Hills Sustainability
21 July 2019 Position Paper

ESG Disclosures in Asia Pacific

A Review of ESG Disclosure Regimes for Listed Companies in Selected Markets.

  1. Piotr Zembrowski, CFA
  2. Mary Leung, CFA
  3. Kurt Schacht, JD, CFA
An overview of ESG disclosure regimes in seven Asia-Pacific markets: Australia, China, Hong Kong SAR, India, Japan, Singapore, and Thailand. We show recent trends in ESG disclosures and provide recommendations for regulators, issuers and investors.
ESG Disclosures in Asia Pacific View the full report (PDF)

Our Position

Meaningful, accurate, timely and comprehensive disclosures of material ESG factors by listed companies are essential for financial professionals as part of their analytical and investment decision-making process. Regulators and exchanges should aim to develop ESG disclosure regimes that result in high quality, consistent and comparable disclosures in their markets.

Main Points


  • Volume of ESG disclosures in APAC increases, but quality lags
  • Solid ESG disclosure practices usually take time to develop, but fast progress is possible
  • Disclosure regimes differ widely, in level of obligation, specificity and coverage
  • Reporting obligations follow “race to the top” pattern of tightening, from voluntary, to “comply-or-explain”, to mandatory.
  • Reporting obligations of large companies tend to be stricter and broader than those of smaller ones
  • Governance issues used to dominate, now environmental issues are coming to the forefront
  • Global frameworks are used by some regulators, but the number of different ones adds confusion



For governments, regulators, and stock exchanges

  • Ensure meaningful, accurate, timely, and comprehensive disclosures
  • Work toward harmonisation of global frameworks
  • Articulate benefits of ESG disclosures to issuers
  • Offer guidance and training

For issuers

  • Educate the board and senior executives on relationship of ESG to strategy and risk management and on the importance of ESG reporting
  • Ensure disclosures of relevant and material ESG information

For asset owners and investment managers

  • Demand high quality ESG information from issuers
  • Articulate the effect of material ESG information on company valuation

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