Legal Landscapes: China- Environmental, Social and Governance

Xiuxiu ZHANG

Partner , Hui Ye


1. What is the current legal landscape for ESG in your jurisdiction?

China’s ESG regulation has shifted from ‘soft initiatives’ to mandatory disclosure. 2026 marks the first year of the full implementation of mandatory disclosure, which will gradually be extended to cover all listed companies and key enterprises. This will form a comprehensive system anchored by the Company Law and Environmental Protection Law, centred on mandatory disclosure rules from the China Securities Regulatory Commission (CSRC) and stock exchanges. This system will be supported by unified standards and verification from the Ministry of Finance and coordinated by multi-departmental industry oversight.

2. What three essential pieces of advice would you give to clients involved in ESG matters?

In China, most common ESG matters may include labor compliance, supply train management and feasibility of sustainable goals.

Firstly, issues surrounding overtime represent a widespread challenge to corporate compliance and are a prominent topic under ESG frameworks. Many companies, particularly in the manufacturing industry, have employees who work over 36 hours per month. Legal recommendations: Implementing multiple working hour systems, including applying for comprehensive working hour arrangements. It is also important to regularly verify overtime pay settlements and establish formal overtime approval procedures.

Secondly, in green supply chain management, taking the EU CBAM(Carbon Border Adjustment Mechanism) as an example, some suppliers have weak foundations in carbon data collection and auditing, which may impact export compliance. To address this challenge, we recommend that companies integrate ESG compliance into their industrial planning, proactively implement compliance measures, and either select suppliers or communicate compliance requirements to them at higher standards. Additionally, companies should provide regulatory guidance and support to their suppliers regularly.

Thirdly,from an ESG reporting perspective, the aim of increased corporate disclosure requirements is to strengthen market oversight by stakeholders. However, some companies may set unrealistic or impractical targets for carbon reduction, water conservation or the promotion of recycled materials, potentially engaging in greenwashing. Chinese media extensively scrutinise corporate greenwashing practices, advising companies to enhance internal and external legal reviews of their sustainability commitments and promotional claims.

3.What are the greatest threats and opportunities in ESG law in the next 12 months?

2026, The Ecological Environment Code marks a milestone in China’s ESG legal system, presenting both pressures and opportunities for enterprises. In the short term, environemental compliance costs will rise and oversight will tighten. Long-term, however, green transformation is inevitable—compliant enterprises will reap multiple rewards including policy dividends, market advantages, financing benefits, and enhanced brand value.

Core Recommendations: proactively transform green compliance from a “cost center” into a “value center.”

4. How do you ensure high client satisfaction levels are maintained by your practice?

As a lawyer and an ESG expert, I maintain high client satisfaction by focusing on clarity, communication, competence throughout the entire representation.

First, I prioritize transparent and consistent communication. I keep clients regularly updated on case progress, explain legal procedures in plain language, and respond promptly to inquiries.

Second, I deliver competent and tailored legal advice. Every case, project is unique, so I take the time to fully understand the client’s goals, risks, and priorities. I provide realistic expectations rather than overpromising.

Third, I emphasize responsiveness and reliability. I respect deadlines, honor commitments, and make myself available when the client needs guidance. Trust is built through consistency and accountability.

5. What technological advancements are reshaping ESG law and how can clients benefit from them?

AI advancements may reduce the cost of ESG compliance in some ways, for example by streamlining data collection. However, while technological evolution clarifies regulatory boundaries, challenges regarding online data and personal privacy protection persist. In China, for example, the adoption of intelligent technologies has lowered the cost of preparing ESG reports for enterprises, but this does not automatically result in higher-quality reports or better performance. Ultimately, corporate leaders must raise their awareness of and commitment to ESG, and then use appropriate technology to implement established improvement goals.