Your South Korean customer has sent you an ESG questionnaire. Here is what their obligations require of them — and what they need from you.
South Korea is implementing mandatory ISSB-aligned sustainability reporting for large KOSPI-listed companies from 2028, with a roadmap finalised in April 2026. South Korean companies — particularly in electronics, automotive, steel, and chemicals — are also subject to ESG questionnaires from their international buyers in the EU, USA, and Japan. If you supply goods or services to a South Korean buyer, or if your South Korean buyer supplies international markets, ESG compliance evidence is increasingly a procurement requirement today — and will become a mandatory regulatory requirement as the 2028 deadline approaches.
Key regulations in South Korea — ESG & Sustainability Reporting Supplier Guide
FSC Mandatory Sustainability Reporting Roadmap
South Korea's Financial Services Commission (FSC) has finalised a roadmap for mandatory ISSB-aligned sustainability reporting. Large KOSPI-listed companies must comply from 2028. The framework is based on IFRS S1 and S2, making South Korean disclosures directly comparable with those of companies in the EU, UK, Australia, Brazil, and Japan. Supply chain disclosure is a core component of IFRS S2.
Korea Exchange (KRX) ESG Disclosure Guidelines
The Korea Exchange has issued ESG disclosure guidelines that large listed companies are already following on a voluntary basis ahead of the mandatory 2028 deadline. Companies in South Korea's major export sectors — electronics (Samsung, LG, SK), automotive (Hyundai, Kia), and steel (POSCO) — are already publishing detailed ESG reports and assessing their supply chains. Suppliers to these companies are already receiving ESG questionnaires.
EU CSRD & CSDDD — Reach into South Korean Suppliers
South Korean companies that supply European buyers are already subject to ESG questionnaires driven by EU CSRD and the incoming CSDDD. European buyers are legally required to assess their supply chains — including suppliers based in South Korea. This is particularly relevant for South Korean companies in electronics, automotive components, batteries, and chemicals that supply EU markets.
US SEC Climate Rules / California SB 253
South Korean companies supplying US buyers — particularly large US companies subject to SEC climate disclosure rules or California SB 253 — will receive ESG questionnaires as US buyers assess their supply chain emissions. South Korea's electronics and semiconductor supply chains are deeply integrated with US technology companies subject to these requirements.
PIPA — Personal Information Protection Act (Amended 2023)
South Korea's PIPA requires organisations to notify the Personal Information Protection Commission (PIPC) and affected data subjects without delay — and within 72 hours — of becoming aware of a personal data breach. The 2023 amendments strengthened breach notification requirements, increased penalties (up to 3% of relevant revenue), and expanded the scope of protected personal information. South Korea has one of the most comprehensive data protection regimes in Asia. Organisations processing South Korean personal data must comply with PIPA regardless of where they are based.
Information and Communications Network Act (ICNA) — Cyber Incident Reporting
South Korea's ICNA requires information and communications service providers to report significant cybersecurity incidents to KISA. South Korea's National Cybersecurity Framework (2024) strengthens obligations for critical infrastructure operators, including supply chain security requirements for companies in the semiconductor, battery, and automotive sectors. Suppliers to major South Korean conglomerates (Samsung, LG, SK, Hyundai) are increasingly subject to cybersecurity due diligence assessments as part of procurement processes.
What this means for you as a supplier
You may not be directly regulated by all of these frameworks today. But your South Korean buyer is preparing for mandatory compliance from 2028 — and is already receiving ESG questionnaires from their EU and US buyers. Large South Korean companies in electronics, automotive, and steel are already assessing their supply chains. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain. The 2028 mandatory deadline is close enough that building your evidence base now is the practical approach.
Key dates
Active now
KRX ESG Disclosure Guidelines — large listed companies already reporting voluntarily; supply chain questionnaires already in circulation
Active now
EU CSRD — large EU companies must disclose supply chain sustainability data including South Korean suppliers
Active now
EU CSRD — large EU companies must disclose supply chain sustainability data including South Korean suppliers
2026
California SB 253 mandatory Scope 3 reporting — US tech buyers must disclose supply chain emissions including South Korean electronics suppliers
April 2026
FSC finalises mandatory sustainability reporting roadmap — framework confirmed for 2028 implementation
July 2029
EU CSDDD Phase 1 — large EU companies must conduct active supply chain due diligence; South Korean suppliers will receive structured questionnaires
2028
FSC mandatory ISSB-aligned reporting begins for large KOSPI companies — supply chain disclosure requirements become mandatory
Why South Korean buyers are already asking ESG questions
South Korea's major export companies — Samsung, LG, SK Group, Hyundai, Kia, POSCO — supply markets in the EU, USA, and Japan that are already subject to mandatory ESG reporting. Those buyers require supply chain data from their South Korean suppliers. The South Korean companies then pass that requirement down to their own supply chains. Even before the 2028 mandatory deadline, ESG questionnaires are already circulating in South Korean supply chains driven by international buyer obligations.
The 2028 FSC mandatory deadline creates a clear preparation timeline. South Korean listed companies are already building their ESG reporting infrastructure — and they need their suppliers to be ready when the mandatory deadline arrives. Suppliers who cannot provide structured ESG evidence will face growing pressure from multiple buyers simultaneously as 2028 approaches.
What your South Korean buyer's questionnaire will ask
South Korean ESG questionnaires draw on KRX guidelines (GRI and ISSB-aligned), and — for companies with international buyers — EU CSRD, US SEC, and California SB 253 requirements. The following areas are consistently covered.
Climate disclosures (IFRS S2 aligned)
Greenhouse gas emissions (Scope 1, 2, and Scope 3 supply chain emissions), climate risk assessment, and transition planning. South Korea's 2050 Carbon Neutrality commitment drives the climate data requirement. Your buyer needs your emissions data to complete their own disclosure.
Environmental management
Energy consumption, water usage, waste management, and any relevant certifications (ISO 14001). South Korean electronics and automotive supply chains face particular scrutiny on chemical management and hazardous substance compliance (RoHS, REACH).
Labour rights and working conditions
Compliance with Korean Labour Standards Act, fair wages, working hours, health and safety standards, and freedom of association. International buyers will additionally ask about ILO core conventions and living wage standards.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. EU CSDDD buyers require documented human rights due diligence from their South Korean suppliers.
Supply chain transparency
Evidence of your own supplier assessment processes. South Korean electronics and automotive supply chains are complex and multi-tiered — buyers need evidence that ESG standards are maintained throughout the chain, not just at the first tier.
Governance and anti-corruption
Anti-bribery and anti-corruption policies aligned with Korea's Act on Combating Bribery of Foreign Public Officials. Board oversight of ESG matters, and whistleblowing mechanisms.
The 2028 preparation window — why acting now matters
The FSC mandatory deadline of 2028 is close enough to create real preparation pressure for South Korean listed companies — and their suppliers. Companies that begin building their ESG reporting infrastructure now will be ready when the mandatory deadline arrives. Companies that wait until 2027 will face a compressed timeline and the risk of being excluded from supply chains as their buyers prioritise compliant suppliers.
The ISSB alignment of the FSC framework means that South Korean company ESG reports will be directly comparable with those of companies in the EU, UK, Australia, Brazil, and Japan. Suppliers who build their evidence base to ISSB standards now will be able to respond to questionnaires from buyers in any of these markets with the same underlying data — a significant efficiency advantage as ESG questionnaire volumes increase.
What happens if your response is inadequate
- →Large South Korean buyers already publishing ESG reports flag you as a higher-risk supplier — creating a documented compliance gap in their public record
- →EU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance — a non-response puts your contract at risk
- →US tech buyers subject to California SB 253 must disclose Scope 3 supply chain emissions — they need your emissions data to comply
- →As the 2028 FSC mandatory deadline approaches, South Korean buyers will accelerate their supply chain assessment programmes — suppliers who are not prepared will face growing pressure from multiple buyers simultaneously
- →International investors applying ESG screens to South Korean companies and their supply chains will flag weak ESG credentials — affecting access to capital and partnership opportunities
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
Received an ESG questionnaire from your buyer?
ESG Stress Free guides South Korean suppliers through K-ESG, TCFD, and international buyer supply chain requirements.