Divergent Paths: A Comparative Analysis of Climate Disclosure Regulation in China and Japan

Abstract

In the context of the continuous intensification of climate change, standardized corporate information disclosure has become a crucial issue. This study, by using the “Corporate Sustainability Reporting Directive” (CSRD) of the European Union as a benchmark, conducted a comparative analysis of the different climate information disclosure regulatory models in the two largest economies in Asia—China and Japan. The analysis revealed that Japan adopted a market-oriented and investor-centered model, adhering to the “financial significance” principle. In contrast, China implemented a state-led, top-down system, adopting the “dual significance” principle, incorporating national strategies such as the “dual carbon” goals into corporate reports. The study concluded that this disparity is not merely a technical issue but is deeply rooted in the unique political, economic, and corporate governance traditions of each country, challenging the possibility of forming a single global sustainable development reporting standard.