国内首个气候准则公开征求意见：范围三首次纳入国家级气候信息披露框架，金融业“漂绿”变难了

Core Viewpoint - The recent release of the draft "Corporate Sustainability Disclosure Standard No. 1 - Climate (Trial) (Draft for Comments)" marks significant progress in China's unified sustainability disclosure framework, aligning with international standards while considering local industry needs [2][3][4]. Group 1: Regulatory Developments - The draft consists of six chapters and 47 articles, covering governance, strategy, risk and opportunity management, indicators and targets, and appendices [2]. - The draft incorporates Scope 3 emissions into the national climate information disclosure framework for the first time, setting specific disclosure requirements [2][5]. - The rapid development of these standards indicates a proactive approach to climate governance, with expectations for formal adoption possibly within the year, ahead of the previously set 2027 timeline [3][4]. Group 2: Implementation Flexibility - The draft emphasizes a separation between the formulation and implementation of standards, allowing companies to voluntarily disclose information before mandatory requirements are established [4][5]. - Companies are encouraged to adopt low-carbon practices, but the draft provides flexibility in disclosing Scope 3 emissions, allowing for management disclosures instead of quantitative data in certain cases [5][6]. Group 3: Industry-Specific Guidelines - The Ministry of Finance is developing application guidelines for nine specific industries, including power, steel, and finance, to address the unique disclosure needs of each sector [8]. - Financial institutions are required to disclose financing emissions related to Scope 1, Scope 2, and Scope 3, enhancing transparency and accountability in climate-related responsibilities [8][9]. Group 4: Challenges in Disclosure - The complexity of calculating Scope 3 emissions poses significant challenges, particularly for small and medium-sized enterprises that may lack the necessary data collection capabilities [7][9]. - The lack of a unified global standard for Scope 3 emissions complicates the disclosure process, leading to inconsistencies in data quality and comparability among companies [7][9].