As 2026 approaches, the era of mandatory ESG (Environmental, Social, and Governance) disclosures under regulatory requirements is beginning, with the A-share bank ESG mandatory disclosure list expanding.
Under the China Securities Regulatory Commission's (CSRC) guidelines for sustainability reporting, the mandatory ESG disclosure framework now includes constituents of the SSE 180, SZSE 100, STAR 50, and ChiNext indices, as well as companies listed both domestically and overseas. Following recent index adjustments, Chengdu Bank and Shanghai Rural Commercial Bank have joined the list.
Statistics show that the A-share bank ESG mandatory disclosure list has grown to 27 institutions, comprising six state-owned banks, nine joint-stock banks, ten city commercial banks, and two rural commercial banks. This means over 60% of A-share listed banks (42 in total) have entered the mandatory ESG disclosure era.
Public data reveals that all 27 banks have disclosed their 2024 ESG reports. However, the quality of these disclosures varies. Industry experts highlight that bank ESG disclosures primarily focus on two key areas: carbon emissions and green finance.
Among the 27 banks, 16 reported a year-on-year decline in total carbon emissions, while nine saw an increase—including one major state-owned bank, six city commercial banks, and two joint-stock banks. Notably, city commercial banks showed inconsistent progress in carbon reduction and disclosure. For instance, Chengdu Bank has yet to disclose emissions data, while Bank of Ningbo did not provide historical comparisons. Among the remaining eight city commercial banks, only Jiangsu Bank and Zhengzhou Bank reported lower emissions.
Rao Shuling, Deputy Secretary-General of the Beijing Green Finance Association, emphasized that banks lagging in disclosure should integrate carbon reporting into their ESG strategies, establish clear timelines, and adopt appropriate accounting methods. Larger banks can build in-house teams, while smaller institutions may outsource or train staff. Effective disclosure can help identify operational inefficiencies and high-carbon risks in loan portfolios, turning compliance into a strategic advantage.
A recent report by the Beijing Green Finance Association and Bank of East Asia (China) found that while domestic banks have made progress in green finance innovation, only 15% of systemically important banks disclose carbon emissions from loan assets. In contrast, international banks like ABN AMRO and Bank of East Asia have adopted PCAF standards and set 2030 emission reduction targets for high-carbon sectors.
The top five banks with the highest year-on-year carbon emission increases were Bank of Beijing (13.88%), Bank of Nanjing (13.23%), Bank of Qingdao (11.92%), Bank of Chongqing (10.96%), and Bank of Hangzhou (10.02%). Meanwhile, the top performers in emission reductions were Shanghai Rural Commercial Bank (-34.52%), Bank of China (-23.64%), China Construction Bank (-20.65%), Chongqing Rural Commercial Bank (-17.89%), and Jiangsu Bank (-8.58%).
Industry insiders identified three key challenges in current ESG disclosures: 1. **Carbon emission gaps**: While Scope 1 and 2 emissions are easier to calculate, Scope 3 (indirect emissions) remains problematic due to a lack of localized data and unclear regulatory guidance. 2. **Climate risk testing**: Major banks claim to conduct stress tests but rarely disclose methodologies or results. 3. **Biodiversity reporting**: No standardized metrics exist under frameworks like TNFD or ISSB, and baseline data is scarce.
In 2024, ten banks disclosed Scope 3 emissions, up from four in 2023. However, reporting methodologies varied widely, covering areas like water usage, purchased goods, and logistics.
On the green finance front, China's green loan balance reached RMB 43.51 trillion by Q3 2025, up 17.5% year-to-date. The PBOC's carbon reduction support tool has facilitated RMB 1.38 trillion in loans since its launch, with eligibility now extended to foreign and regional banks.
Among the 17 banks disclosing Q3 2025 data, carbon reduction loans totaled RMB 6.19 billion across 353 projects, reducing emissions by over 1.7 million metric tons. Industrial Bank led in loan volume (RMB 600 million), while China Merchants Bank achieved the highest emission reductions (440,000 tons).
Experts suggest expanding carbon reduction tools to high-emission industries, climate finance pilots, and circular economy initiatives, alongside innovative products like carbon credit-backed loans and digital green finance solutions.
