China’s first climate disclosure standard officially released: key points companies must know

In December 2025, nine Chinese government bodies jointly issued the Corporate Sustainability Disclosure Standard No. 1 Climate (Trial), referred to as the Climate Disclosure Standard in this article.

The standard builds upon the General Guidelines for Corporate Sustainability Disclosure (Trial) released in November 2024. As the first thematic standard under China’s emerging sustainability reporting framework, it includes detailed disclosure requirements related to the governance, strategy, risk management, metrics and targets, aligning with both domestic policy priorities and international sustainability reporting frameworks.

Here are our five key takeaways for companies to help bring the guidance to life as you prepare your disclosures:

1. Integrate China's requirements while benchmarking against international standards

What the standard says:

The standard maintains close alignment with IFRS S2 Climate-related Disclosures, while incorporating China-specific requirements - this includes greenhouse gas (GHG) accounting, the impact of carbon trading on financial statements, and alignment with national climate commitments when disclosing the inputs for climate-related scenario analysis. According to the Drafting Notes of the standard, the Ministry of Finance maintains ongoing exchanges with the ISSB and comparable authorities for streamlining global compliance.

What does this mean for you?

Pay close attention to China-specific requirements like carbon labelling and alignment with the Nationally Determined Contribution (NDC). At the same time, keep a close eye on ISSB updates, such as the recently released IFRS S2 amendments. The provision for jurisdictional reliefs in the amendments might ease compliance burden for Chinese companies operating globally.

2. The standard will be rolled out in phases (currently trial phase)

What the standard says:

The standard is currently voluntary, with mandatory requirements and the application scope to be defined at a later stage. Guidance for nine key industries, including power, steel, coal, petroleum, fertilisers, aluminium, hydrogen, cement, and automotive, is currently under development. According to the Drafting Notes of the standard, the rollout will start with listed and large companies, expanding from qualitative descriptions to quantitative data. Following the guidance from the Ministry of Finance, several pilot companies in the construction and biotechnology sectors have completed and published sustainability disclosure reports in compliance with the standard.

What does this mean for you?

Follow the upcoming industry specific guidelines and benchmark your progress against pilot companies in sectors that have already published reports. Although the disclosure is currently voluntary, companies should begin building internal capabilities now to collect complex data for Scope 3 emissions and scenario analysis before they become mandatory.

3. Integrate climate factors into strategy and risk management systems

What the standard says:

Companies are expected to disclose 1) the governance body(s) or individual(s) responsible for oversight of climate-related risks and opportunities, 2) identify climate-related risks and opportunities that could reasonably be expected to affect your business prospects, and 3) the effects of those risks and opportunities on your strategy, decision-making, current and anticipated financial performance (download our factsheet for more details on risk management disclosure). Furthermore, companies are advised to conduct scenario analysis to assess the resilience of their business models.

What does this mean for you?

The implications go beyond simple reporting. To effectively implement mitigation plans, companies must integrate climate factors into your daily decision-making, including resource allocation, risk management, and the selection of production equipment or processes.

4. Expect a mix of qualitative and quantitative disclosures

What the standard says:

The standard requires both current and anticipated financial impacts of climate-related risks and opportunities. Both quantitative and qualitative disclosures are expected - quantitative disclosures (presented as single figures or ranges) should clearly identify the impact on the financial performance, cash flows, and other relevant financial statements for the upcoming reporting period, while qualitative information provides the necessary context and assumptions.

What does this mean for you?

You are expected to provide predictive quantitative data, either single figures or ranges, on the financial impact of climate-related risks and opportunities (download our factsheet for more details and disclosure examples). This must be accompanied by qualitative information that explains materiality, risk mitigation and monitoring measures, and key assumptions, ensuring the data is transparent and comprehensive for stakeholders.

5. Practical flexibility for complex data

What the standard says:

Recognising the challenges of gathering and disclosing complex data (e.g., financial impacts, scenario analysis, and Scope 3 emissions), the standard allows companies to use all reasonable and supportable information available without incurring undue cost or effort. However, for companies with material climate risks, a transition to quantitative climate-related scenario analysis is expected once the necessary capabilities are established.

What does this mean for you?

Focus on building internal capacities in carbon emission management and disclosure, especially regarding quantitative financial impact disclosure, climate-related scenario analysis, and Scope 3 emissions. Consider using third-party organisations to verify and assure your data to build market trust. SLR offers introductory and topic-based trainings for management and organisational capability building purposes. Please contact our experts below for more information.

How can SLR support you?

Under China's Dual Carbon Targets, the Climate Disclosure Standard represents a major move to standardise and regulate climate disclosure practices. We recommend that Chinese companies - especially listed companies and those with material climate risks - act proactively to meet the requirements and gain a competitive edge in sustainability practices and disclosure.

Our global experts have rich experience and technical background in financial modelling, scenario analysis and carbon management. With a proven track record in diverse sectors such as the automotive, mining, electronics, pharmaceuticals, and retail, SLR helps you navigate the complexities of climate data collection and analysis, aligning with national and international frameworks.

Learn more about our following services and download our factsheet to review our project experience with industry leaders.

Climate-related services:

• Gap analysis and strategic planning
• GHG assessment and measurement
• Scenario analysis
• Transition planning and capability building
• Climate Disclosure

Other related services:

• Corporate Sustainability Strategy: Double materiality assessments, Sustainability governance, Roadmap implementation and monitoring, Specialist ratings (such as S&P Global’s Corporate Sustainability Assessment, CSA)
• Due diligence & Impact Assessment: Social and environmental due diligence, impact assessment screening