Situation

Sustainability and CBAM reporting

Almost nobody in this region starts this work voluntarily. It arrives as a procurement questionnaire from a European customer, a contract clause, or a listing rule with a date attached. Then it becomes finance’s problem, because it is a disclosure, controls and assurance problem wearing an environmental coat.

Two separate pressures are worth telling apart. Local listing rules — Singapore and Malaysia from FY2025, Australia’s first group from January 2025, Taiwan from FY2026, Japan’s largest issuers for years ending March 2027 — put ISSB-based climate disclosure on a published timetable. Quite separately, exporters of steel, aluminium, cement, fertiliser, hydrogen or electricity into the EU now sit inside CBAM, whose definitive regime began on 1 January 2026 and which needs embedded emissions calculated at installation level, per production route. That is a plant-level measurement job, not a corporate reporting one, and the two are routinely confused.

On the CSRD question specifically: the 2026 Omnibus package cut the scope sharply, to EU companies above 1,000 employees and €450m turnover, with first reports in 2028. It also capped what those companies may demand from suppliers under 1,000 employees. If you are below that line, the honest answer is that you owe far less than the questionnaire in your inbox implies — and knowing that is worth money.