Your Taiwanese customer or buyer is asking for ESG information. Here is what the regulatory environment requires — and what they need from you.
Taiwan is one of Asia's most advanced ESG regulatory environments and a global hub for semiconductor, electronics, and precision manufacturing supply chains. The Taiwan Stock Exchange (TWSE) and Financial Supervisory Commission (FSC) have introduced mandatory sustainability reporting for listed companies, with phased requirements extending to smaller companies. Taiwan's FSC Sustainable Finance Action Plan and the mandatory adoption of IFRS S1 and S2 (ISSB standards) from 2026 place Taiwanese companies — and their suppliers — at the forefront of Asia-Pacific ESG compliance. If you supply goods or services to a Taiwanese company, particularly in the technology, electronics, or manufacturing sectors, ESG questionnaires covering carbon emissions, supply chain due diligence, and responsible sourcing are now a standard procurement requirement.
Key regulations in Taiwan — ESG Supplier Guide
FSC Sustainable Finance Action Plan — Mandatory Sustainability Reporting
Taiwan's Financial Supervisory Commission (FSC) requires all TWSE and TPEx listed companies to publish annual Corporate Sustainability Reports (CSRs) aligned with GRI Standards. The FSC's phased roadmap extends mandatory reporting to all listed companies by 2026, with IFRS Sustainability Disclosure Standards (IFRS S1 and S2, based on ISSB) becoming the mandatory framework from 2026. Reports must cover environmental performance, social responsibility, governance, and supply chain sustainability.
FSC Climate Disclosure Requirements — TCFD Alignment
The FSC requires TCFD-aligned climate disclosure from listed companies, covering governance of climate-related risks, strategy, risk management, and metrics and targets. Financial institutions, insurance companies, and large listed companies were the first in scope. The FSC's roadmap extends climate disclosure requirements to all listed companies by FY2025, with IFRS S2 (Climate-related Disclosures) replacing TCFD as the mandatory framework from 2026.
Taiwan Greenhouse Gas Reduction and Management Act
Taiwan's Greenhouse Gas Reduction and Management Act (now amended as the Climate Change Response Act) establishes a mandatory GHG inventory and reporting system for large emitters. The Act introduces a carbon fee mechanism, effective from 2025, targeting industrial facilities emitting above threshold levels. Companies in the semiconductor, petrochemical, steel, and cement sectors are primary targets. The carbon fee creates direct cost implications for Taiwanese manufacturers and their supply chains.
EU CSDDD — Corporate Sustainability Due Diligence Directive
EU companies sourcing from Taiwan — particularly in electronics, semiconductors, textiles, and precision manufacturing — will be required under CSDDD to conduct human rights and environmental due diligence across their supply chains. Taiwanese suppliers will receive questionnaires on labour practices, environmental management, conflict minerals, and carbon emissions. The semiconductor and electronics sectors face particular scrutiny given their global supply chain significance.
US Uyghur Forced Labor Prevention Act (UFLPA)
The US Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods produced in whole or in part in Xinjiang, China, or by entities on the UFLPA Entity List, are made with forced labour and are prohibited from import into the United States. Taiwanese electronics and manufacturing companies with supply chains touching Xinjiang — including polysilicon for solar panels, cotton, and certain raw materials — face significant compliance obligations and must document supply chain traceability.
What this means for you as a supplier
Taiwanese suppliers to international buyers face ESG requirements from multiple directions: domestic FSC mandatory sustainability reporting, EU CSDDD supply chain due diligence, US UFLPA forced labour compliance, and buyer-specific questionnaires from global technology companies. The semiconductor and electronics sectors face the most intensive scrutiny, with buyers requiring Scope 1, 2, and 3 emissions data, conflict minerals declarations (3TG: tin, tantalum, tungsten, gold), supply chain mapping, and labour rights certifications. Carbon emissions reporting is increasingly a procurement gate — major technology buyers including Apple, Google, and Microsoft require Taiwanese suppliers to report and reduce Scope 3 emissions.
Key dates
FY2023 (reported 2024)
Mandatory sustainability reporting — TWSE/TPEx companies with capital ≥NT$10bn
FY2024 (reported 2025)
Mandatory sustainability reporting extended to companies with capital ≥NT$2bn
2025
Taiwan carbon fee effective — large industrial emitters subject to carbon pricing
FY2025 (reported 2026)
Mandatory sustainability reporting extended to all TWSE/TPEx listed companies; TCFD climate disclosure mandatory for all listed companies
2026
IFRS S1 and S2 (ISSB standards) become mandatory framework for all listed companies
July 2029
CSDDD Phase 1 — largest EU companies must conduct supply chain due diligence including Taiwanese suppliers
Semiconductor supply chains: the most scrutinised in the world
Taiwan's semiconductor industry — led by TSMC, MediaTek, and ASE Group — sits at the centre of global technology supply chains. International buyers including Apple, NVIDIA, AMD, and major European electronics companies require their Taiwanese suppliers to report Scope 1, 2, and 3 greenhouse gas emissions, disclose water usage (critical for semiconductor fabrication), document conflict minerals sourcing (3TG: tin, tantalum, tungsten, gold), and demonstrate compliance with RBA (Responsible Business Alliance) standards. TSMC's own supplier code of conduct has become a de facto industry standard that flows down to sub-tier suppliers. Taiwanese SME suppliers to the electronics sector should expect detailed carbon, water, and labour questionnaires as a condition of continued procurement.
Carbon fee and CBAM: double exposure for exporters to the EU
Taiwanese manufacturers exporting to the EU face a dual carbon cost exposure. Domestically, Taiwan's carbon fee (effective 2025) applies to large industrial emitters. For EU exports, the EU Carbon Border Adjustment Mechanism (CBAM) imposes a carbon price on imports of cement, steel, aluminium, fertilisers, electricity, and hydrogen. Taiwanese steel and aluminium producers exporting to the EU must report embedded carbon content from October 2023 (transitional phase) and will face financial CBAM obligations from 2026. Companies in these sectors should establish carbon accounting systems and engage with their EU buyers on CBAM compliance documentation requirements.
FSC roadmap: what non-listed Taiwanese companies need to know
While the FSC mandatory sustainability reporting framework currently applies to TWSE and TPEx listed companies, the requirements flow down to unlisted suppliers through buyer procurement requirements. Listed companies are required to report on their supply chain sustainability, meaning that SME suppliers — even if not listed — will receive questionnaires from their listed customers. The FSC has also signalled that mandatory reporting will be extended to larger unlisted companies in future phases. Taiwanese SMEs should begin building ESG data collection capabilities now, even if not yet directly in scope for mandatory reporting.
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.
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