What Changes on 1 January 2027 in Sustainability Reporting

Nothing is announced on 1 January 2027. That is what makes the date worth writing down. Several instruments that were legislated in 2025 and 2026 attach to financial years, and a large number of those years begin on that Friday. A company that treats the date as a deadline will be late, because the obligation is to have been collecting data since the first day of the year.

Here is what turns over, jurisdiction by jurisdiction, with the source for each date.

Europe: the first CSRD year that survives the Omnibus

Directive (EU) 2026/470 entered into force on 18 March 2026 and narrowed CSRD sharply. The scope gate is now more than 1,000 employees together with turnover above €450 million. In-scope EU companies report on financial years beginning on or after 1 January 2027, which puts the first reports in 2028. Non-EU ultimate parents come in a year later, reporting in 2029 on FY2028. Member States have until 19 March 2027 to transpose (DLA Piper; Gibson Dunn).

The standards those reports are written against also change on the same boundary. The European Commission adopted the revised ESRS delegated act on 3 July 2026, and it applies to financial years beginning on or after 1 January 2027 (European Commission). We have written on what the July adoption changed and on the value-chain cap that protects undertakings below 1,000 employees.

Two things follow for a company that survives the gate. Its FY2027 disclosures are prepared against a standard adopted only months before the year starts, and any datapoint mapping built against the 2023 ESRS has to be re-checked. The CSRD timeline covers the surrounding dates.

Europe: the border and the forests

CBAM has been in its definitive regime since 1 January 2026, and 2027 is when the money and the paperwork arrive. Under Regulation (EU) 2025/2083, Member States begin selling CBAM certificates to authorised declarants on a common central platform from 1 February 2027. The first CBAM declaration, covering calendar year 2026 imports, is due by 30 September 2027. The same regulation sets a single mass-based de minimis threshold, initially 50 tonnes a year (European Commission; Regulation (EU) 2025/2083). Our note on the definitive regime covers the mechanics.

For an importer, the practical consequence of that pair of dates is a cash timing question rather than a reporting one. Certificates become purchasable in February and the surrender obligation for the previous year lands in September.

The EU Deforestation Regulation runs on its own clock. After Regulation (EU) 2025/2650, large and medium operators apply from 30 December 2026, and micro and small operators from 30 June 2027 (European Commission). So the large-operator date sits two days before the new year, and the small-operator date sits halfway through it. We covered the deadline that moved and the cutoff that did not separately.

Japan: the first tier is already inside its reporting year

Japan’s first mandatory SSBJ cohort does not start on 1 January 2027. It is halfway through its reporting year by then.

The Cabinet Office Ordinance amendment of 20 February 2026 makes SSBJ disclosure mandatory for entities with market capitalisation of ¥3 trillion or more, for annual reporting periods ending March 2027. The ¥1 trillion tier follows for periods ending March 2028, and ¥500 billion for March 2029. The Financial Instruments and Exchange Act amendments underpinning this were made on 15 July 2026 (IFRS Foundation, Japan jurisdictional profile).

For a Japanese group that also reports in Europe, this is the ordering that matters. The Japanese filing arrives in mid-2027 and the European one in 2028, and both draw on overlapping data. Our SSBJ roadmap and the note on dual filing go into that.

Korea, Australia, Taiwan, Malaysia

Korea. The Financial Services Commission published its final roadmap on 8 July 2026. From 2028, KOSPI-listed companies with consolidated assets of KRW 10 trillion or more must file ESG disclosures, and the threshold drops to KRW 5 trillion from 2029. Because the 2028 filing covers fiscal 2027, the data collection begins on 1 January 2027 for the first cohort. A further reduction to KRW 2 trillion from 2030 is under consideration and not decided (FSC). We track this in our Korea disclosure roadmap.

Australia. AASB S2 Group 2 applies to annual reporting periods commencing on or after 1 July 2026, for entities meeting at least two of three criteria: consolidated revenue of A$200 million or more, gross assets of A$500 million or more, or 250 or more employees (IFRS Foundation, Australia profile). A Group 2 entity with a December year end therefore starts its first mandatory year on 1 January 2027.

Taiwan. The phased adoption of IFRS S1 and S2 puts listed companies with paid-in capital between NT$5 billion and NT$10 billion into scope for financial year 2027, reporting in 2028. Companies above NT$10 billion were already in scope for FY2026, reporting in 2027, and all remaining listed companies follow for FY2028 (IFRS Foundation, Chinese Taipei profile).

Malaysia. Under the National Sustainability Reporting Framework, ACE Market listed corporations and large non-listed companies with annual revenue of MYR 2 billion or more begin climate-first reporting for annual periods beginning on or after 1 January 2027. Full application of IFRS S1 and S2 for that group comes later, from 1 January 2030. Main Market issuers outside the first group started climate-first reporting from 1 January 2026 and reach full application in 2028 (IFRS Foundation, Malaysia profile).

The wider count. The IFRS Foundation stated on 12 June 2025 that thirty-six jurisdictions have adopted or otherwise used the ISSB standards, or are finalising steps to introduce them (IFRS Foundation). Our ISSB adoption tracker follows the individual profiles.

What is still open

Two items get quoted as 2027 dates and should not be.

Singapore’s large non-listed companies. These are companies with annual revenue of at least S$1 billion and total assets of at least S$500 million. Earlier timelines put them at FY2027. The IFRS Foundation’s Singapore profile, updated 26 June 2026, records that they will begin reporting from FY2030, with the requirements to be formalised in legislation (IFRS Foundation, Singapore profile). Listed issuers are on their own earlier track.

The United Kingdom. UK SRS S1 and S2 were issued on 25 February 2026 and are available for voluntary use. They do not themselves create a legal obligation. The date for mandatory application depends on the outcome of the FCA’s consultation for listed companies, with final decisions expected in autumn 2026 (IFRS Foundation, United Kingdom snapshot). Anyone planning against a firm UK mandatory date is planning against a decision that has not been published.

What the date actually asks of you

Every item above except the CBAM certificate sales and the first CBAM declaration is a collection obligation, not a filing one. The filings land in 2028. What begins on 1 January 2027 is the year whose numbers those filings will contain.

That distinction decides where the work goes now. A datapoint mapping re-checked against the revised ESRS in December 2026 is useful. The same mapping done in October 2027 arrives after ten months of data have already been recorded the old way. The same is true for a Korean group starting its fiscal 2027 collection, an Australian Group 2 entity with a December year end, and an ACE Market issuer in Kuala Lumpur.

For a group caught by more than one of these, the shape of the problem is one dataset serving several outputs on different calendars, which is the case we have written up in the Asia-Pacific reporting overview.

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