Reporting Beyond India: ISSB, CSRD, CBAM and What Buyers Are Asking
For most Indian companies the international sustainability regime is not a filing obligation. It is a contractual one: a customer subject to it asks for data, and the request arrives with a purchase order rather than a notice. Understanding which regime is driving the request is what allows a sensible answer, particularly now that the largest of them has been cut back substantially.
- The international standards, and India's position on them
- The European reporting directive after the simplification package
- The carbon border mechanism, now in its definitive phase
- The deforestation regulation, and where the pressure actually comes from
And what India has done about them
The two international sustainability disclosure standards, on general requirements and on climate, were issued in June 2023 and are effective for annual reporting periods beginning on or after 1 January 2024. Earlier application is permitted, provided both standards are applied at the same time and the entity discloses that it has done so. The climate standard integrates and builds on the recommendations of the climate disclosure task force and incorporates industry-based metrics.
The task force does not exist
The climate disclosure task force issued its sixth and final status report on 12 October 2023, stated that it had fulfilled its remit, and disbanded. At the financial stability board's request the international standard-setter's foundation took over monitoring companies progress on climate-related disclosure from 2024 and published its first successor monitoring report in November 2024. The recommendations themselves remain available as a standalone framework and implementation resource, and were fully incorporated into the international standards, shaping the governance, strategy, risk management and metrics architecture of both, with the climate-specific requirements reflected principally in the climate standard. A company applying both standards meets the recommendations. What no longer exists is the body. Any framework document, engagement letter or report that refers to the task force as a current body is referring to something that was wound up three years ago. This is the single most common dated reference in Indian sustainability material.
On 11 December 2025 the standard-setter issued targeted amendments to the climate standard on greenhouse gas emissions disclosures, intended to reduce complexity, duplication and cost in applying specified requirements. They apply to annual reporting periods beginning on or after 1 January 2027, may be applied earlier, and an entity applying them early must disclose that fact. They amend the climate standard only and do not change its original effective date.
The four reliefs are narrower than they are often described. An entity may exclude emissions associated with derivatives, facilitated emissions and insurance-associated emissions when measuring and disclosing Scope 3 category 15 emissions, identifying and explaining what it excluded; this is not a general exemption from financed-emissions reporting. Where a jurisdictional authority or an exchange on which the entity is listed requires a different greenhouse gas measurement method, global warming potential values, or industry classification for disaggregating financed emissions, the entity may use what is required of it instead of what the standard otherwise specifies. The relief is not a free choice of protocol version: it bites only where another authority mandates something different.
India has not adopted these standards. There is no notification adopting them and the mandatory Indian regime remains the business responsibility and sustainability report. The Institute is running awareness activity, which is education rather than adoption. The accurate framing for an Indian entity is that the international standards matter through group reporting for a foreign parent, through lender and investor demand, and through voluntary adoption, not through Indian law.
Nor has India notified sustainability reporting standards corresponding to the two international ones, and no adoption or convergence roadmap, effective date or phased population had been announced by the ministry, the oversight authority, the securities regulator or the Institute as at 17 September 2026. India is not among the jurisdictions for which the foundation has published a final adoption profile.
That is not the same as saying nothing applies. Mandatory sustainability reporting already exists in India under the securities regulator's report, its core and the industry standards that go with it. What should not be confused with Indian equivalents of the international reporting standards are those requirements, the Institute's assurance material, which governs engagements rather than preparation, the social audit standards, which apply within their own framework, and the Institute's maturity model and guidance notes, which are guidance and not notified standards. The Institute's May 2026 general sustainability-assurance document remains an exposure draft.
Assigning an Indian effective date to standards that have not been adopted would be a serious error. General statements supporting international comparability, or participation in the standard-setter's discussions, are not an adoption roadmap.
Cut back, and still moving
This is the most volatile item on any Indian sustainability page, because the European Union has spent 2025 and 2026 reducing the scope of a directive it adopted in 2022.
A simplification package was presented on 26 February 2025. Directive (EU) 2025/794 of 14 April 2025, in force from 17 April 2025, postponed the second and third reporting waves by two years and postponed the related due diligence timetable by one year. First-wave undertakings, large public interest entities already subject to the earlier non-financial reporting directive, reported for financial years beginning in 2024 as planned, and a targeted relief adopted on 11 July 2025 and published as Commission Delegated Regulation (EU) 2025/1416 extended specified transitional reliefs for their 2025 and 2026 reporting.
The substantive simplification is no longer a political agreement. It is law. Parliament adopted the text on 16 December 2025, the Council approved it on 24 February 2026, and it was enacted as Directive (EU) 2026/470 of 24 February 2026, published on 26 February and in force from 18 March 2026. Member States must transpose the reporting amendments by 19 March 2027.
The threshold is not merely more than 1,000 employees, which is how the Commission proposal is still widely described. For an EU undertaking both conditions must be met, at group level where appropriate.
| Population | Final threshold | First reporting period |
|---|---|---|
| Existing first-wave entities | The original first-wave population for FY 2024 to FY 2026, but a Member State may exempt an entity below either new threshold for FY 2025 and FY 2026 | FY 2024, reported in 2025 |
| Permanent scope, EU undertakings | Both net turnover above €450 million and an average of more than 1,000 employees, tested at group level where applicable. The two are cumulative, not alternatives. | Financial years beginning on or after 1 January 2027, reported in 2028 |
| Listed small and medium entities, formerly the third wave | Removed from mandatory scope | No mandatory reporting wave |
| Non-EU groups | More than €450 million EU turnover in each of the two preceding consecutive financial years, plus an EU subsidiary or branch above €200 million turnover | Financial years beginning on or after 1 January 2028, reported in 2029 |
Directive (EU) 2026/470, subject to national transposition and the transitional exemptions, so the immediate position of a particular company must be checked against the implementing law of the relevant Member State.
The value chain cap, which is the part that reaches an Indian supplier
The enacted directive protects an undertaking in the reporting group's value chain that does not exceed an average of 1,000 employees in the preceding financial year. There is no turnover condition attached to this protection. For a request made to satisfy the reporting obligation, such a supplier may give a self-declaration that it has no more than 1,000 employees, which the European undertaking ordinarily need not verify; the supplier has a statutory right to refuse information exceeding what the EU voluntary reporting standard prescribes; a contract cannot require more, and a contractual provision purporting to do so is not binding; if more is asked for, the reporting undertaking must say that it exceeds the voluntary standard and tell the supplier of the right to refuse; and the reporting undertaking is treated as having complied without obtaining it. Until the delegated voluntary standards apply, the reference point is Commission Recommendation (EU) 2025/1710, based on the EFRAG standard for small and medium entities. Two limits matter. The protection covers requests made for sustainability reporting; it does not touch requests under the EU due diligence legislation, another legal requirement, or an independent commercial purpose. And the directive imposes no reporting obligation on the Indian supplier at all: it gives a right to decline, and that right operates through the transposing law of the Member State.
What this means for an Indian supplier
The correct 2026 message is not that European reporting is coming for you. It is that the scope has been cut back sharply and the dates pushed out, so the live exposure is the value chain data request from a customer that remains in scope, not a direct filing obligation of your own. If a customer is asking for data, ask them which regime the request arises under and which reporting year it relates to. A surprising number of requests are made under a version of the rules that has since been changed.
Definitive from January 2026
The mechanism was established by Regulation (EU) 2023/956 of 10 May 2023, ran a transitional reporting-only period from 2023 to 2025, and applies in its definitive regime from 1 January 2026, bringing authorisation requirements, reporting, and the purchase and surrender of certificates. Regulation (EU) 2025/2083 of 8 October 2025, simplifying and strengthening it, was published on 17 October and entered into force on 20 October 2025.
That regulation introduced an annual exemption where an importer's cumulative net imports of cement, fertilisers, aluminium, and iron and steel do not exceed 50 tonnes in a calendar year. Electricity and hydrogen are outside the exemption. If the threshold is exceeded the obligations apply to every covered import made during that year, including the first 50 tonnes, not merely to the excess, which is the point most commonly got wrong.
Certificate sales begin through the common central platform on 1 February 2027, and certificates bought in 2027 cover emissions embedded in goods imported during 2026. The first annual declaration and the first surrender, both covering calendar year 2026, are due by 30 September 2027.
Indian exposure is concentrated in iron and steel, aluminium, cement and fertilisers. The practical obligation falls on the European importer, but the data has to come from the Indian producer, which is why it arrives as a customer request rather than as a regulatory notice. An exporter in those sectors that cannot produce embedded emissions data at product level is at a commercial disadvantage regardless of what the regulation requires of it directly.
December 2026, and it reaches more sectors
The regulation applies from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators, except micro and small operators already covered by the earlier timber regulation, who are bound from 30 December 2026. It was amended in December 2024 and December 2025, the later amendments adding simplification measures intended to reduce administrative cost and compliance burden. The commodities covered are cattle, wood, cocoa, soy, palm oil, coffee and rubber, plus derived products including leather, chocolate, tyres and furniture.
Indian exposure is in coffee, rubber and tyres, leather, and wood products, and the obligation is a due diligence and geolocation one rather than an emissions one. It reaches a quite different set of Indian exporters from the carbon border mechanism, and considerably more smallholder-based supply chains, which is what makes it hard.
Where to go next
Environmental, Social, and Governance
Back to the main page: what we do, how an engagement is structured, and how to reach us.
Business Responsibility and Sustainability Reporting: Who Reports, What, and From When
The reporting obligation, how the top one thousand population is actually determined since the 2024 change, the nine core attributes subject to verification, and the glide path year by year.
Getting the Core Verified: Assurance, Assessment and the Independence Bar
The 2025 change from reasonable assurance to assurance or assessment, who may provide it, the conflict rules that decide which firm can do what, and the standards an engagement is conducted under.
Building an ESG Framework That Survives Contact With the Data
Why most sustainability programmes fail at the data layer rather than the policy layer, how to run a materiality assessment that is defensible, integrating sustainability into governance and risk, and what a first year should actually attempt.
Environmental Compliance: Producer Responsibility, Carbon Credits and Energy
The compliance obligations underneath the reporting: extended producer responsibility across plastic, electronic and battery waste, the carbon credit trading scheme, and the energy efficiency regime it sits alongside.
Send an enquiry
If a customer has sent you a sustainability questionnaire, send it to us. Which regime it arises under usually determines how much of it you actually have to answer, and the answer is often less than it appears.
Position as at 17 September 2026. Reviewed every six months.
This page is general information, not professional advice. Sustainability regulation is the fastest-moving area on this website and the one where published material ages worst. The securities regulator has softened its assurance requirement, made value chain reporting voluntary and redefined who counts as a value chain partner, all since 2024. The European Union has cut back the scope of its reporting directive and pushed out its dates. The climate disclosure task force was disbanded in 2023. Any advice in this area needs a date on it. Take professional advice before acting on anything on this page. We are happy to be that adviser, but we do not act on a web page, ours or anyone else's, without one.