"FSC Underestimates Korean
Companies' Climate Disclosure Capabilities"
- Some 700 companies already disclosing
through CDP — far more than the FSC's 58 mandatory targets
- Of the 292 companies analyzed in the
‘2025 CDP Korea Report’, 77% (222) calculate and report Scope 3
- CDP Korea Committee: "Disclosure
roadmap must be redesigned to reflect real climate disclosure capacity"
- 'CDP Korea Conference 2026,' featuring
the CDP awards ceremony and exploring the transition, to be held on the 10th
As the Financial Services Commission (FSC)
unveiled a draft "ESG Mandatory Disclosure Roadmap" on the 25th that
severely limits the scope of mandatory climate disclosure—citing corporate
burden and insufficient response capacity—new figures suggest that Korean
companies' actual readiness for climate disclosure far exceeds the government's
assessment.
On February 25, the FSC announced a highly
conservative draft roadmap that sets Korea's first mandatory ESG (climate)
disclosure for "KOSPI-listed companies with assets of KRW 30 trillion or
more" beginning in 2028 (FY27), with Scope 3 disclosure deferred a further
three years to 2031. In practice, the KOSPI-listed companies with assets of KRW
30 trillion or more number just 58. The plan fully reflects industry arguments
that point to the distinctive nature of Korea's manufacturing- and export-driven
economy and to insufficient climate response capacity.
The CDP Korea Committee (secretariat: Korea Sustainability Investment Forum, KoSIF), however, revealed in its 2025 CDP Korea Report, published on the 9th, that some 700 Korean companies have voluntarily disclosed climate information even in the absence of any legal obligation. That figure far exceeds the 58 companies designated as the first mandatory targets under the FSC roadmap.
In particular, the number of companies reporting value-chain-wide emissions (Scope 3)—widely regarded as difficult to calculate—surged from 127 in 2023 to 222 in 2025 (76% of those analyzed) in just two years. On average, these companies have already completed calculation and reporting for 8 of the 15 Scope 3 categories—more than half. Da-yeon Lee, Director of the ESG Management Division at KoSIF, explained: "Contrary to the FSC's judgment, which deferred Scope 3 disclosure to 2031 on the grounds of technical limitations and infrastructure, Korea's major companies are already operating systems capable of identifying and managing more than half of their value-chain emission sources."
As a result, criticism that the FSC's draft
roadmap underestimated Korean companies' climate disclosure capabilities is
expected to intensify. Calls are also likely to grow louder for the final
roadmap—to be confirmed in April—to reflect companies' actual capacity by
expanding the scope of initial application and redesigning disclosure standards
to meet global requirements.
CDP is a global, finance-led international
initiative that requests environmental disclosure from the world's major
companies—covering issues such as climate change, water, forests, biodiversity,
and plastics—and incorporates that information into financial activity.
Notably, the climate disclosure standard (S2) of the International
Sustainability Standards Board (ISSB)—one of the international sustainability
disclosure standards Korea has adopted—was built on CDP's framework, and the
information it requires is similarly structured. Disclosure through CDP is
therefore regarded as a response to mandatory global climate disclosure.
Ji-in Jang, Chair of the CDP Korea
Committee, emphasized: "CDP was introduced in earnest in Korea in 2008,
and our companies have steadily built up climate disclosure capabilities in the
process of responding to demands from investors and customers. The FSC's ESG
Mandatory Disclosure Roadmap must be carefully redesigned to fully account for
this reality and to ensure that climate disclosure connects to climate
finance."
Sherry Madera, CEO of CDP, said:
"Environmental disclosure is now core business data in itself,"
adding that "the disclosure decisions made today will determine tomorrow's
competitive advantage."
According to the report, the third-party
verification rate—directly tied to the reliability of greenhouse gas emissions
data—reached 91%, far surpassing the global average of 67%. Climate
performance, however, was found to need improvement. In the Scope 3 domain in
particular—which accounts for 90% of the total emissions of the companies
analyzed—only 15% had set reduction targets, and progress toward those targets
actually showed emissions increasing: -15% in the short term and -6% in the
long term, a state of "reverse gear." This points to the policy
challenge of converting accumulated climate disclosure experience into genuine
emissions reductions—including the swift mandating of Scope 3 emissions
disclosure.
Structural barriers to the energy
transition also persisted. Renewable energy accounted for just 3.07% of the
analyzed companies' total energy consumption, while self-generated renewable
power was a mere 0.20%. Among Korean RE100 members, the domestic implementation
rate (9.7%) was lower than that of overseas operations (16.8%), clearly
reflecting the constraints of Korea's domestic procurement environment.
Meanwhile, this year's top performers—the
2025 Korea Leaders—were also announced. The Carbon Management Honors Club,
comprising companies that earned a Leadership A grade or higher and completed
third-party verification, includes KT&G, Hyundai Wia, Hyundai Motor
Company, IBK (Industrial Bank of Korea), and LG Uplus. SK hynix, Samsung
Electro-Mechanics, Samsung C&T, Shinhan Financial Group, and Hyundai
E&C have maintained their place in the Climate Change Hall of Fame
(Platinum Club) for several consecutive years. Hyundai Motor Company won the
grand prize in the water security category.
KoSIF, secretariat of the CDP Korea Committee, will host the CDP Korea Conference 2026 (CKC 2026)—which seeks practical solutions for the transition and includes the CDP awards ceremony—on Tuesday the 10th, beginning at 10 a.m. at the Pullman Ambassador Seoul Hotel. (End)