Carbon accounting regulations in Asia-Pacific

According to the United Nations, the APAC region was responsible for more than half of global greenhouse gas (GHG) emissions in 2020 and is also particularly vulnerable to the climate change impacts. As the urgency to reduce GHG emissions increases and global discussions to provide more transparency on emissions advances, countries in the Asia-Pacific region are responding with regulations on monitoring, tracking, and reporting GHG emissions. 

In the final of three regional articles on carbon accounting and reporting, Enhesa experts Paula Galbiatti Silveira and Marina Dorileo draw attention to the existing and upcoming legislation in Japan, China, Malaysia, Australia, and New Zealand to tackle climate challenges.

Japan

Japan’s climate action initiatives benefit from three Acts focused on GHG emissions: 

• Ordinance on the Reporting of Calculated Greenhouse Gas Emissions (Joint Ministerial Ordinance No. 2 of 29 March 2006) 

• Enforcement Order of the Act on Promotion of Global Warming Countermeasures (Cabinet Order No. 143 of 7 April 1999) 

• Act on Promotion of Global Warming Countermeasures (Act No. 117 of 9 October 1998) 

Under these three Acts, companies classified as a Specified Greenhouse Gas (GHG) Emitter must measure and submit annual reports on their GHG emissions every June (if a Specified Transportation GHG Emitter) or July (if a Specified Facility GHG Emitter). 

A Specified GHG Emitter includes companies that: 

• Consume 1,500 KI or more energy in the previous year 

• Emit at least 3,000 tons of non-energy-related carbon dioxide (CO2) equivalent GHG, and employ a minimum of 21 regular workers 

Different gases have different calculation circles: 

• From 1 April through 31 March for CO2, CH4, and N2O 

• From 1 January through 31 December for HFCs, PFCs, SF6 and NF3 

Companies are recommended to use the voluntary Basic Guideline for Calculating Greenhouse Gas Emissions Throughout the Supply Chain to calculate their emissions.
 

SSBJ Standards 

Additionally, the country’s Sustainability Standards Board of Japan (SSBJ) issued their sustainability disclosure standards on 5 March 2025.  

Based on the International Sustainability Standards Board’s (ISSB) sustainability disclosure standards, SSBJ issued ‘Theme-based Sustainability Disclosure Standard No. 2 Climate-related Disclosures’ based on IFRS S2. Companies can apply the SSBJ Standards voluntarily. 

However, the standards were created with the assumption that they would become mandatory within the framework of the Financial Instruments and Exchange Act for companies listed on the Prime Market of the Tokyo Stock Exchange (TSE).

China

GHG emissions are regulated in China under several initiatives, for example: 

• Interim Regulation on the Management of Carbon Emission Trading 

• Management Measures on Carbon Emission Trading (Trial) 

• Guidance on Enterprise Greenhouse Gas Emission Measurement and Reporting-Power Generation Facilities 

These regulations require companies that are a Greenhouse Gas Key Emission Entity (engaging in an industry covered by the national carbon emission rights trading market with an annual GHG of 26,000 tons of CO2eq or more) to measure and submit their gross GHG emissions annually. 

Data must be submitted to the National Pollutant Discharge Permit Management Information Platform by 31 March each year.
 

Expansion of GHG accounting and reporting requirements 

GHG accounting and reporting requirements in China were recently expanded in March 2025 to include facilities in the iron and steel and aluminium smelting industries that emit above the mentioned threshold, according to the Work Plan for Including the Iron and Steel, Cement, and Aluminium Smelting Industries in the National Carbon Emission Trading Market.  

In particular, as of 11 April 2025, these facilities are required to submit the GHG emission report of 2024 by 30 June 2025, according to the Notice on Successfully Conducting Work Related to National Carbon Emission Trading Market in 2025.
 

GHG emissions reporting in annual sustainability report 

In China, designated listed companies must disclose the amount of GHG emissions in an annual report by 30 April, following Guidelines No. 14 and 17 of the Shanghai Stock Exchange (SSE) and the Shenzhen Stock Exchange (SZSE), respectively. 

Designated listed companies include: 

• Companies listed on SSE which are constituents of the SSE 180 Index or the STAR 50 Index, and companies listed simultaneously on SSE and overseas markets 

• Companies listed on SZSE which are constituents of the SZSE 100 Index, and companies listed simultaneously on SZSE and overseas markets

The company can refer to the voluntary instruments as applicable for procedures and methods for measuring GHG emissions:  

• Guide No.4 of Shanghai Stock Exchange for Self-Regulation of Listed Companies—Compilation of Sustainability Reports 

• Guide No.13 of SSE STAR Market for Self-Regulation of Listed Companies—Compilation of Sustainability Reports 

• Guide No.3 of Shenzhen Stock Exchange for Self-Regulation of Listed Companies—Compilation of Sustainability Reports

Malaysia

Only companies listed in the Bursa Malaysia stock exchange are required to prepare a Sustainability Statement that includes GHG emissions. 

The Bursa Malaysia Main Market Listing Requirements (MMMLR) mandates that listed companies must: 

• Prepare a statement on the management of material economic, environmental, and social risks and opportunities 

• Include disclosures on the common material sustainability matters set out in Annexure PN9-A — one of which is emissions management. A common indicator listed for emissions management is the company’s Scope 1, 2, and 3 GHG emissions in tons of CO2eq.  

Annual reports are part of the company’s obligation to remain listed on the Main Market of Bursa Malaysia.

Australia

In Australia, the National Greenhouse and Energy Reporting Act 2007 introduces a single national reporting framework for reporting and dissemination of information related to GHG emissions applicable to businesses emitting more than 25,000 tons of CO2eq or consuming more than 25,000 MW of electricity or 2.5 million liters of fuel per year.  

Obligations include: 

• Corporations that meet a National Greenhouse and Energy Reporting (NGER) threshold must report their GHG emissions by 31 October each year 

• Businesses emitting more than 25,000 tons of CO2or consuming more than 25,000 megawatts of electricity or 2.5 million liters of fuel in a year are required to report to the Greenhouse and Energy Reporting Officer (GEDO) and must register by the end of August following the financial year in which they have to report 

The mentioned report must be made in accordance with the National Greenhouse and Energy Reporting Regulations 2008, the National Greenhouse and Energy Reporting (Measurement) Determination 2008 and the National Greenhouse and Energy Reporting (Measurement) Technical Guidelines.
 

AASBS2 Climate-related Disclosures 

Also in Australia, the Corporations Act 2001 has been modified to incorporate the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024. Companies which meet the sustainability reporting threshold must produce annual sustainability reports containing: 

• Climate statements regarding material financial risks and opportunities 

• Metrics and targets relating to Scope 1, 2, and 3 emissions 

Sustainability reports must also include information from the Australian Sustainability Reporting Standards, which refer to the AASBS2 Climate-related Disclosures — a mandatory Standard based on the mentioned IFRS S2, which applies to reporting periods beginning on or after 1 January 2025.  

In addition, companies can use the Greenhouse Gas Protocol Scope 3 Calculation Guidance to assist them with Scope 3 GHG emissions accounting.

New Zealand

In New Zealand, carbon accounting and reporting regulations derive from the New Zealand Emissions Trading Scheme and by sustainability reporting requirements. 

Participant companies (those that undertake activities listed in Schedule 3 or 4 of the Climate Change Response Act 2022 such as industrial processes, including producing iron, steel, aluminum or clinker) in the New Zealand Emissions Trading Scheme must: 

• Collect the prescribed data 

• Calculate the emissions and the removals from the emission-releasing activity in accordance with the methodologies prescribed in regulations 

• Keep records of the data or information and calculations for a period of 20 years after the end of the year to which they relate 

Prescribed data and methodologies relevant to the general industry are covered under the Climate Change (Stationary Energy and Industrial Processes) Regulations 2009.
 

Aotearoa New Zealand Climate Standard 1 Climate-related Disclosures (NZ CS 1) 

The Financial Markets Conduct Act 2013 requires companies that are a Climate Reporting Entity (large, listed companies with a market capitalization of over NZD 60 million) and others to prepare climate-related disclosures (CRDs) according to the standards developed in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and lodge them with the Registrar. 

Additionally, applicable companies must report according to the NZ CS1, based on the TFCD Recommendations, which are now part of the ISSB Standards.

The increasing scrutiny on carbon emissions

Global commitments to address climate changes under the Paris Agreement and to limit the increase of global temperature to 1.5 degrees Celsius accelerate efforts to diminish GHG emissions, as well as manage climate risks. Authorities around the world are implementing stricter GHG monitoring and reporting obligations for companies following a global alignment on disclosure standards to ensure quality climate-related information is available.  

Read more about the carbon accounting and reporting regulatory landscape in Europe and the United States, as well as staying ahead as voluntary policies shift to mandatory laws.