Myanmar

Yes.

ESG disclosure requirements primarily apply to companies (i) which possess investment permits or endorsements issued by the Myanmar Investment Commission and are considered to have “a large potential impact on the environment and the local community”; and/or (ii) whose business activities are subject to environmental impact assessments or initial environmental examinations (together, the In-Scope Companies). The requirements include:

1. The Myanmar Investment Law and the Myanmar Investment Rules (Investment Laws), which require companies that are subject to environmental and social impact assessments to report their compliance status on a regular basis. Furthermore, such companies are required to submit a compliance report within 3 months after the end of each financial year in the prescribed form to the Myanmar Investment Commission to report on the impact of the approved investments on the environment and local community.
2. The Environmental Conservation Law and its subordinate legislation, being the Environmental Conservation Rules and the Environmental Impact Assessment Procedures (Environmental Conservation Laws), which prescribe the types of business activities subject to prior environmental assessments and set out disclosure requirements for such businesses, including the disclosure of initial environmental reports and continuous reporting obligations.

Companies listed on the Yangon Stock Exchange (YSX) and public companies with more than 100 shareholders are required to submit a directors’ report annually to the Securities and Exchange Commission (SEC) and the Directorate of Investment and Company Administration (DICA). The directors’ report shall disclose all risks and uncertainties faced by the company, although no specific reference to environmental or social related matters is mentioned under the law for making such disclosures. Furthermore, such companies are subject to continuous disclosure requirements to report to the SEC and DICA on any material changes in a timely manner.

As part of Myanmar’s response to the Extractive Industries Transparency Initiative (an organisation that seeks to establish a global standard to promote the open and accountable management of oil, gas and mineral resources), all companies in extractive industries incorporated in Myanmar are required to disclose their beneficial owners and whether they are related to any politically exposed person. However, Myanmar was delisted from the Extractive Industries Transparency Initiative in February 2024, and it remains unclear whether DICA continues to enforce these disclosure requirements.

The disclosure requirements specified in section A.2 above are mandatory.

For In-Scope Companies, the focus is on environmental and social aspects.

For financial institutions, the additional focus is on anti-money laundering and anti-bribery.

The disclosure requirements for In-Scope Companies are not generally based on international standards.

The disclosure requirements relating to beneficial ownership and politically exposed person replicate the corresponding concepts in the Extractive Industries Transparency Initiative Standard 2019.

The disclosure requirements for In-Scope Companies adopt a double materiality approach whereas a single materiality approach applies to YSX-listed companies and financial institutions.

No.

No, and we are not aware of any plans by the authorities to introduce such requirements.  Where the Ministry of Natural Resources and Environmental Conservation identifies non-compliance with environmental rules by an investor, it has the authority to engage a third-party expert to assess the investor’s compliance status.

No, but a YSX-listed company has been making voluntary disclosure of its sustainability practices and initiatives.

No.

No.

We are not aware of any recent development in ESG reporting requirements.

Yes. The Myanmar Climate Change Policy formulated by the former government in 2019 mandates the implementation of the Myanmar Climate Change Strategy (2018-2030), which sets out a 13-year roadmap with a stated 2030 goal of achieving climate resilient and low-carbon energy, transport and industrial systems that support inclusive and sustainable development and economic growth. The Myanmar Climate Change Strategy (2018-2030) includes sectoral master plans covering six priority areas, each with defined outcomes:

1. Agriculture, fisheries and livestock – to achieve climate-resilient productivity and climate-smart responses in the agriculture, fisheries and livestock sectors to support food security and livelihood strategies while also promoting resource-efficient and low-carbon practices;
2. Natural resource management – to manage natural resources in a way that enhances the resilience of biodiversity and ecosystem services that support social and economic development and deliver carbon sequestration;
3. Energy, transport and industrial systems – to build climate-resilient and low-carbon energy, transport and industrial systems that support inclusive and sustainable development and economic growth;
4. Towns and cities – to ensure all township and city dwellers, including the most vulnerable, are safe from increased risks of rapid- and slow-onset natural disasters and live in sustainable, inclusive, low-carbon, climate-resilient towns;
5. Disasters, risks and health impacts – to enable communities and economic sectors to respond to and recover from climate-induced disasters, risks and health impacts and build a healthy society;
6. Education, awareness and technological systems – to strengthen education, awareness and technological systems that foster a climate-responsive society and human capital to design and implement climate-resilient and low-carbon development solutions for inclusive and sustainable development.

These targets are embedded as the government's policy priorities under the Myanmar Climate Change Strategy (2018-2030) rather than as legally binding obligations. They sit within the broader Myanmar Climate Change Policy (2019) framework, which directs implementation of the Strategy but does not itself carry the force of primary legislation.

No.

No.

No.

No, and we are not aware of any plan by the authorities to introduce such requirements.

No, and we are not aware of any plan by the authorities to introduce such requirements.

None has been implemented to date. Myanmar has not introduced any specific initiatives aimed at mobilising capital towards sustainable or climate-related investment. The Myanmar Climate Change Strategy (2018-2030) identifies climate finance as one of its five implementation pillars and envisages mechanisms to channel funding towards its sectoral outcomes, but these remain aspirational with no specific measures having been rolled out in practice.

In May 2026, the National-Level Leading Committee on the Development of Electric Vehicles and Related Industries announced a voluntary vehicle replacement scheme allowing owners to deregister older or unserviceable vehicles in exchange for authorisation to import an electric vehicle (EV). The Central Bank of Myanmar will facilitate the scheme by selling the foreign currency required for the EV import at an appropriate exchange rate. This measure has not been expressly tied to the sectoral outcomes under the Myanmar Climate Change Strategy (2018-2030) and appears to respond primarily to the prevailing fuel supply situation. Beyond this scheme, we are not aware of further developments suggesting a move towards mandatory transition plans, due diligence obligations or broader climate-related finance initiatives. 

No. We are not aware of any such legal action taken by the relevant regulators or other stakeholders such as investors within the past five years, based on publicly available information.

No. However, the applicable laws (see section A.2 above) carry penalties for non-compliance, including fines, regulatory penalties (e.g., revocation of licences) and criminal liabilities.

Likely grounds include:

1. disclosure liabilities under investment laws, securities laws and regulations, e.g. providing materially false or misleading information in listing documents or other corporate disclosure documents such as ESG compliance reports or information;
2. breaches of directors’ duties; and
3. claims in tort for misrepresentation.

We are not aware of any recent development in this regard.