Southeast Asia Sustainability Reporting Watch: Indonesia, Thailand and Vietnam

Vietnam put a price on carbon for 110 industrial facilities before it finished rewriting the disclosure rules for its listed companies.

That inversion says more about the region than any comparison table. These three markets are not moving through the same sequence at different speeds. They are moving through different sequences entirely, and a supplier trying to work out what it will be asked for next year has to track each one separately.

Indonesia Has The Standards And Is Now Writing The Mandate

The Indonesian Sustainability Standards Board, DSK IAI, ratified PSPK 1 and PSPK 2 on 1 July 2025. You will also see them written as SPK 1 and SPK 2, which is the same pair of standards. PSPK 1 covers general sustainability disclosure requirements and PSPK 2 covers climate, mirroring IFRS S1 and IFRS S2 respectively. Both take effect on 1 January 2027.

Standards without a mandate are just guidance, and OJK spent the first quarter of this year fixing that. Its draft regulation went to consultation on 22 February 2026, closing on 13 March, and would require disclosures based on PSPK 1 and PSPK 2 across financial sector entities, issuers and public companies.

The phasing runs in two waves. Main board issuers, large banks and the stock exchange itself come in from 2027. Additional listed entities, debt issuers and smaller banks follow across 2028 and 2029.

Worth pinning down before you plan around it: whether "from 2027" means reporting during 2027 on the 2026 financial year, or reporting on the 2027 financial year. Commentary is split, and the two readings are a full year apart. If it is the first, the relevant data collection year is the one currently running.

Two features of the draft deserve more attention than they have received. In-scope organisations would have to publish transition plans, and the reported information would require mandatory independent assurance. Assurance from the first cycle is unusual for a first-time regime, and it is the provision most likely to determine whether Indonesian reporting quality outruns the regional average or gets bogged down in capacity constraints.

None of this displaces POJK 51, the 2017 regulation that has required sustainability reports from financial services institutions, issuers and public companies for years. Companies already producing those reports are not starting from zero. They are starting from a document built on a different logic, and converting a POJK 51 narrative into a PSPK 2 climate disclosure is a rebuild rather than a reformat.

The Indonesian Taxonomy Is On Its Third Version In Three Years

TKBI, the Indonesia Taxonomy for Sustainable Finance, reached Version 3 on 5 February 2026, launched at the annual financial services industry meeting.

Version 2, from February 2025, covered construction and real estate, transportation and storage, and part of agriculture. Version 3 adds advanced criteria for agriculture, forestry and fishing, manufacturing across two batches, and water supply, sewerage, waste management and remediation, plus enabling sectors including information and communication and professional, scientific and technical activities.

Two concepts arriving in Version 3 matter for anyone financing a long-lived asset. Sunsetting sets an expiry on technical screening criteria, so an activity that qualifies today may not qualify at reassessment. Grandfathering protects financial instruments issued under earlier criteria. Together they answer the question every project sponsor asks, which is what happens to my classification when the thresholds tighten.

Version 3 also introduces entity-level and portfolio-level assessment alongside activity-level screening, and applies a sector-agnostic decision tree for do-no-significant-harm testing. Coverage is aimed at sectors relevant to Indonesia's nationally determined contribution.

Thailand Has The Clearest Timetable In The Region

The Thai SEC consulted on an ISSB roadmap that closed on 19 December 2024, and the resulting schedule is the most specific of the three countries.

SET50 companies report in 2027 for the 2026 reporting period. SET100 companies follow in 2028 for 2027. Other SET-listed companies and IPO candidates come in during 2030 for the 2029 period. Companies listed on mai, together with REITs, infrastructure funds and trusts and property funds, arrive in 2031 for 2030. Reporting is at consolidated entity level, and foreign-incorporated listed companies are in scope alongside Thai ones.

No modifications to IFRS S1 or S2 have been proposed, which is worth noting because several Asian jurisdictions have taken the opposite route. What Thailand proposes instead is a set of transition reliefs running for five years: a climate-first approach covering IFRS S2 plus the climate-relevant parts of IFRS S1, permission to publish sustainability information at a different time from the financial statements, optional Scope 3 disclosure, and flexibility on greenhouse gas measurement methods. Limited assurance on greenhouse gas information is required.

Until that regime bites, Form 56-1 One Report remains the operative obligation. It has applied since financial periods ending 31 December 2021, consolidates the registration statement and annual report into one filing, and already requires sustainability content across policies and targets, stakeholders and value chain, environmental performance including greenhouse gas emissions, social performance, and compliance incidents. Filing is due within three months of the fiscal year end through SETLink.

A Thai company that treats 56-1 One Report as a compliance formality and the ISSB roadmap as a 2027 problem has misread the gap between them. The SET50 first report covers the 2026 financial year, which is the year currently running.

Thailand's Taxonomy Now Covers The Emitting Sectors

Phase 1 was published on 30 June 2023 with detailed criteria for energy and transport. Phase 2 followed on 27 May 2025, extending to agriculture, construction and real estate, manufacturing and waste management, and bringing the taxonomy to six sectors.

It was developed by the Thailand Taxonomy Board, a grouping of 32 public and private agencies led by the Department of Climate Change and Environment, the Bank of Thailand, the SEC and the Stock Exchange of Thailand, with support from the IFC, GIZ and ADB. Six environmental objectives sit behind it: climate mitigation, climate adaptation, sustainable use and protection of marine and water resources, resource resilience and circular economy transition, pollution prevention and control, and biodiversity and ecosystem protection.

Two features distinguish it from the EU model. Classification is a traffic light rather than a binary: green for activities at or close to net zero by 2050 on a 1.5 degree pathway, amber for transitional activities with credible decarbonisation pathways and prescribed sunset dates at 2040, red for activities not compatible with a net zero trajectory and due to be phased out. And the whole thing is voluntary, a common reference tool for financial institutions assessing clients rather than a binding classification.

Amber with a 2040 sunset is the category Thai manufacturers should look at hardest. It is a financing runway with an expiry date printed on it.

Vietnam Went At It From The Other End

Decree 29/2026/ND-CP, published on 3 March 2026, operationalises Vietnam's first domestic carbon trading exchange by plugging it into existing securities market infrastructure. The Hanoi Stock Exchange provides the trading platform. The Vietnam Securities Depository and Clearing Corporation handles custody and settlement. The Ministry of Agriculture and Environment runs the national registry. Securities companies act as trading and depository members.

Decision 263/QD-TTg, signed by Deputy Prime Minister Tran Hong Ha in February 2026, names the covered facilities: 34 thermal power plants, 25 steel producers and 51 cement plants. Pilot allocations run to 243,082,392 tonnes of CO2 equivalent for 2025 and 268,391,454 tonnes for 2026. The Ministry of Agriculture and Environment leads distribution alongside the Ministry of Industry and Trade and the Ministry of Construction, assigning facility-level quotas and issuing implementation guidance. Expansion of sectoral coverage is contemplated after 2028.

Obligations on covered entities are concrete and immediate. Monitoring, reporting and verification systems. Registered quotas deposited with custodians before trading. Segregated accounts for carbon transactions. Periodic and ad hoc reporting to authorities.

Sitting underneath, Decree 06/2022/ND-CP requires facilities emitting above 3,000 tonnes of CO2 equivalent a year to submit emissions inventories.

Listed-company sustainability disclosure is the piece still in motion. Circular 96/2020/TT-BTC, effective since 1 January 2021, remains the governing instrument, and the State Securities Commission has been reviewing amendments to bring reporting closer to international standards. No date has been fixed. For a Vietnamese cement producer, this means the carbon compliance obligation is live and quantified while the disclosure obligation is still a consultation.

Vietnam's Green Taxonomy Is Already Binding

Decision 21/2025/QD-TTg was issued on 4 July 2025 and took effect on 22 August 2025, giving Vietnam its first legally binding green taxonomy. It spans seven industry groups and 45 project types across energy, transport, construction, water resources, agriculture and forestry and fisheries and biodiversity conservation, manufacturing, and environmental services.

Qualification requires two things. The project needs the appropriate environmental impact assessment approval, environmental permit or registration unless exempt. And it must meet sector-specific technical benchmarks, such as zero-emission vehicles in transport, green building certification in construction, or water loss at or below 15 per cent for new systems.

Confirmation comes either from the environmental authority during the EIA or permit process, or from an independent certified third party. Classification unlocks eligibility for green credit and green bonds under the Environmental Protection Law framework.

What EU And Japanese Buyers Will Actually Ask For

Here is the part regional suppliers keep getting wrong. Your obligation date is not the date that matters. Your customer's is.

Japan issued its own standards through the SSBJ on 5 March 2025: a universal application standard plus Theme-based Standard No. 1 on general disclosures and No. 2 on climate, designed to be functionally aligned with ISSB. The FSA's discussed phasing starts with companies above 3 trillion yen market capitalisation for periods ending March 2027, then 1 trillion yen for March 2028, 500 billion yen for March 2029, and the remainder of listed companies during the 2030s. Limited assurance on sustainability information has been discussed.

Work the arithmetic. A Japanese customer in the first tier needs its FY2026 value chain emissions data now, from suppliers whose own home mandates start in 2027 at the earliest. The request arrives before the obligation does, every time.

The European position is similar in shape and different in mechanism. CSRD reporters face a value chain cap that limits what they can require from smaller suppliers, but the cap governs mandatory information demands, not contractual terms. Purchase agreements routinely ask for what the cap would not compel.

EUDR is the blunter instrument. Following the targeted revision in Regulation (EU) 2025/2650, due diligence applies from 30 December 2026 for large and medium operators and 30 June 2027 for micro and small enterprises. For Indonesian palm oil, Vietnamese coffee and rubber, and Thai rubber, that is a geolocation and traceability obligation sitting entirely outside any disclosure regime, and the revision shifted the filing burden upstream: only the first operator placing a product on the EU market submits a due diligence statement, with downstream operators retaining the reference number. If you are the first operator's supplier, the data request lands on you.

The asymmetry runs one way. Buyers in Tokyo and Frankfurt are inside their own compliance cycles. Suppliers in Jakarta, Bangkok and Ho Chi Minh City are mostly not, yet. The gap is filled by contract.

What To Build Now

Get greenhouse gas accounting to facility level with a defensible methodology, whichever country you are in. Every regime described above resolves to this, and it is the one asset that serves the local mandate, the customer questionnaire and the financing application at the same time.

Map your product to your national taxonomy before your bank does. TKBI Version 3, Thailand Taxonomy Phase 2 and Decision 21 all now cover manufacturing or construction in some form. Knowing where you sit is cheaper than being told.

If you sell into Japan, ask your largest customers which SSBJ tier they fall into and when their first report is due. That date, minus one year, is when they will need your numbers.

If you sell into the EU, separate what the value chain cap protects you from and what your contract already commits you to. They are not the same set.

For Vietnamese facilities in power, steel or cement, treat the MRV build as the priority. Quota trading requires data quality that emissions inventory reporting does not, and the accounts and custody arrangements have to exist before the first trade.

The common error across all three markets is sequencing readiness against the local rule. The local rule is the last deadline you will face, not the first.

Position as of 25 September 2026. OJK's ISSB-aligned regulation was at draft stage following consultation and the final form and dates may differ. Thailand's ISSB roadmap reflects the SEC's proposed approach following its 2024 consultation. Japan's SSBJ application timeline reflects FSA discussions and had not been finalised in regulation. Vietnam's carbon market pilot and disclosure rules continue to develop. Confirm current requirements against OJK, DSK IAI, the Thai SEC, the Stock Exchange of Thailand, Vietnam's State Securities Commission and Ministry of Agriculture and Environment, the Japanese FSA, and your own advisers.

Sources

Otoritas Jasa Keuangan, Dewan Standar Keberlanjutan, PSPK 1 and PSPK 2 Sustainability Disclosure Standards, Indonesia Taxonomy for Sustainable Finance, Securities and Exchange Commission, Stock Exchange of Thailand, Bank of Thailand, Thailand Taxonomy Board

This article is intended for general professional information and does not constitute legal, financial, or investment advice.