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China Sustainability Disclosure Standards (CSDS) -- Basic Standard

ENFORCEMENT TIMELINE

Issued December 16, 2024

Enforcement: Issued December 16, 2024

Overview

The Basic Standard of the China Sustainability Disclosure Standards (CSDS) is the top-tier standard of a unified national sustainability disclosure framework, formally issued on December 16, 2024 by the Ministry of Finance and eight other authorities. While drawing reference from the International Sustainability Standards Board's (ISSB) IFRS Sustainability Disclosure Standards, it is built as an independent disclosure framework tailored to China's policy and market environment. The CSDS framework has a three-tier structure -- "Basic Standard," "Specific Standards," and "Application Guidance" -- with the Basic Standard setting out the top-level principles common to specific standards (such as the forthcoming climate-related disclosure standard) and application guidance yet to be developed. Scope and implementation requirements await further rules; at present, voluntary application by companies is possible. The aims are to build a unified national sustainability disclosure system, provide investors with comparable and reliable information, improve the transparency of China's capital markets, and establish a China-specific system while ensuring alignment with international standards. Currently at the voluntary-application stage, mandatory application is expected to be phased in over time -- prioritizing listed companies, large state-owned enterprises, and financial institutions -- as scope and implementation requirements are clarified. Rather than prescribing individual disclosure items, the Basic Standard sets out principles common to the disclosure system as a whole: governance, strategy, risk management, metrics and targets, materiality, information reliability, and ongoing comparability.

Enforcement Timeline

- Sequential publication of specific standards, beginning with the climate-related disclosure standard.

- Finalization of application guidance (a public consultation draft of the Basic Standard's application guidance was published in June 2025).

- Expanding application to listed companies as scope is clarified.

- Building a data assurance framework in coordination with the sustainability information assurance standard.

- Ongoing alignment with the ISSB.

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Business Impact

- Building ESG data management systems.

- Integrated management of financial and sustainability information.

- Strengthening governance structures.

- Managing alignment with overseas disclosure regimes (ISSB, EU, etc.).

- Preparing for third-party assurance: In January 2026, the Ministry of Finance issued "Sustainability Information Assurance Standard No. 6101 -- Basic Standard (Trial)" (Cai Kuai [2026] No. 1), advancing in parallel the development of a framework for third-party assurance of disclosed information. Companies are advised to build data management systems with future assurance requirements in mind. Companies operating in both the Chinese and overseas markets will need data management capabilities that can simultaneously satisfy multiple disclosure regimes.