Taiwan

Contributing law firm: Lee and Li, Attorneys-at-Law

Year in review

1 July 2025 to 30 June 2026

  • The phased introduction of mandatory sustainability reporting aligned with IFRS S1 and IFRS S2 commenced from FY2026 starting with larger listed companies. Relief from mandatory disclosure of Scope 3 GHG emissions has been extended to cover the first three years of reporting.
  • Almost NT$5 billion (approx US$154 million) in carbon fees were collected for the first carbon fee cycle based on emissions generated in 2025. There are also plans for a pilot ETS and carbon border adjustment mechanism.
  • Taiwan passed circular economy-related bills in June 2026, establishing a new framework for resource circulation. The Ministry of Environment has been authorised to establish green design standards, mandate the reduction, reuse and lifetime extension of designated products, as well as promulgate guidelines on the use of “circular product certificates” to prevent greenwashing.
  • To achieve Taiwan’s 2050 net zero target, the Executive Yuan has released Taiwan's Comprehensive Carbon Reduction Action Plan, an upgraded strategy building on the 2050 Net Zero Pathway. The plan revamped the 12 key strategies from the 2050 Net Zero Pathway into 20 flagship carbon reduction programmes covering reduction efforts across six major sectors: energy, residential and commercial, agriculture, environment, transportation, and manufacturing. These programmes were also launched to achieve a 28% national interim GHG emissions reduction target, plus or minus 2%, by 2030. This target represents the third NDC proposed by the Ministry of Environment in December 2024, under the mandate of Climate Change Response Act, which the Executive Yuan subsequently approved in February 2026.
  • Although there are currently no mandatory supply-chain due diligence obligations in Taiwan, this is a potential area to monitor with a draft programme being formulated on human rights due diligence.

Scroll down or click below for further information on each key theme.

 

Please click on the podcast above for a snapshot of the three key themes of ESG reporting, transition and greenwashing in respect of Taiwan. 

Key contacts

Benjamin Li
Partner, Lee and Li, Attorneys-at-Law

Helen Huang
Associate Partner, Lee and Li, Attorneys-at-Law

JaeSeon Han
Attorney, Lee and Li, Attorneys-at-Law

 

A. ESG reporting

Yes.

Regulated GHG emitters

The Climate Change Response Act (CCRA) provides that businesses designated by the Ministry of Environment (MOENV) are required to report their GHG emissions each year by submitting relevant data to the registry of the MOENV, and the data submitted must be verified by a certified verification institute. The designated businesses are specified in a list of Businesses Subject to Accounting and Registration of Greenhouse Gases Emission Sources (List of Regulated GHG Emission Sources).

In March 2025, the MOENV updated the List of Regulated GHG Emission Sources, expanding its scope to include additional industries such as the IT service industry, retail businesses, hotels, and hospitals that meet their respective reporting thresholds.

All businesses specified in the List of Regulated GHG Emission Sources that meet the relevant threshold (i.e., 25k tonnes of GHG emissions) are subject to GHG accounting, reporting, and verification requirements, save that the newly added industries noted above are not required to undergo verification of their GHG accounting results.

Under the Regulations for Management of Inventory  and Registration of Greenhouse Gases, the regulated businesses are required to submit a GHG emissions accounting report by 30 April of each year and the verification of the GHG accounting results by 31 October of each year. Certain reporting requirements were added on 19 December 2025 to better accommodate the nature of the newly included industries. The reported data is publicly accessible on the MOENV’s Platform on GHG Emission Amount.

Listed companies and financial institutions

The Taiwan Stock Exchange’s (TWSE) Corporation Rules Governing the Preparation and Filing of Sustainability Reports by Listed Companies and the Taipei Exchange’s (TPEx) Rules Governing the Preparation and Filing of Sustainability Reports by Listed Companies require all listed companies to submit ESG reports (including GHG emissions data) on an annual basis (by 31 August of each year starting from 2025) subject to a verification and certification process.

Listed companies and financial institutions are also required to disclose their climate-related information in their annual reports.

The Financial Supervisory Commission (FSC) promulgated the Guidelines of Climate-Related Financial Disclosure for Domestic Banking Institutions and the Guidelines of Climate-Related Financial Disclosure for Insurance Institutions which require domestic financial institutions to disclose their climate-related financial risks every year from June 2023.

The disclosure requirements mentioned in section A.2 above are mandatory. Failure to submit the ESG reports would trigger an administrative fine ranging from NT$10,000 to NT$30,000. 

Businesses subject to the List of Regulated GHG Emission Sources are required to report their GHG emissions. 

Listed companies are required to specify in their ESG reports various sustainability-related indicators based on the FSC's requirements by industry and must also indicate the response measures and their progress in respect of the risks and opportunities as a result of climate change (such as the short-, medium- and long-term operational and strategic plans of the company, the financial impact of the climate change on the company, and GHG emissions data). The reporting generally covers all the commonly seen ESG elements.

The requirements for listed companies are being enhanced in phases through mandatory sustainability reporting requirements aligned with IFRS S1 and IFRS S2 – starting with mandatory climate reporting. See section A.5 below.

The mandatory ESG reporting requirements in Taiwan incorporate the GRI Standards, TCFD Recommendations and SASB Standards. However, requirements for listed companies are transitioning towards the ISSB Standards.

The FSC announced in October 2025 that, beginning in fiscal year 2026, TWSE and TPEx-listed companies are required to adopt the ISSB Standards in three phases, based on paid-in capital. Listed companies are required to include, as a standalone chapter in their annual report, sustainability reporting fully aligned with both IFRS S1 and IFRS S2 from fiscal year:

  1. 2026 for listed companies with a paid-in capital of NT$10 billion or more;
  2. 2027 for listed companies with a paid-in capital of at least NT$5 billion but no more than NT$10 billion; and
  3. 2028 for all other listed companies.

Transitional provisions available under the ISSB Standards will apply in the first year of reporting; for example, companies may initially disclose only climate-related information and are not required to present comparative information for prior periods. The FSC has extended the relief from mandatory Scope 3 GHG emissions disclosure by two additional years to cover the first three reporting years.

Additionally, based on the FSC's announcement in April 2026, companies may elect to apply the IFRS S2 December 2025 Amendments from 1 January 2026. For the companies that elect to do so, they must disclose their early adoption of the amendments.

The reporting requirements for listed companies’ sustainability reports and the FSC guidelines applicable to banks and insurance institutions adopt a single materiality approach. 

Regulated GHG emitters

Entities subject to the List of Regulated GHG Emission Sources are required to disclose Scope 1 and Scope 2 emissions, whereas disclosure of Scope 3 emissions is encouraged but not mandatory.  

The accepted measurement methodologies are specified under the Regulations for Management of Inventory and Registration of Greenhouse Gases and include emission factor method, mass balance method, direct measurement, and any other measurement methods approved by the MOENV.

Listed companies

Listed companies are subject to mandatory Scope 1 and Scope 2 disclosure under a phased approach beginning from fiscal year 2024 based on market capitalisation and industry sector.

Regarding Scope 3, the FSC has stated that since companies and their value chains are not yet familiar with this concept, and because the GHG Protocol, which is fundamental to Scope 3, is currently under revision, companies will not be mandated to conduct Scope 3 reporting for the first three years. For first-phase companies aligning in 2026, this means they are required to disclose Scope 3 emissions for fiscal year 2029 onwards. In line with IFRS S2, the GHG Protocol applies as the measurement methodology except for emission sources already regulated by the MOENV.

The reporting of sustainability indicators and Scope 1 and Scope 2 emissions in ESG reports submitted by listed companies must be assured by certified institutions. The MOENV has indicated that, to preserve flexibility in compliance, it does not currently plan to mandate independent assurance for Scope 3 emissions reporting.

No. However, the integration of ESG and other non-financial considerations into corporate strategies has been gradually gaining momentum in Taiwan due to growing focus from investors and other stakeholders.

Yes. In December 2022, various regulators jointly promulgated the Taiwan Taxonomy Guidelines for Sustainable Activities that include 29 types of regular economic activities (e.g. transportation and logistics) and 14 types of enabling economic activities (e.g. CCUS technologies). The taxonomy was further amended in December 2024.

It is not a mandatory requirement, but financial institutions are encouraged to refer to the Taxonomy Guidelines when making investments and issuing financial instruments labelled as “sustainable”.

The ISSB Standards are being implemented under a phased approach as outlined in section A.5 above.

Despite high market adoption, there are currently no proposals for the TNFD to become a mandatory reporting framework in Taiwan.

With the legal framework of ESG reporting now in place, it is expected that the regulators will focus on implementation and strengthen the enforcement of listed companies' mandatory ESG reporting.

In response to the global trend towards simplifying reporting requirements and reducing reporting burden, the MOENV and FSC are expected to work together to streamline reporting obligations by harmonising GHG inventory regulations and jointly establishing Scope 3 carbon emissions factors. This approach aims to eliminate redundant tasks while balancing improved disclosure accuracy with enhanced efficiency.

B. Transition

Yes, Taiwan’s “2050 Net Zero Pathway” was announced in March 2022 under which the government vowed to reach net-zero emissions by 2050 through four main strategies in the areas of: energy, industry, lifestyle, and social transition. The CCRA codifies this commitment to decarbonisation and sets out net-zero emissions as Taiwan's long-term goal to be attained by 2050.

The Executive Yuan has since announced an upgraded plan, Taiwan's Comprehensive Carbon Reduction Action Plan, which introduces 20 flagship carbon reduction programmes across six major sectors: energy, residential and commercial, agriculture, environment, transportation, and manufacturing.

As part of this plan, the government intends to devote new resources to geothermal and hydropower to diversify and maximise renewable energy sources. The MOEA has since released the Regulations for Demonstration Incentives of Geothermal Power Generation, and Regulations for Demonstration Incentives of Small Hydropower Generation in February 2026 and June 2026 respectively to encourage investments in these two sectors.

Carbon market

There is currently no mandatory carbon trading market in Taiwan. However, Taiwan is set to launch a pilot programme for its national Emissions Trading Scheme (T-ETS) in the second half of 2026, marking a major milestone in its climate strategy following the implementation of carbon fees in 2025. Partnering with the "Green Growth Alliance" - a group of roughly 20 major emitters managing 126 factories and representing about 80% of the regulated emissions - the pilot is expected to implement a mock trading platform to test a cap-and-trade mechanism. This trial serves to prepare industries for the official, legally binding ETS rollout targeted for 2028.

To facilitate a voluntary carbon exchange scheme, the MOENV announced the Regulations on Carbon Credit Trading, Auction, and Transfer, which took effect on 15 August 2024.

Pursuant to the CCRA, it is also expected that a trading market for voluntary reduction quotas will be established soon. According to the CCRA, businesses may propose voluntary reduction projects to implement GHG reduction measures, and apply to the MOENV for approval to obtain emission credits (GHG Credits), which should be used in accordance with the requirements and time period set by the MOENV. The MOENV promulgated on 12 October 2023 the Greenhouse Gas Voluntary Emission Reduction Projects Regulations (for the implementation of the scheme on GHG Credits) and the Regulations for the Management of Offsetting the Increased Greenhouse Gas Emissions (for the implementation of the GHG offset scheme described above).

Carbon fee

A carbon fee scheme was introduced in 2025 and applies to electricity and manufacturing businesses that emit over 25k tonnes of Scope 1 and Scope 2 GHG emissions per year.

The regime was established pursuant to the: (a) Regulations Governing the Collection of Carbon Fees; (b) Designated Greenhouse Gas Reduction Goal for Entities Subject to Carbon Fees; and (c) Regulations for Administration of Self-Determined Reduction Plan, which were promulgated by the MOENV on 29 August 2024. Businesses are encouraged to voluntarily develop GHG emission reduction plans and set GHG reduction targets for 2030 based on standards promulgated by MOENV so as to qualify for a reduced carbon fee rate for meeting GHG reduction targets.

For its first carbon fee cycle, the MOENV has collected around NT$5 billion of carbon fees based on emissions generated in 2025. The collected fees will be used to implement GHG reduction and climate change adaptation work in accordance with the CCRA.

CBAM

In July 2025, MOENV announced plans to develop a CBAM to prevent carbon leakage. Taiwan’s CBAM is planned to initially target the steel and cement industries for carbon emission trial reporting. However, no concrete legislative timeline has been issued since the announcement.

There are no mandatory requirements for corporate transition plans and/or their disclosure. However, listed companies subject to IFRS S2-aligned climate reporting obligations are required to disclose aspects of any transition plans they may have.

Regulated businesses subject to carbon fees are not required to set climate targets or have a transition plan in place. However, the relevant regulations encourage such businesses to voluntarily develop GHG emission reduction plans and set GHG reduction targets for 2030 based on the standards promulgated by the MOENV so as to qualify for a reduced carbon fee rate for meeting GHG reduction targets.

Companies are not generally required to disclose, set or meet climate-related targets. 

However, listed companies subject to IFRS S2-aligned climate reporting obligations are required to disclose details of any climate-related targets they have set or are required to meet.

In addition, to reduce the impact of climate change caused by new or changed “GHG Sources” (i.e. businesses on the List of Regulated GHG Emission Sources), under the CCRA, businesses with new or changed GHG Sources that reach a certain scale are required to carry out incremental GHG offsets by a certain percentage through voluntary reduction quota (including purchase thereof), obtaining certain reduction benefits (such as replacement of automobiles with EVs) or implementing the GHG reduction measures set forth under Article 29 of the CCRA. For the implementation of the GHG offset scheme, the MOENV promulgated the Regulations for the Management of Offsetting the Increased Greenhouse Gas Emissions on 12 October 2023. See section B.2 above for details.

Under the Waste Disposal Act (WDA), a mandatory extended producer responsibility scheme is in place for manufacturers and importers of certain categories of products and packaging. They are required to pay a recycling and disposal fee primarily based on business / import volume. An amendment to the WDA was passed in the Legislative Yuan on 16 Jun 2026 to extend the scheme to renewable energy power generation equipment manufacturers, importers, and installers.

In addition, the Resource Circulation Promotion Act (RCPA) authorises the MOENV to (a) establish green design standards for products and construction projects. The standards may include the compulsory usage of materials that are easily decomposable and durable, and incorporation of a certain proportion of recyclable materials; and (b) promulgate regulations regarding the issuance and restrictions on the use of a "circular product certificate" to prevent greenwashing.

As at the date of this publication, the amendments to the WDA have not yet formally taken effect, and the MOENV has not released any plans regarding the promulgation of ancillary regulations under the RCPA to operationalise the resource circulation measures.

Taiwan has yet to formally enact legislation similar to the EU’s CSDDD. The closest initiative is the draft Programme for Enterprises to Respect Human Rights in the Supply Chains (HR Programme) (previously known as the Guidelines on Business to Respect Human Rights) released by the Ministry of Economic Affairs (MOEA). The programme is intended to be implemented alongside an update to Taiwan's National Action Plan on Business and Human Rights. The HR Programme will recommend mechanisms for human rights due diligence and remediation by businesses, both within their operations and supply chains, as well as the reporting of these efforts' outcomes.

The MOEA has since embarked on an advocacy tour in October 2025 to inform the private sector about the government's plan and to gather their feedback on the draft HR Programme. According to the plan, the MOEA will adopt a phased approach, initially requiring listed companies in the manufacturing sector with a paid-in capital of NT$50 billion or more to conduct due diligence based on the HR Programme and disclose the results in their sustainability reports.

At present, the MOEA has not yet finalised the HR Programme. That said, the FSC has announced that human rights due diligence will be one of the social factors evaluated in their annual ESG assessment of listed companies.

Additionally, Taiwan's industries, which often act as a core pillar to the global supply chain, have recently come under increased scrutiny for their production methods, particularly concerning labour conditions. The Ministry of Labor has since issued the Guidelines for Enterprises to Prevent Forced Labor on 13 February 2026. The guidelines (though not of mandatory force) provide core indicators and frameworks for preventing forced labour, as well as practical tools regarding legal compliance for companies to assist them in navigating through the international trade restrictions and operational risks.

In addition to the Taiwan Taxonomy Guidelines for Sustainable Activities mentioned in section A.10, under Taiwan's Comprehensive Carbon Reduction Action Plan, the government plans not only to increase green spending but also to channel private sector capital into green and sustainable businesses.

One initiative is the MOENV's implementation plan for strengthening investment in green growth and net-zero industries through the creation of a green growth fund aimed at boosting investment in net-zero, sustainable and emerging industries. The National Development Fund operating under the Executive Yuan initially injected NT$10 billion to the fund, while simultaneously seeking to attract private capital for joint investment. The first group of private investors included investment companies, private equity funds and asset management firms, and the government has just completed its third round of the selection process.

The carbon fee mechanism mentioned in section B.2 further supports this cause. Based on the MOENV's announcement on 3 June 2026, this year the MOENV has collected around NT$5 billion of carbon fees from the regulated businesses, which will be used to implement greenhouse gas reduction and climate change adaptation work in accordance with the CCRA.

Government spending will also prioritise the procurement of low-carbon materials for infrastructure projects.

Other initiatives aimed at guiding private sector investment include the Trillian Dollar Investment National Development Plan, the National Credit Guarantee Mechanism, the ESCO Performance Credit Guarantee, and various tax credit programmes under the Industrial Innovation Act. Additionally, financing policies and programs related to green loans and green bonds, along with efforts to encourage investment in the green energy industry by life insurers, collectively seek to increase green investment and financing to over NT$5 trillion.

As mentioned in section B.6, the government is currently updating Taiwan's National Action Plan on Business and Human Rights, which will include the release of the HR Programme. Although the final version of the HR Programme is still under review, it is anticipated that the ESG framework in Taiwan will primarily focus on labour rights in the near future, with a particular focus on the rights of immigrant workers.

C. Greenwashing

Taiwan has yet to initiate any legal proceedings, regulatory actions, or investigations directly related to greenwashing. However, recent small-scale enforcement actions may indicate the government’s future focus on this issue. In both cases, the Fair Trade Commission fined the violators for misleading or deceptive claims - one for stating that its ESG conference was supported by the MOENV and the MOEA, and the other for claiming that its product was the only one in the store to receive a government subsidy for energy efficiency. 

No, but greenwashing conduct is likely to be subject to the regulatory and penalty regimes under the Securities and Exchange Act, the Fair Trade Act, and/or the Civil Code.

The possible grounds may include securities fraud, false statement, false advertising, and/or tort liabilities.

The MOENV has announced plans to introduce anti-greenwashing guidelines for businesses using sustainability awards and labels by the end of 2026. The guideline aims to regulate the use of such information in advertising, reports, and product sales, based on three key principles: truthfulness, proportionality in scope, and the prohibition of ambiguity. Following its introduction, the greenwashing prevention regime is expected to shift towards the implementation of stricter regulations, aiming to protect consumers and investors from being misled.

Given that a more comprehensive ESG disclosure regime has been established, it can be expected that regulatory or legal scrutiny of the accuracy of ESG disclosures may increase. However, based on public sources, there have been no related lawsuits or government enforcement as yet.

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This material is provided for general information only. It does not constitute legal or other professional advice.