TCF POST Special Report


Taiwan’s revised sustainability disclosure roadmap could reduce the reporting burden on smaller listed companies while preserving climate-related transparency requirements, with implications for textile and clothing manufacturers connected to Taiwanese brands, investors and global supply chains.

The key policy development is the adjustment announced on September 23, 2026, by Taiwan’s Financial Supervisory Commission (FSC) and Ministry of Environment (MOENV). The revised approach narrows the group required to adopt the full IFRS Sustainability Disclosure Standards and gives some smaller companies more time to develop comprehensive reporting systems.

The implications extend beyond listed companies. Textile mills, garment manufacturers, dyeing and finishing plants, and material suppliers may face continued requests from customers for reliable greenhouse-gas emissions data, even when they are not directly subject to the full disclosure requirements.

Full adoption narrowed to about 560 companies

The official FSC announcement, issued jointly with the MOENV on September 23, revises Taiwan’s original 2023 roadmap for aligning listed companies with the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards.

Under the revised policy, full mandatory adoption will cover approximately 560 listed companies, down from around 1,970. The eligible group comprises companies with paid-in capital of at least NT$2 billion and smaller companies that fall under the environment ministry’s mandatory greenhouse-gas inventory and verification regime.

The authorities said the adjustment reflects concerns over smaller companies’ limited resources, difficulties identifying material sustainability issues beyond climate change, and problems obtaining reliable supply-chain data.

The revised arrangements retain a distinction between comprehensive sustainability reporting and basic climate disclosure:

  • Around 560 companies: required to adopt the applicable IFRS sustainability standards under the revised scope.
  • Smaller companies outside mandatory environmental oversight: still required to disclose basic climate governance, risk management and Scope 1 and Scope 2 greenhouse-gas emissions.
  • Scope 3 emissions: voluntary for companies in the third implementation phase under the revised transitional arrangements.

The government has maintained its overall sustainability objectives while adjusting the reporting burden and implementation requirements.

Climate reporting comes first for smaller companies

The revised roadmap gives third-phase companies a longer transition period. During their first two years of adoption, they will need to report climate-related information, while broader sustainability disclosures beyond climate will begin in the third year.

The change is particularly relevant to textile and clothing businesses because collecting data across a production chain can be more difficult than measuring emissions at an individual facility.

For example, a textile manufacturer may need to track fuel consumed by boilers, electricity used in spinning and dyeing, and emissions associated with purchased materials and upstream suppliers. Scope 3 reporting can extend further across the value chain, making data collection more demanding.

The revised policy also removes the requirement for second- and third-phase companies to obtain independent assurance of Scope 1 and Scope 2 emissions at the parent-company standalone level. Consolidated group-level reporting requirements remain subject to the applicable schedule.

During the first two years, companies may also defer filing their dedicated sustainability chapter until the annual-report deadline—14 days before the annual general meeting—if they cannot file it alongside their financial report by the end of March.

What it means for textile and clothing supply chains

For the textile, clothing and footwear industry, the most important distinction is between direct regulatory obligations and commercial demands from customers.

The revised rules do not automatically exempt a textile mill or garment exporter from sustainability information requests made by a listed customer. Brands and manufacturers may still need emissions data from suppliers to prepare their own disclosures, manage climate risks and assess progress against reduction targets.

The continued requirement for basic climate reporting by smaller listed companies also means the transition is not being abandoned. Rather, Taiwan is prioritising comprehensive reporting by larger and environmentally significant businesses while allowing other companies more time to develop the necessary systems.

For suppliers, the practical priorities remain:

  • Establish reliable records of electricity and fuel consumption.
  • Improve the consistency of emissions data across production facilities.
  • Build systems for collecting information from upstream material suppliers.
  • Distinguish measured emissions from estimates and clearly document calculation methods.
  • Prepare for customer reporting requests even when the supplier is not directly covered by full IFRS adoption.

These are industry implications of the policy, rather than additional legal requirements specifically imposed on every textile or clothing supplier.

Implementation and next steps

The FSC said it would revise the relevant roadmap documents and review annual-report regulations and related orders by the end of 2026. It also plans to provide practical guidance, industry-specific disclosure examples and training, while coordinating with the MOENV to improve product carbon-footprint emission factors and reduce duplicate verification work.

The authorities plan to review the arrangements again in 2030, taking account of international developments, disclosure quality and companies’ readiness.

For Taiwan’s textile and clothing sector, the revised roadmap offers smaller businesses additional time to strengthen their reporting capacity. However, it does not remove the commercial importance of carbon transparency. Suppliers seeking to maintain relationships with international brands and buyers will still need credible, consistent environmental data as sustainability reporting becomes more closely linked to financial risk management and supply-chain decisions.