Japan: FSA and TSE (Financial Services Agency and Tokyo Stock Exchange)

TCFD-aligned and SSBJ/ISSB-based sustainability disclosure for Prime Market companies.
Status: Phased rollout from 2022; new SSBJ standards effective from FY2026[1][2][3][4][5][7][9].
Prime Market Companies
~1,600
Top tier of TSE, phased SSBJ adoption[3][4]
Mandatory Since
2022
TCFD-aligned climate disclosure for Prime Market[5][6]
SSBJ Standards
2025
Finalized March 2025, effective FY2026[2][3][4][7]
Scope 1 & 2 Emissions
Required
Prime Market, phased for all listed[4][5]
Japan Sustainability Disclosure Requirements
EntityFrameworkKey RequirementsStatus
TSE Prime Market (≥¥3T market cap)TCFD, SSBJTCFD pillars, Scope 1 & 2 GHG, climate targets, board oversightMandatory FY2026[2][3][4][5][7]
Other Prime MarketTCFD, SSBJPhased adoption, same requirements as above2027–2029[3][4][7]
Growth/Standard MarketVoluntary (TCFD, SSBJ)Encouraged, may become mandatoryPending
Unlisted/Financial InstitutionsVoluntary/RequestedDisclosure if requested by investors/partnersGrowing[3][5]
Japan Sustainability Disclosure Timeline
YearMilestoneStatus (2025)
2021TCFD-aligned disclosure required for Prime MarketActive
2022Climate disclosure in statutory securities filingsActive
2023FSA drafts SSBJ standards, public consultationConsultation
2025SSBJ standards finalized (March), handbook publishedComplete[2][3][7]
2026SSBJ standards effective for large Prime MarketMandatory[2][3][4][7]
2027+Phased expansion to all Prime Market, then othersPlanned[2][3][4][7]
Japan: Entity Coverage by Disclosure Regime (2025, est.)
Estimated number of companies by disclosure status (2025).
Japan Integration and Influence
  • Alignment: SSBJ standards based on IFRS S1/S2, TCFD pillars[1][2][3][4][7][9]
  • Legal status: Disclosure in statutory annual securities filings[2][3][4][5][7]
  • Governance: Board oversight and ESG strategy required[2][3][4][5][7]
  • Comply or explain: TSE governance code for sustainability/ESG[5][6]
  • Phased expansion: Gradual rollout to all Prime Market, then Growth/Standard[2][3][4][7]

About Japan’s Sustainability Disclosure Regime

Japan’s sustainability disclosure system, led by the FSA and TSE, is now among the most advanced globally, requiring TCFD-aligned and SSBJ/ISSB-based reporting for Prime Market companies[1][2][3][4][5][7][9]. The new SSBJ standards, finalized in March 2025, mandate climate and sustainability disclosure in statutory filings, with phased expansion to all major listed companies by 2029. The regime emphasizes board-level governance, strategic ESG integration, and international alignment, setting a high bar for transparency and comparability in Asia.

Note: All data reflects official FSA, TSE, SSBJ, and industry updates as of May 2025.

Japan - FSA & TSE (Financial Services Agency & Tokyo Stock Exchange)