China releases Climate-related Sustainability Disclosure Standard (Trial)
Climate-related disclosure continues to gain regulatory momentum across major economies. In this context, China has taken another step in building a structured sustainability reporting system by introducing a dedicated climate disclosure standard. The document forms part of a broader framework for corporate sustainability disclosure and provides insight into the direction of future climate-related reporting requirements in the Chinese market.
On 25 December 2025, the Accounting Department of the Ministry of Finance of the People’s Republic of China released Notice Cai Kuai [2025] No. 34 on the issuance of the Corporate Sustainability Disclosure Standard No. 1 – Climate (Trial). The notice states that, before implementation scope and implementation requirements are formally prescribed, enterprises are to apply the Standard on a voluntary basis. The document is dated 19 December 2025 and records joint development by the Ministry of Finance together with other relevant central government ministries and financial regulatory authorities.
Disclosure objective
Formulated in accordance with the Corporate Sustainability Disclosure Standards – Basic Standard (Trial), the Climate Standard regulates the disclosure of climate-related risks, opportunities and impacts and aims to safeguard the quality of sustainability information. The disclosure objective is defined as providing material climate-related information to investors, creditors, the government and its relevant departments, and other stakeholders, in order to support economic decision-making, resource allocation and other related decisions.
Core disclosure framework
The Standard adopts a disclosure structure based on Governance, Strategy, Risk and Opportunity Management, and Metrics and Targets. In its official questions-and-answers document, the Accounting Department describes this structure as a “four pillars plus impacts” approach. In addition to disclosures under the four pillars, enterprises are required to disclose material climate-related impact information that is not covered by those sections.
Where climate-related impact information is disclosed through other channels, such as disclosures required by law on environmental information, the information should remain consistent. Climate-related impact disclosures should not obscure or blur disclosures on climate-related risks and opportunities, and the two categories of information should be clearly distinguishable.
When preparing disclosures, enterprises are required to use reasonable and supportable information that is available without undue cost or effort. This requirement applies to the identification of climate-related risks, opportunities and impacts that may affect enterprise prospects, to the preparation of information on expected financial effects and climate-related impacts, and to key assumptions used in climate-related scenario analysis. The Standard also sets out requirements for Scope 3 GHG emissions measurement and requires disclosure of the amount and proportion of assets or business activities exposed to climate-related physical risks, climate-related transition risks and climate-related opportunities.
International convergence and technical references
According to the official explanations, the drafting approach combines international convergence with China-specific considerations. The Accounting Department states that the Climate Standard is aligned in structure with international sustainability disclosure standards and that its requirements on climate-related risks and opportunities are overall aligned with IFRS S2 Climate-related Disclosures.
China-specific considerations reflected in the Standard include requirements on climate-related impact disclosure, the basis for greenhouse gas accounting, the impact of carbon emissions trading on financial statements, enterprise innovation measures for addressing climate change, and scenario assumptions linked to nationally determined contributions.
In terms of technical references, the Standard refers to the Greenhouse Gas Protocol (GHG Protocol) developed by the World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD). For global warming potential values, enterprises are required to use values stipulated by relevant national authorities and may refer to the most recent assessment available at the reporting date, issued by the Intergovernmental Panel on Climate Change (IPCC), when converting emissions into carbon dioxide equivalents.
Implementation and planned guidance
The Accounting Department emphasises that the Climate Standard is issued on a trial basis and that standard setting is separated from implementation requirements. At the current stage, there is no uniform mandatory application requirement. Prior to the formal determination of implementation scope and requirements, application of the Standard remains voluntary.
The official explanations describe a gradual implementation pathway that progresses from pilot application to broader adoption, from listed companies to non-listed companies, from large enterprises to small and medium-sized enterprises, from primarily qualitative requirements to more quantitative requirements, and from voluntary disclosure to mandatory disclosure.
To support application, the Accounting Department states that industry-specific application guidance is being developed for sectors including power, steel, coal, oil, fertiliser, aluminium, hydrogen, cement and automotive manufacturing. Following issuance, this guidance is intended to form an application system consisting of the Basic Standard, Specific Standards and Industry Application Guidance.
