Phased Implementation of Requirement to Disclose Sustainability-Related Financial Information in Their Annual Reports for TWSE- and TPEx-Listed Companies in Taiwan Starting from FY2026

To align with the Sustainability Disclosure Standards (“IFRS Sustainability Disclosure Standards”) issued by the International Financial Reporting Standards Foundation (“IFRS Foundation”), Taiwan’s Financial Supervisory Commission (“FSC”) released the “Roadmap for Taiwan’s Alignment with the IFRS Sustainability Disclosure Standards” (“Roadmap”) ^[1] in 2023. Pursuant to the Roadmap, from FY2026 onward, TWSE- and TPEx-listed companies in Taiwan will be subject to the phased implementation of a requirement to disclose sustainability-related financial information in a dedicated section of their annual reports, according to their respective levels of paid-in capital amount. Such disclosure must comply with the IFRS Sustainability Disclosure Standards as recognized by the FSC. To implement the Roadmap, the FSC announced a draft amendment to the “Regulations Governing Information to be Published in Annual Reports of Public Companies” (“Draft Amendment”) in May 2025, and designated July 21, 2025, as the deadline for public comments. This article provides an overview of the key points of the Draft Amendment.

1. TWSE- and TPEx-listed Companies Shall Disclose Sustainability-Related Financial Information in a Dedicated Section of their Annual Reports in Accordance with the Roadmap and Simultaneously with their Financial Reports.

Companies that meet certain conditions designated by the FSC are required to disclose sustainability-related financial information approved by their board of directors in a dedicated section of their annual reports (Article 7, Paragraph 2 of the Draft Amendment). The sustainability-related financial information must be filed simultaneously with the company’s financial statements and uploaded to the FSC-designated electronic filing system. If a company cannot complete the entire annual report by the regulatory deadline, it may first file the dedicated section on sustainability-related financial information, and subsequently file the full annual report once finalized (Article 23, Paragraph 2 of the Draft Amendment).

In accordance with the phased implementation timeline and applicability scope under the Roadmap, the FSC will define the “certain conditions” referred to in Article 7, Paragraph 2 of the Draft Amendment based on the companies’ paid-in capital amount, as illustrated below:
 

Fiscal Year of Implementation	Applicable Companies
2026	Companies with paid-in capital of NT$10 billion or more
2027	Companies with paid-in capital of NT$5 billion to less than NT$10 billion
2028	All remaining TWSE- and TPEx-listed Companies

2. Preparation and Disclosure of Sustainability-Related Financial Information Shall Follow Article 10-1 of the Draft Amendment, Other Applicable Laws and Regulations, and FSC-recognized IFRS Sustainability Disclosure Standards.

The preparation and disclosure of sustainability-related financial information by the TWSE- and TPEx-listed companies must comply with Article 10-1 of the Draft Amendment, other applicable laws and regulations, and the IFRS Sustainability Disclosure Standards as recognized by the FSC if there is no specific statutory provision. The subparagraphs of Article 10-1 of the Draft Amendment are formulated with reference to key provisions of IFRS S1 “General Requirements for Disclosure of Sustainability-related Financial Information” and IFRS S2 “Climate-related Disclosures” issued by the IFRS Foundation.

We recommend that companies evaluate the gap between their existing disclosure practices and the requirements under IFRS S1 and S2, based on their respective levels of paid-in capital amount. Companies should also begin identifying and organizing relevant data as early as possible to ensure a smooth transition and full compliance with the FSC’s forthcoming disclosure requirements.
 

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[1] Aaron Chen & Tina Lee (2023), FSC Released Taiwan's Roadmap to Align with IFRS Sustainability Disclosure Standards , Lee, Tsai & Partners.