Taiwan's Climate Disclosure Rules: What You Need to Know

Taiwan climate disclosure at a glance

Taiwan's Financial Supervisory Commission (FSC) amended its annual report regulations on 7 November 2025 and endorsed IFRS S1 and IFRS S2 on 12 November 2025, so every company listed on the Taiwan Stock Exchange or the Taipei Exchange publishes a sustainability chapter in its annual report, phased by paid-in capital, starting with companies of NT$10 billion or more that report on financial year 2026 and file in 2027. On 23 September 2026 the FSC and the Ministry of Environment announced a narrower mandatory scope of 560 companies, with rule amendments due by the end of 2026; Taiwan applies the ISSB standards as issued, with limited assurance on Scope 1 and 2 emissions from the first report.

How Taiwan got here

The FSC's Sustainable Development Roadmap (2022) phased in greenhouse gas inventories and assurance by company size, starting with parent-company Scope 1 and 2 inventories for financial year 2022 at companies with NT$10 billion or more in paid-in capital and in steel and cement. On 17 August 2023 the FSC published its roadmap for listed companies to align with the IFRS Sustainability Disclosure Standards. In 2024 the Taiwan Stock Exchange required every listed company to publish a sustainability report from 2025, covering financial year 2024. The November 2025 amendments moved climate disclosure into the annual report itself, filed alongside the financial statements.

What Taiwan's climate disclosure rules require

In-scope companies include a dedicated chapter titled "Sustainability-related Financial Information" in their annual report, prepared under IFRS S1 and IFRS S2 as endorsed by the FSC and approved by the board of directors.

• IFRS S1 (General Requirements): material sustainability-related risks and opportunities that could reasonably be expected to affect cash flows, access to finance or cost of capital, structured on the four pillars of governance, strategy, risk management, and metrics and targets. The reporting entity, reporting period, data and assumptions match the financial statements. In the first year a company reports climate-related information only and skips prior-year comparatives.

• IFRS S2 (Climate-related Disclosures): climate-related transition and physical risks, scenario analysis, industry-based metrics, and Scope 1, Scope 2 and Scope 3 emissions. The FSC extended the standard's one-year Scope 3 relief to three years, citing supplier readiness and the GHG Protocol revision expected in 2027.

• The GHG Protocol as the measurement standard: IFRS S2 paragraph 29(a)(ii) requires the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004). The FSC requires listed companies to use it for every emission source outside those the Ministry of Environment already regulates, with the standard's first-year option to keep another method.

Scope 1 and Scope 2 emissions receive independent third-party limited assurance from the first report, at the consolidated group level. The chapter is filed with the annual financial statements: Phase 1 companies file by 16 March 2027. The FSC announced on 23 September 2026 that, for the first two reporting years, companies that cannot file the chapter in March can file it with the annual report, 14 days before the shareholders' meeting.

Who is in scope

Every company listed on TWSE or TPEx falls under the rule, phased by paid-in capital at the end of the reporting year, and foreign companies listed in Taiwan follow the same requirements.

Phases under the current rule

• Phase 1: paid-in capital of NT$10 billion or more. Financial year 2026, filed in 2027.

• Phase 2: NT$5 billion to under NT$10 billion. Financial year 2027, filed in 2028.

• Phase 3: under NT$5 billion. Financial year 2028, filed in 2029.

The September 2026 adjustment (announced)

The FSC and the Ministry of Environment announced that the full standards apply to listed companies with paid-in capital of NT$2 billion or more, plus companies below NT$2 billion that the Ministry requires to register and verify their greenhouse gas inventories. That gives 126 companies in Phase 1, 118 in Phase 2 and 316 in Phase 3. The other 1,410 listed companies publish basic climate information: climate governance, risk management, and Scope 1 and 2 emissions. Phase 3 companies get two climate-only years and report Scope 3 voluntarily. Phase 2 and 3 companies drop the separate parent-company assurance and keep consolidated assurance. The FSC plans to amend the annual report regulations and related orders by the end of 2026 and to review scope and reliefs again in 2030.

Supply-chain reach: Phase 1 companies add Scope 3 for financial year 2029 and Phase 2 companies for 2030, so their suppliers in Taiwan and abroad receive emissions data requests during the relief period.

Note on financial institutions: banks, insurers and securities and futures firms follow the FSC's Green and Transition Finance Action Plan at every size, and steel and cement companies keep the original roadmap's inventory and assurance dates.

Key dates and milestones

Phase 1 and Phase 2 companies report sustainability topics beyond climate from their second reporting year. Reasonable assurance and Scope 3 assurance: not specified in the rule.

Why this matters beyond Taiwan

1. Supply-chain ripple across Asia and beyond. From financial year 2029, Phase 1 groups in semiconductors, electronics, petrochemicals and textiles add Scope 3, which turns their purchased goods, logistics and outsourced manufacturing into supplier emissions data requests across Southeast Asia, mainland China, Japan and the United States. Their customers gain assured Scope 1 and 2 figures for their own Scope 3 inventories.

2. Regional convergence on the ISSB baseline. Taiwan applies IFRS S1 and IFRS S2 as issued, so a group with entities in Japan, South Korea, Singapore, Hong Kong or Australia can build one IFRS S2-aligned inventory and reuse it. The September 2026 adjustment cites the EU's Omnibus I scope reduction and the size-based phasing in Japan and South Korea.

3. Two regulators, one dataset. The Ministry of Environment's inventory registration and verification list now decides mandatory scope for smaller companies. The FSC and the Ministry plan to align greenhouse gas verification with accountant assurance to remove duplicated work, and to expand the national product carbon footprint emission factor database to lower the cost of Scope 3 data.

How companies should prepare

Phase 1 companies are ten months into their first reporting year, and their first chapter goes to an assurance provider and the board before the March 2027 filing.

• Establish your greenhouse gas inventory on the GHG Protocol. Companies that built parent-company inventories under the 2022 roadmap now report a consolidated corporate carbon footprint for the same group as the financial statements, measured on the GHG Protocol.

• Map your value-chain exposure to Taiwanese reporters. The three-year Scope 3 relief is the window to identify your material categories and collect supplier data. If your customers are Taiwanese listed groups, their Scope 3 numbers include you from 2029.

• Build assurance-ready processes early. Limited assurance applies from the first report, on a March deadline shared with the financial statements. Methodology documentation, source-data traceability and review controls run during measurement, so every figure answers the auditor's question: where did this number come from?

• Build on the frameworks you already use. The four pillars carry over from existing TCFD-based climate disclosures, GRI sustainability reports and CDP responses. The new work is the consolidated boundary, scenario analysis and industry-based metrics, with board approval of the climate report.

How Terrascope can help

Terrascope's AI-powered platform helps companies across Asia-Pacific move from baseline emissions data to audit-ready disclosures, including Dyno Nobel, which achieved limited assurance over 1.6 million tonnes of Scope 1 and 2 emissions across five continents a full year ahead of Australia's reporting deadline.

• Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, so your consolidated inventory stays current across every subsidiary and builds the Scope 3 categories you need before the relief ends.

• Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in, so your limited assurance engagement runs on evidence that is already in place.

• Supply-chain intelligence. Analytics shows where your Scope 3 hotspots sit and which suppliers drive them, so the three-year relief becomes reduction planning time.

• Multi-framework alignment. ISSB Reporting drafts your IFRS S1 and IFRS S2 disclosures from your measured data, reviewed by your team, ready for board approval and the annual report chapter.

Frequently asked questions

Speak to an expert

Are you ready to get ahead of Taiwan's IFRS S1 and IFRS S2 requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.