Sustainability affects us all. Every nation benefits from policies and behaviours that protect our planet – and from consistent and high-quality reporting and auditing of sustainability-related business activities. It makes sense, then, to learn from each other, nationally and internationally, and work together to develop the best possible answers to the challenges we face.
A new report, Accelerating jurisdictional implementation of sustainability disclosure and assurance standards, is the result of an ACCA initiative to encourage greater international collaboration and knowledge-sharing around sustainability reporting, in this case between the UK and China.
Aimed at policymakers, regulators, standard-setters and other relevant bodies in the UK and China, the report sets out a series of recommendations for accelerating the development and implementation of high-quality sustainability disclosure and assurance standards.
‘By understanding the approaches, challenges and lessons learned in each other’s jurisdiction,’ it says, ‘both countries can strengthen the coherence and credibility of their sustainability reporting – and ultimately enable smoother cross-border trade and investment.’
Unrealistic expectations lead to poor-quality disclosures
Much of the analysis in the report springs from a roundtable event organised by ACCA and held in November 2025, which brought together policymakers, academics, accountancy and assurance professionals, and corporations of all sizes from both countries. The event discussed the challenges seen in both jurisdictions around sustainability reporting and explored how they could be overcome.
Phased and proactive
The roundtable identified unrealistic expectations around sustainability disclosures as a key challenge in both jurisdictions, as they lead to poor-quality disclosures and an excessive administrative burden. The report recommends that regulators and policymakers should take a phased approach to implementing sustainability disclosure and assurance on the basis of an assessment of the market’s readiness. Pragmatism, it says, is essential.
It also recommends a more proactive approach to engagement and collaboration between policymakers, standard-setters and regulators, both nationally and internationally. A lack of dialogue between stakeholders is seen as a hurdle to implementation, often resulting in duplicated effort, misaligned requirements and reduced comparability.
‘Proactive engagement,’ says the report, ‘builds trust, reflects real-world operational needs, leverages lessons from other jurisdictions and strengthens the global baseline.’
Consistency
The report advocates an approach to sustainability reporting that anchors requirements in internationally recognised frameworks, with minimal amendments in each jurisdiction.
It suggests that adopting International Sustainability Standards Board (ISSB) standards – which are increasingly being adopted by jurisdictions worldwide – along with the International Auditing and Assurance Standards Board’s sustainability assurance standard ISSA 5000 would be an effective approach. The report points out that robust and consistent sustainability standards support both the UK’s modern industrial strategy and China’s current five-year plan for national economic and social development.
The use of global standards reduces costs and facilitates trade
The widespread use of these standards reduces the risk of fragmented local requirements, says the report, and enables more comparable, transparent, trustworthy and decision-useful information across jurisdictions – ‘reducing costs for multinational entities, facilitating international trade and giving investors the information they need to allocate capital effectively’.
The report includes a comparison of sustainability disclosure and assurance standards in the UK and China. It found that the approach in the two jurisdictions differs only in ‘a few respects, including their alignment with ISSB standards and the processes used to develop and implement the standards’.
The UK’s first two government-issued sustainability reporting standards (UK SRS S1 and S2) were published in February 2026 and are closely aligned with ISSB standards, with only minimal amendments to reflect the UK’s particular legal and market context. In the Chinese mainland, disclosure requirements are being established through state-led national standards; they are informed by the ISSB standards but include more substantive jurisdiction-specific adaptations.
Improving uptake
In terms of the ways in which uptake of sustainability disclosure and assurance can be improved, the report recommends clear guidance for companies and practical support during implementation, including a transparent implementation roadmap with defined milestones.
Only 25% of organisations are sustainability reporting-ready
Fragmented and incomplete data has long been recognised as a barrier to sustainability reporting. A 2025 ACCA survey that analysed companies’ readiness for sustainability reporting found that only 25% of respondents felt that their own organisation’s processes were ready to collect and use sustainability information for internal and external purposes. More than half (57%) said they were only partially ready or not ready at all.
This report argues that advanced digital tools enhance the quality, reliability and traceability of information and strengthen stakeholder confidence. ‘Developing simple, open-access digital tools can be helpful for entities who don’t have the resources to develop tools in-house,’ it adds.
Audit
On sustainability assurance, the roundtable identified inconsistent terminology and unclear expectations as challenges that could erode confidence in assurance and the underlying disclosures. The report recommends clear regulatory guidance that sets out ‘explicit definitions of scope, boundaries, assumptions and exclusions’.
A market not dominated by a few big firms is essential for credibility
It adds that a diverse and efficient assurance market – one that is not dominated by a few large firms – is essential for credibility as well as resilience.
Collaboration is essential for the development and implementation of consistent sustainability disclosure and assurance standards, and the report suggests that China and the UK could work together through the existing EFD (UK-China Economic and Financial Dialogue) initiative on key areas, such as the development of an implementation roadmap.
ACCA, it adds, is happy to facilitate further interactions similar to the roundtable event and create ‘a forum where individuals from a range of different entities from the UK and China can share their challenges and work together to develop recommendations’.
