北交所策略专题报告 北交所 ESG 信披体系再完善：聚焦绩优股，掘金 ESG 组合领先的超额收益 北交所研究团队 ——北交所策略专题报告 | 诸海滨（分析师） | 余中天（分析师） | | --- | --- | | zhuhaibin@kysec.cn | yuzhongtian@kysec.cn | | 证书编号：S0790522080007 | 证书编号：S0790525050003 | 事件：北交所增补三项环境议题指南，ESG 披露框架持续完善 2026 年 1 月 30 日，沪深北交易所修订发布《上市公司可持续发展报告编制指南》， 增补《第三号 污染物排放》《第四号 能源利用》《第五号 水资源利用》三项议 题指南。北交所于 2025 年 1 月 17 日首次发布《指南》及其附件《第一号 总体 要求与披露框架》《第二号 应对气候变化》。北交所表示，本次修订在保持原有 框架基础上，新增《第三号 污染物排放》《第四号 能源利用》《第五号 水资 源利用》三个应用指南，进一步细化环境维度披露要求，为上市公司提供更清晰、 可操作的披露指引。三份指南主要内容均分为相关风险和机遇评估、核算、披露 要点三大板块。《第 ...

2026年1月30日，在证监会统筹指导下，沪深北三家证券交易所集中发布或修订可持续发展报告编制相关指南，新增污染物排 放、能源利用、水资源利用三大环境方面相关指引。 此次规则升级恰逢"十五五"开局之年，也是A股上市公司ESG信息披露"首考"关键节点，标志着我国上市公司可持续发展信息披露规则体系进一步完善， 为资本市场绿色转型与高质量发展奠定坚实制度基础。 规则协同发力 构建绿色转型指引体系 记者梳理发现，指南内容全面覆盖风险评估、工作流程、常见披露数据核算流程和方法等重难点问题，在强化规范性的同时兼顾行业包容性，注重贴合上 市公司信息披露实务，有利于服务上市公司合规稳妥地做好首个强制披露报告期的相关工作，助力上市公司全面夯实可持续发展根基，为"十五五"时期实 现高质量发展奠定坚实的基础。作为资本市场核心基础设施，三家交易所此次规则修订将进一步形成监管协同合力。 具体来看，相关指南主要围绕三方面展开：一是系统说明各议题涉及的主要风险与机遇，如生产运营中的环境合规风险、绿色技术应用带来的市场机遇 等；二是提供披露数据的计算流程与方法，涵盖污染物排放量统计、综合能耗计算、水资源取用与消耗计量等，增强数据可比性与可靠 ...

Core Viewpoint - The mandatory disclosure of sustainable development reports for listed companies in China is approaching, with many companies already preparing their 2025 reports, marking a significant shift from passive compliance to proactive enhancement of ESG information disclosure [1][2]. Group 1: Regulatory Changes - The revised "Management Measures for Information Disclosure of Listed Companies" came into effect on July 1, 2023, mandating companies to publish sustainable development reports as per exchange regulations, elevating ESG disclosure from voluntary to regulatory compliance [2]. - The Shanghai, Shenzhen, and Beijing Stock Exchanges will implement the "Guidelines for Sustainable Development Reports of Listed Companies" in 2024, requiring companies to disclose their 2025 reports by 2026 [2]. Group 2: Reporting Practices - Companies are focusing on core performance indicators to enhance readability and are separating sustainable development reports from social responsibility reports to strengthen thematic clarity [1][3]. - The emphasis on supply chain management and sustainability is increasing, with companies aiming to meet both domestic and international disclosure requirements [3]. Group 3: Challenges in Disclosure - The transition to quantitative data disclosure is challenging, with companies facing difficulties in data collection, talent shortages, and insufficient tools [1][4]. - A significant gap exists in the quantitative disclosure of climate-related data, with only 37.80% of companies actively reporting their greenhouse gas emissions performance [5][6]. Group 4: Industry Insights - The demand for ESG quantitative data is rising, with 102 fund companies issuing 1003 ESG public fund products by September 2023, reflecting an 11.94% increase from the previous year [6]. - Companies are encouraged to develop a comprehensive indicator system for quantitative data, which includes target setting, progress monitoring, and data collection [6][7]. Group 5: Recommendations for Improvement - Suggestions for enhancing ESG disclosure include strengthening policy guidance, promoting industry leaders as role models, and developing third-party platforms for technical support [9]. - Establishing a standardized system for ESG disclosure that aligns with international rules is essential to reduce compliance costs and improve efficiency [9].

Group 1 - The core viewpoint emphasizes the importance of listed companies in the capital market, with 5,167 companies in the Shanghai and Shenzhen exchanges having a market value exceeding 100 trillion yuan, ranking second globally [1] - By the end of 2024, 1,869 companies disclosed sustainability reports, representing a disclosure rate of 34.7%, indicating a significant portion of companies are systematically reporting sustainability-related information [5] - The establishment of a mandatory sustainability information disclosure system marks a significant step in promoting sustainable development and enhancing the long-term sustainability capabilities of listed companies [2][3] Group 2 - The new "National Nine Articles" introduced in April 2024 aims to improve the sustainability information disclosure system for listed companies, combining mandatory and reference guidelines [2] - The quality of disclosures has improved, with 99.3% of reports including quantitative indicators, and 62.1% of companies identifying climate risks and opportunities [5] - The international recognition of Chinese companies' sustainability efforts is increasing, with about one-third of companies in the Shanghai and Shenzhen markets receiving improved MSCI ESG ratings by the end of 2024 [6] Group 3 - The sustainable disclosure system is designed to align with international standards while considering China's unique circumstances, promoting a gradual and flexible approach to implementation [7] - The shift from disclosure to governance reflects a broader trend where ESG principles are increasingly integrated into corporate strategy and risk management [8] - The next steps involve guiding companies to implement new development concepts and continuously improving disclosure standards to achieve more balanced and focused sustainability reporting [9]

Group 1: Conference Overview - The 2025 Sustainable Global Leaders Conference will be held from October 16 to 18 in Shanghai, focusing on "Collaborating to Address Challenges: Global Action, Innovation, and Sustainable Growth" [1] - The conference is co-hosted by the World Green Design Organization (WGDO) and Sina Group, with support from the Shanghai Huangpu District Government, and aims to explore new paths for sustainable development [1] - Approximately 500 prominent guests, including 100 international attendees, will participate, featuring politicians, Nobel laureates, and leaders from Fortune 500 companies [1] Group 2: Insights on ESG Practices - Zhang Lili, Vice President of Government Affairs and Public Relations at Bureau Veritas, emphasized that sustainable development should be viewed as a driver of technological innovation and market competitiveness rather than a cost burden [2][4] - Companies should treat sustainability reports as "health check-ups" rather than "report cards," highlighting both achievements and areas for improvement [4][8] - There is a call for companies to establish transparent and verifiable data systems to build trust in sustainability efforts, avoiding "greenwashing" practices [4][6] Group 3: Strategic Recommendations for Companies - Companies are encouraged to align their sustainability strategies with overall business strategies, integrating sustainability into corporate governance and management structures [6][9] - Successful companies have demonstrated that technology innovation and supply chain collaboration are crucial for sustainable development [7][9] - The importance of third-party certifications is highlighted, as they can enhance trust and facilitate access to international markets [10][11] Group 4: Global Engagement and Leadership - Chinese private enterprises are encouraged to expand internationally and participate in global energy systems, leveraging the established reputation of state-owned enterprises [4][11] - There is a push for Chinese companies to share their experiences and contribute to international standard-setting, transitioning from "followers" to "rule-makers" in sustainability [4][11] - The need for inclusivity in sustainable development is emphasized, with a focus on supporting developing countries in their sustainability efforts [4][11]

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has guided the Beijing Stock Exchange (BSE) to release new disclosure guidelines focusing on environmental issues, aiming to enhance the quality of ESG reporting among listed companies [1][2]. Group 1: Guidelines and Framework - The BSE has revised the "Guidelines for the Preparation of Sustainable Development Reports" to include new application guidelines on "Pollutant Emissions," "Energy Utilization," and "Water Resource Utilization," effective from September 5, 2025 [1][2]. - The guidelines aim to improve awareness and systematic management of sustainable development risks, while providing clear disclosure requirements without imposing additional burdens on companies [2][3]. - The guidelines serve as a reference for companies in preparing their sustainable development reports, detailing common risks and opportunities related to environmental issues [3][4]. Group 2: Industry Response and Practices - Companies listed on the BSE, such as BetterRay and others, have actively engaged in ESG reporting, with 16 companies already disclosing their 2024 ESG reports [1][4]. - BetterRay has integrated ESG principles into its corporate strategy, setting long-term goals for carbon neutrality and aiming for a 5% annual reduction in carbon emissions per product by 2030 [5][6]. - The BSE encourages innovative small and medium-sized enterprises to gradually enhance their ESG disclosures, reflecting a growing commitment to sustainable practices within the industry [4][3].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has guided the Beijing Stock Exchange (BSE) to release new disclosure guidelines focused on environmental issues, aiming to enhance the quality of ESG reporting among listed companies [1][2][4]. Group 1: New Guidelines and Objectives - The BSE has revised the "Guidelines for the Preparation of Sustainable Development Reports by Listed Companies," which will be open for public consultation starting September 5, 2025 [2]. - The new guidelines include three specific application guidelines on "Pollutant Emissions," "Energy Utilization," and "Water Resource Utilization," aimed at improving awareness and management of sustainability risks [2][3]. - The guidelines emphasize providing reference materials rather than imposing additional mandatory disclosure requirements, thereby reducing the burden on companies [2][3]. Group 2: Impact on Listed Companies - Listed companies on the BSE have actively engaged in ESG information disclosure, with 16 companies, including Better Energy, already releasing their 2024 ESG reports [1][6]. - Better Energy has integrated ESG principles into its corporate strategy, setting ambitious long-term goals for carbon neutrality and reduction in carbon emissions per product [6]. - The guidelines are expected to enhance the ability of listed companies to prepare ESG reports by providing detailed explanations and practical steps for implementation [5]. Group 3: Industry Response and Trends - The new guidelines are seen as a response to the global "dual carbon" goals and environmental regulations, pushing companies like China National Offshore Oil Corporation to adopt green development as a core strategy [7]. - Companies are increasingly focusing on ESG performance to attract international clients and gain competitive advantages in the market [7].

Core Viewpoint - The revised "Guidelines for the Preparation of Sustainable Development Reports by Listed Companies" aims to enhance the environmental practices of listed companies in China, focusing on pollution emissions, energy utilization, and water resource management [1][2]. Group 1: New Guidelines - Three new specific guidelines have been added: "Pollutant Emissions," "Energy Utilization," and "Water Resource Utilization," providing a structured approach for companies to identify risks and opportunities, accounting processes, and disclosure points [2]. - The new guidelines detail common risks such as production capacity limitations due to pollutant emission controls and opportunities like cost reductions through new pollution prevention technologies [2]. - The guidelines do not impose additional mandatory disclosure requirements but emphasize key workflows and examples to improve the quality of sustainability reporting [2][3]. Group 2: ESG Reporting Trends - As of June 2025, 1,869 listed companies have disclosed sustainability reports, achieving an overall disclosure rate of 34.72%, a 10 percentage point increase from the previous two years [4]. - Over 2,200 companies are expected to disclose sustainability or social responsibility reports for 2023, with an annual growth rate of 20% in disclosures over the past three years [4]. - More than 1,000 companies have reported carbon emissions, with a 50% annual growth in the number of companies disclosing such information [4]. Group 3: Governance and Management - 67.27% of companies have established governance structures, and 63.93% have disclosed strategic information related to sustainability [5]. - 78.07% of companies conduct materiality assessments to identify key issues, while 93.32% disclose information on stakeholder communications [5]. - The guidelines are facilitating a shift from mere disclosure to precise governance, with over 70% of companies establishing dedicated ESG management bodies [5]. Group 4: ESG Ratings Improvement - The ESG ratings of listed companies have significantly improved, with the proportion of companies rated AAA or AA increasing from less than 3.2% at the end of 2023 to 7.2% by the end of 2024 [6]. - Companies like Guizhou Moutai and Sungrow Power have seen their ESG ratings improve, leading to increased foreign investment and recognition in international capital markets [6][7]. - The ongoing development of additional guidelines is expected to further systematize sustainability disclosures, enhancing the capital market's ability to differentiate pricing based on ESG performance [7].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) is seeking opinions on the second batch of guidelines for the preparation of sustainable development reports by listed companies, indicating a structured approach to enhance ESG disclosures in the market [1][2]. Group 1: Guidelines and Regulations - The newly revised guidelines include three additional chapters on pollutant emissions, energy utilization, and water resource utilization, providing a comprehensive framework for companies to enhance their sustainable development reporting [1][2]. - The guidelines aim to strengthen companies' awareness of risks and opportunities while standardizing information disclosure practices without imposing additional mandatory disclosure requirements [2]. Group 2: ESG Performance and Market Impact - As of June 2023, 1,869 listed companies have disclosed sustainable development reports, achieving an overall disclosure rate of 34.72%, which is an increase of approximately 10 percentage points compared to the previous two years [3]. - The introduction of the guidelines has led to a significant rise in attention to issues such as climate change and fair treatment of small and medium enterprises among listed companies [3]. - Companies like Kweichow Moutai and CATL have seen improvements in their ESG ratings, reflecting increased recognition from international investors and enhancing their attractiveness for sustainable investment [3].

Core Viewpoint - The China Securities Regulatory Commission (CSRC) is seeking opinions on the second batch of guidelines for listed companies' sustainable development reports, focusing on environmental issues such as pollutant emissions, energy utilization, and water resource usage, aiming to enhance sustainable development awareness and improve disclosure standards among listed companies [1][2]. Group 1: Guidelines Overview - The newly revised guidelines include three chapters on pollutant emissions, energy utilization, and water resource usage, providing detailed explanations and examples for companies to enhance their sustainable development reporting capabilities [2][3]. - The guidelines aim to strengthen companies' awareness of risks and opportunities while standardizing information disclosure without imposing additional mandatory requirements [3][4]. Group 2: Implementation and Compliance - The guidelines serve as a "toolbox" for companies to identify key issues and analyze sustainability-related risks and opportunities, while the disclosure framework outlines mandatory reporting requirements for specific companies by May 1, 2024 [4][5]. - As of June 2025, 1,869 listed companies had disclosed sustainability reports, achieving an overall disclosure rate of 34.72%, an increase of approximately 10 percentage points compared to the previous two years [5][6]. Group 3: ESG Ratings and Market Impact - The integration of ESG factors into credit ratings has gained traction, with 32% of companies in the Shanghai and Shenzhen stock markets seeing improvements in their MSCI ESG ratings by the end of 2024 [7][8]. - Enhanced ESG performance is expected to positively influence companies' public image and attract long-term investment, as seen with companies like Kweichow Moutai and CATL, which have received significant upgrades in their ESG ratings [8].