What do the CMB's new sustainability disclosure obligations bring?

The Capital Markets Board's new framework marks a shift from voluntary, fragmented sustainability disclosure toward a structured, comparable reporting regime for publicly held companies. For boards and general counsel, the practical question is no longer whether to report, but how to build a defensible, audit-ready process.

What is changing

The core change is scope and standardisation. Companies within the threshold must now report against a defined set of environmental, social and governance indicators, on a fixed calendar, using a consistent methodology. This makes disclosures comparable across issuers — and makes gaps far more visible to regulators and investors alike.

Who is in scope

Applicability is tied to size and public-interest thresholds. Even companies below the mandatory line are increasingly asked for the same data by lenders, insurers and counterparties, so a 'wait and see' posture rarely holds for long. We advise treating the threshold as a floor, not a ceiling.

How to prepare

Start with a gap analysis against the required indicators, assign clear internal ownership, and put data-collection controls in place well before the reporting window. The most common failure is not a lack of intent but a lack of reliable, documented data. Getting the governance right early turns a compliance burden into a strategic advantage.

How we help

Our corporate team helps boards map obligations, design reporting governance and review disclosures for legal exposure before they are filed. If you would like a readiness assessment for your company, we are glad to help.