Japan TCFD (2023 rule)
Cabinet Office Ordinance on Disclosure of Corporate Affairs (2023 amendment) and TSE CG Code Principle 3.1.3
Topic : Climate · Level : National
Today
TCFD-based section in Annual Securities Reports still applies to firms not yet under SSBJ. Large Prime firms move to SSBJ.
Summary
Since FY ending March 2023, Japanese filers include a TCFD-based sustainability section in Annual Securities Reports. Prime firms also follow a TCFD comply-or-explain principle. This regime stays for firms outside the SSBJ phases; the largest Prime firms switch to SSBJ from FY ending March 2027.
Who is concerned
- Turnover
- non précisé
- Employees
- non précisé
- Listed company
- cotées seulement
- Sectors
- All sectors
- Triggering activities
- Filing an Annual Securities Report
- TSE Prime listing (CG Code TCFD principle)
- Extraterritorial reach
- No
non précisé
- Examples
- TSE Standard-market manufacturer
- Prime firm below SSBJ phase thresholds
- Japanese importer with China suppliers
What the law requires
- Include a sustainability section in the Annual Securities Report (governance, risk management)
- Disclose strategy and metrics where material, along TCFD pillars
- Prime firms: disclose climate info on TCFD or equivalent basis, comply or explain
Penalties
FIEA: false statements in securities reports up to 10 yrs prison and/or ¥10m fine; companies up to ¥700m.
What this changes for a supplier in China
Japanese buyers still on the 2023 regime ask for climate data less systematically than SSBJ filers. Requests rise as more Prime firms move to SSBJ.
Expected evidence
- Scope 1-2 GHG data
- Climate risk info for key plants
- Energy consumption records
Tiers : Tier 1