FIEA / SSBJ Japan
Financial Instruments and Exchange Act — Cabinet Office Ordinance on Disclosure (SSBJ Standards mandate)
Topic : ESG disclosure · Level : National
Today
Ordinance amended 20 Feb 2026: SSBJ mandatory for Prime ≥¥3tn from FY Mar 2027, ≥¥1tn Mar 2028, ≥¥500bn Mar 2029.
Summary
Japan made SSBJ sustainability standards (based on IFRS S1/S2) mandatory in the Annual Securities Report for large Prime Market companies. Firms with market cap of ¥3tn or more start with FY ending March 2027, ¥1tn+ follow in 2028. Limited assurance is planned one year later.
Who is concerned
- Turnover
- not specified (avg market cap ≥¥3tn, then ≥¥1tn, ≥¥500bn)
- Employees
- non précisé
- Listed company
- cotées seulement
- Sectors
- All sectors
- Triggering activities
- TSE Prime Market listing
- Filing an Annual Securities Report
- Average market cap above phase threshold
- Extraterritorial reach
- No
Scope 3 under SSBJ climate standard requires value-chain emissions data, including from overseas suppliers.
- Examples
- Japanese automaker on TSE Prime, cap > ¥3tn
- Electronics group on Prime, cap ¥1-3tn
- Trading house with China sourcing
What the law requires
- Disclose sustainability and climate info under SSBJ Standards in the Annual Securities Report
- Report Scope 1, 2 and 3 GHG emissions with climate risks and opportunities
- Obtain limited assurance from the year after first application (planned)
- Use 2-year relief allowing sustainability info to be filed after financial statements
Penalties
FIEA: false statements in securities reports up to 10 yrs prison and/or ¥10m fine; companies up to ¥700m. Safe harbor planned.
What this changes for a supplier in China
Japanese buyers subject to SSBJ must report Scope 3. Chinese Tier 1 suppliers will receive requests for product carbon data and Scope 1-2 figures from 2026-2027.
Expected evidence
- Scope 1-2 GHG inventory (ISO 14064 or GHG Protocol)
- Product carbon footprint for supplied parts
- Energy and electricity source data
Tiers : Tier 1-2