--- title: China's Corporate Sustainability Disclosure Standards (CSDS) 2026 description: "China's CSDS: what has applied since 30 April 2026, which issuers are in scope, and how the standards map to the ESRS datapoints European groups already report." image: https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/38185587.jpg --- [Skip to content](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#main-content) [![Fiegenbaum Solutions Logo](https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg) ![Fiegenbaum Solutions Logo](https://www.fiegenbaum.solutions/hubfs/Branding/Fiegenbaum-Solutions_Logo.svg)](https://www.fiegenbaum.solutions/en/?hsLang=en) - [English](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies) - [Deutsch](https://www.fiegenbaum.solutions/blog/china-steigt-ein-was-die-neuen-esg-vorgaben-fuer-europaeische-unternehmen-bedeuten) - Services - [Climate Risk Assessment](https://www.fiegenbaum.solutions/en/climate-risk-analysis-for-companies) - [VSME Report](https://www.fiegenbaum.solutions/en/vsme-reporting-for-smes) - [ESG Due Diligence VCs & Series A+](https://www.fiegenbaum.solutions/en/esg-due-diligence-vcs-series-a-startups) - [Corporate Carbon Footprint](https://www.fiegenbaum.solutions/en/company-carbon-footprint-methods-tools-best-practice) - Tools - [Scope 3 Quick-Check](https://www.fiegenbaum.solutions/en/scope-3-quick-check) - [ESG Investment Quick-Check](https://www.fiegenbaum.solutions/en/esg-investment-quick-check) - [CSRD Materiality Screening](https://www.fiegenbaum.solutions/en/csrd-materiality-screening) - [Pricing](https://www.fiegenbaum.solutions/en/esg-climate-consulting-fixed-prices-carbon-footprint-vsme-due-diligence-climate-risk) - [About me](https://www.fiegenbaum.solutions/en/about-me) - [Blog](https://www.fiegenbaum.solutions/en/blog) - [Contact](https://www.fiegenbaum.solutions/en/contact) ###### 13 min read # China's Corporate Sustainability Disclosure Standards (CSDS): What Applies from 30 April 2026 By: [Johannes Fiegenbaum](https://www.fiegenbaum.solutions/en/blog/author/johannes-fiegenbaum) on 7/4/25, 3:41 PM · Last updated October 5, 2026 [Supply Chain & EUDR](https://www.fiegenbaum.solutions/en/blog/tag/supply-chain-eudr) [Climate Policy & Green Claims](https://www.fiegenbaum.solutions/en/blog/tag/climate-policy-green-claims) ![Shanghai skyline with the Oriental Pearl Tower seen across the river](https://www.fiegenbaum.solutions/hubfs/pexels-cluster-images/38185587.jpg) **Status: October 2026.** China's Ministry of Finance has finalised the basic standard of its Corporate Sustainability Disclosure Standards (CSDS). The first mandatory reports, covering financial year 2025, were due on 30 April 2026; the next cycle covers financial year 2026. The milestones to watch now are the mandatory scope of the climate standard issued in December 2025 and the implementation notices of the Shanghai, Shenzhen and Beijing exchanges. For a European group, the interesting part is not the Chinese filing itself. Most groups will never file one. The interesting part is that a listed Chinese customer, joint venture partner or tier 1 supplier now has to publish sustainability information on a fixed date, and will collect the underlying data from everyone attached to it, including suppliers and parents with no listing in China at all. **Table of Contents** 1. [What applies from April 2026: the CSDS basic standard, the climate standard and who is in scope](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#what-applies-from-april-2026) 2. [Where the CSDS and ESRS overlap, and where they do not](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#csds-and-esrs-overlap) 3. [What an EU parent already has: CSDS requirements against existing ESRS datapoints](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#csds-against-existing-esrs-datapoints) 4. [What European groups with Chinese operations should do before the next filing cycle](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#what-european-groups-should-do) 5. [2026 outlook: convergence, ratings and the next milestones](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#2026-outlook) 6. [Frequently Asked Questions](https://www.fiegenbaum.solutions/en/blog/china-esg-reporting-requirements-2026-european-companies#frequently-asked-questions) ## What applies from April 2026: the CSDS basic standard, the climate standard and who is in scope The CSDS are built as a three-part system: a basic standard that sets the general disclosure architecture, thematic standards for individual topics, and application guidance. The basic standard was finalised by the Ministry of Finance in December 2024, after the China Securities Regulatory Commission had put draft disclosure standards out in May 2024. The first thematic standard, CSDS No. 1 Climate (Trial), was issued by the Ministry of Finance together with other ministries in December 2025 as a voluntary trial standard modelled on IFRS S2; the scope of mandatory application has not yet been set. It adds topic-level requirements on top of the governance, strategy, risk management and metrics structure of the basic standard. Two bodies issue rules here and they bind differently. The Ministry of Finance (MOF) writes the national standards: the CSDS basic standard, the thematic standards such as Corporate Sustainability Disclosure Standard No. 1: Climate (Trial), and the MOF Application Guidelines that explain their application. Those texts set what a disclosure has to contain and form the building blocks of the unified national standards system. The China Securities Regulatory Commission (CSRC) and the exchanges under it write the listing rules: who must publish, by when and in which filing. The exchange guideline decides whether a company reports at all, the MOF standard decides what the report has to say. When a data request arrives from China, ask which of the two the sender answers to: that sets the deadline and the level of detail expected. Scope comes from the exchange guidelines, which name index membership rather than size thresholds. That is the practical difference to the CSRD: in China you check whether an entity sits in a named index, not whether it passes an employee or turnover test. | Requirement | Who is in scope | Exchange | First reporting year | | --- | --- | --- | --- | | Exchange sustainability guidelines | SSE 180 and STAR 50 constituents, plus dual-listed groups | Shanghai | FY2025, filed by 30 April 2026 | | Exchange sustainability guidelines | SZSE 100 and ChiNext constituents | Shenzhen | FY2025, filed by 30 April 2026 | | Exchange sustainability guidelines | Voluntary, disclosure encouraged | Beijing | Not mandated | | CSDS basic standard (Ministry of Finance) | Framework for the mandated issuers above, wider application phased | All | FY2025 reporting cycle | | CSDS No. 1 Climate (Trial), issued December 2025 | Voluntary trial standard, mandatory scope pending | All | Roadmap to 2027 | The mandated population is roughly 400 to 460 listed companies: the four indices have 430 constituent slots between them, dual-listed issuers come on top, and a company that sits in two indices counts once. That is a single-digit share of all mainland listings. My position on that number: it is the least important figure on this page. A disclosure obligation that binds a few hundred issuers generates data requests across tens of thousands of suppliers, and nobody has mandated that second layer. ## Where the CSDS and ESRS overlap, and where they do not The CSDS take the ISSB architecture as their base, so anyone who knows IFRS S1 and S2 will recognise the four content pillars. The notable departure is materiality. The Chinese basic standard asks for impact as well as financial materiality, which puts it closer to the ESRS than to IFRS S1, but it leaves the assessment methodology to the reporting company. An EU parent that has run a prescriptive double [materiality assessment](https://www.fiegenbaum.solutions/en/blog/materiality-assessment-smes-esg-compliance-growth?hsLang=en) can reuse the reasoning, not the documentation format. | Dimension | CSDS (China) | ESRS (EU) | IFRS S1 and S2 | | --- | --- | --- | --- | | Materiality | Impact and financial, methodology left to the company | Double materiality, prescriptively defined | Financial materiality only | | Assurance | National assurance standard since January 2026, applied voluntarily | Limited assurance mandatory | Set per jurisdiction | | Value chain | Focus on direct operations | Extends through the value chain | Only where financially material | | Social topics | National priorities, including rural development and common prosperity | ESRS S1 to S4 | Not covered | Two divergences cost real work. The first is the value chain boundary: an ESRS reporter has already been forced to look beyond its own gates, a CSDS reporter has not, so a Chinese entity asked for group level value chain data will usually have neither the process nor the mandate. The second is that China regulates this as information disclosure under securities law, not as part of the management report, which decides who signs and which deadline governs, unlike the European side described in the [overview of the ESRS standards](https://www.fiegenbaum.solutions/en/blog/a-complete-overview-of-esrs-standards-key-reporting-guidelines-for-corporate-sustainability-under-csrd?hsLang=en). ## What an EU parent already has: CSDS requirements against existing ESRS datapoints Most of what the CSDS ask for already exists somewhere in an EU group that reports under the ESRS. It is rarely the datapoint that is missing, it is the entity level cut of it. | CSDS disclosure area | ESRS anchor already reported | What has to be collected in China | | --- | --- | --- | | Governance of sustainability matters | ESRS 2 GOV-1 to GOV-5 | Local board and committee structure, delegated responsibilities | | Climate risks and opportunities | ESRS 2 IRO-1 and ESRS E1 | Site level exposure for the Chinese locations | | Greenhouse gas emissions, Scope 1 and 2 | ESRS E1-6 | Scope 2 method choice and local grid factors | | Greenhouse gas emissions, Scope 3 | ESRS E1-6 | Purchased goods and logistics data from local suppliers | | Value chain and business conduct | ESRS S2 and G1 | Tier 1 supplier data and local conduct policies | Three things break repeatedly when a Chinese entity is consolidated into a group data set. Boundary definition comes first: the Chinese legal entity, the production site and the joint venture stake are three different perimeters, and the local finance team consolidates by the first while the ESG report needs the second. Then the Scope 2 method, where a location based figure from the local grid and a market based figure from the group template are not the same number and the difference is not an error. Third, data ownership: the emission figures sit with a plant engineer who has no reporting mandate. An industrial group with two production sites in eastern China and a sales entity spent its entire first cycle on those three points and none of it on the standard text. Some work cannot be shared between the two reports at all and needs its own budget: EU taxonomy alignment, which needs NACE-coded revenue, CapEx and OpEx and has no Chinese counterpart; the value chain due diligence narrative of the ESRS; and the social topics tied to Chinese national development priorities, which have no ESRS datapoint to land in. ## What European groups with Chinese operations should do before the next filing cycle The realistic goal for the next cycle is not a Chinese report, it is answering a Chinese customer or subsidiary request with numbers that match the group report. 1. Check whether any Chinese entity, customer or joint venture partner sits in the SSE 180, STAR 50, SZSE 100 or ChiNext indices, or is dual listed. That list decides who sends requests in the months before each 30 April deadline. 2. Pull the entity level cut of the ESRS datapoints in the mapping above for every Chinese entity, and note which ones do not exist at that level yet. 3. Fix the Scope 2 method and the emission factors for the Chinese sites in writing, following the [GHG Protocol](https://ghgprotocol.org/corporate-standard), before the first request arrives. 4. Name one owner per entity for [sustainability data](https://www.fiegenbaum.solutions/en/blog/unlocking-long-term-value-esg-data-business-success?hsLang=en), not per topic. Topic owners produce one good year. 5. Run a dry filing on FY2026 numbers against the basic standard structure. Manufacturing and heavy industry are hit first, financial services follow through their portfolios, and technology entities mostly get pulled in as suppliers rather than as issuers. On tooling: a separate Chinese reporting system is the wrong answer for almost every group of this size. The requirement is a second reporting view on one data set, not a second data set, so the question to ask a vendor is whether the entity level data can carry two framework mappings at once. My position: the groups that struggle in 2026 will not be the ones that misread the standard, they will be the ones whose Chinese entities were never in the reporting perimeter to begin with. Background: [key ESG metrics](https://www.fiegenbaum.solutions/en/blog/7-key-esg-metrics-2025?hsLang=en) and the [step-by-step guide to sustainability reporting](https://www.fiegenbaum.solutions/en/blog/create-comprehensive-sustainability-report-steps-standards?hsLang=en). ## 2026 outlook: convergence, ratings and the next milestones The direction of travel is convergence with the ISSB, with standards aligned to IFRS S1 and S2 planned for 2027 and a unified national reporting system targeted for 2030. The sequencing matters for an EU group: under the revised CSRD thresholds the first group report covers financial year 2027, two years after the first mandatory Chinese filings. A Chinese subsidiary or listed partner is therefore the first place where an outside reader tests the group's data model. Hong Kong is ahead of the mainland here, having pushed listed issuers towards IFRS S2 climate disclosure earlier. Ratings are the open flank: domestic agencies score national priorities international providers do not model, so the same [climate risk assessment](https://www.fiegenbaum.solutions/en/blog/physical-risks-and-transition-risks-how-to-assess-climate-risks?hsLang=en) reads differently in each. Watch the exchange implementation notices and the first thematic standard; that is where the next change comes from, not from the announcements. Capital market context sits in the [ESG capital market dashboard](https://atlas.fiegenbaum.solutions/en/esg-kapitalmarkt?utm_source=fiegenbaum-solutions&utm_medium=blog&utm_campaign=atlas-esg-kapitalmarkt&utm_content=china-esg-reporting-requirements-2026-european-companies). ## Frequently Asked Questions Which companies must report from April 2026, and which year does the first report cover? Constituents of the SSE 180, STAR 50, SZSE 100 and ChiNext indices plus dual-listed groups. The first report covered financial year 2025 and was due on 30 April 2026; each following report is due by 30 April for the preceding financial year. Does the CSDS require double materiality or single financial materiality? Both dimensions, impact and financial, which puts the CSDS closer to the ESRS than to IFRS S1. The methodology is left to the company. Do non-listed Chinese subsidiaries of European groups fall in scope? Not directly. A subsidiary outside a mandated index has no filing obligation of its own, it is reached through listed customers and partners requesting supplier data. Can data prepared for ESRS be used for a Chinese filing? The datapoints largely carry over, the cuts do not. What is missing is the entity level view: Scope 2 by local grid, site level climate exposure, workforce figures on local definitions. Is third-party assurance required for a Chinese sustainability report? Not under the exchange guidelines, which leave assurance to the issuer. In January 2026 the Ministry of Finance issued a national assurance standard, [Sustainability Information Assurance Standard No. 6101 (Trial)](https://climatecooperation.cn/climate/china-issues-sustainability-assurance-standards-to-strengthen-disclosure-credibility/), but it sets rules for the assurance providers and is applied voluntarily; it does not oblige any company to have its report assured. The CSRD requires limited assurance on the sustainability statement, so Chinese site data that flows into an EU group report gets checked there in any case. Budgeting a review of the Chinese figures early is cheaper than explaining a gap to the group auditor later. Next step Turn climate risk or ESG data into a decision? In a 30-minute intro call we map where your biggest lever is, with no obligation. [Book an intro call](https://www.fiegenbaum.solutions/en/contact?hsLang=en) ![Johannes Fiegenbaum](https://www.fiegenbaum.solutions/hubfs/Johannes_07-modified.png) ### Johannes Fiegenbaum ESG and sustainability consultant based in Hamburg, specialised in VSME reporting and climate risk analysis. Has supported 300+ projects for companies and financial institutions, from mid-sized manufacturers to major banks and insurers. [More about](https://www.fiegenbaum.solutions/en/about-me?hsLang=en) Related articles ## You may also like ### [Supply Chain & EUDR Digital Product Passport (DPP) 2026: EU, China & US Requirements + Implementation Guide A digital product passport is a structured, machine-readable record of a physical product: what it is made of, where it came from, what its environmental footprint is, and how it ... 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