Climate Change Administration

To lighten the reporting burden on enterprises and align with the EU Omnibus I initiative's trend toward relaxation and simplification, the Ministry of the Environment (MOENV) and the Financial Supervisory Commission (FSC) have engaged in inter-ministerial negotiations. The two agencies will harmonize greenhouse gas (GHG) inventory regulations and jointly establish Scope 3 industrial carbon emission factors to prevent redundant work and lower corporate costs. Furthermore, addressing the proliferation of expensive ESG awards and consulting services, the MOENV plans to issue anti-greenwashing guidelines by the end of 2026 to build a transparent and credible green ecosystem, guiding enterprises toward genuine carbon reduction.

一、Clarifying Assurance Standards to Ease Scope 3 Concerns Among Enterprises

Late last year, the FSC announced a three-phase roadmap for TWSE and TPEx-listed companies to align with the IFRS Sustainability Disclosure Standards. Phase 3 companies (with paid-in capital under NT$5 billion) will begin preparing sustainability-related financial information under these standards starting in 2028, with formal reporting commencing in 2029.

To provide maximum flexibility, Scope 3 disclosure for Phase 3 enterprises will be deferred until the fourth fiscal year after adopting the standards (i.e., 2032). Additionally, current IFRS standards do not require third-party assurance for Scope 3 data, significantly reducing initial compliance costs. Recognizing the resource constraints of small and medium-sized enterprises (SMEs), the FSC is surveying 1,700 companies to evaluate deferring disclosure requirements for "sustainability information beyond climate" and "Scope 3 emissions" for SMEs.

二、Harmonizing Inventory Rules and Prioritizing Scope 3 Factors for Electronics and Semiconductor Sectors

To resolve duplicate work stemming from differing regulations between the two agencies, rules will be harmonized based on the MOENV's framework. Beyond directly recognizing verified Scope 1 and Scope 2 results from MOENV-regulated entities, the FSC will extend the filing deadline for Scope 1 and Scope 2 assurance up to the end of October each year, eliminating redundant verification costs through aligned reporting schedules.

In response to corporate challenges regarding data collection difficulty and insufficient supply chain emission factors, the MOENV will collaborate with the Ministry of Economic Affairs (MOEA) and the FSC to gradually establish local Scope 3 carbon emission factors. Given their significant share of exports, emission factors for the semiconductor and electronic components manufacturing sectors will be prioritized to meet global supply chain requirements.

三、Drafting Taiwan’s Anti-Greenwashing Guidelines Referencing European and U.S. Standards

In response to greenwashing concerns caused by improper citations of sustainability awards and exaggerated partial achievements, the MOENV will draft the "Anti-Greenwashing Guidelines for Corporate Use of Sustainability Awards and Labels" by referencing the latest European and U.S. trends — such as banning unverified labels, mandating the disclosure of evaluation-related conflicts of interest, and requiring evidence-backed claims. This initiative aims to shift Taiwan's focus from "encouraging disclosure" to "regulating claims," preventing the misleading of consumers and investors.

The MOENV emphasized that the guidelines focus on regulating corporate usage behavior in advertisements, sustainability reports, and product sales. These usages must adhere strictly to three core principles: real and valid, proportionate in scope, and prohibition of ambiguity. Concurrently, evaluating bodies must comply with principles including full disclosure of evaluation criteria, transparency regarding financial relationships with evaluated companies, consideration of major negative violations, and fulfillment of investigative responsibilities.

The MOENV stated that achieving 2050 Net-Zero emissions requires a pragmatic approach. The government will continue to enhance carbon inventory infrastructure and guide carbon reduction through concrete financial incentives. Moving forward, the MOENV will collaborate closely with the FSC to support enterprises in moving steadily toward an internationally competitive and sustainable Taiwan.