and new profiles go into the next edition.