What each market requires — and how Clidapt helps you comply.
Spain has some of the EU’s most active sustainability reporting requirements. Non-financial reporting began under Law 11/2018, the EU CSRD is being transposed into Spanish law (the "LEIS" bill), and since June 2025 Royal Decree 214/2025 requires large companies to publish their carbon footprint and a GHG reduction plan. SMEs typically respond to these demands using the voluntary VSME standard.
Across Latin America, sustainability reporting is moving from voluntary to mandatory, largely by adopting the ISSB’s IFRS S1 and S2 standards. Brazil’s securities regulator (CVM) makes ISSB-based reporting mandatory for listed companies from 2026, and Mexico’s CNBV requires IFRS S1/S2-aligned reports for issuers from the 2025 financial year. Companies of all sizes increasingly face value-chain ESG requests.
The EU has the world’s most comprehensive sustainability reporting regime. Large companies report under the CSRD using the European Sustainability Reporting Standards (ESRS) on a double-materiality basis, though the 2025–2026 Omnibus reform narrowed the scope to larger companies. SMEs use the voluntary VSME standard to meet value-chain requests.
The UK requires large companies to report energy and carbon data under SECR (Streamlined Energy and Carbon Reporting) and mandates TCFD-aligned climate disclosures for large companies and LLPs. The UK is also developing UK Sustainability Reporting Standards (UK SRS) based on the ISSB’s IFRS S1/S2.
In the US there is currently no federal mandatory climate disclosure rule — the SEC’s 2024 climate rule was abandoned and proposed for rescission in 2026. State-level rules lead instead: California’s SB 253 requires large companies doing business in California to disclose Scope 1, 2 and 3 emissions, with first reporting in 2026 (SB 261, on climate risk, is currently paused by litigation).