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ESG DID NOT COLLAPSE IN 2026. IT CHANGED ADDRESS
Muhammad Nazrul Abd Rani
The dominant headline about sustainability regulation in 2026 has been one of retreat. After two years in which the European Union set the global pace, Brussels has spent the past year unwinding much of what it built. Read on its own, that story invites a comfortable conclusion: the ESG project has peaked, the compliance burden is lifting, and companies that delayed were right to wait. The data tell a more awkward story. The centre of gravity in sustainability reporting has not disappeared; it has moved east, and it has changed shape. For boards in Malaysia and the wider region, mistaking the European retreat for a global reprieve is the single most expensive error available this year.
The retreat that everyone noticed
On 24 February 2026 the Council of the European Union gave final approval to the Omnibus I simplification package, published two days later as Directive (EU) 2026/470 and in force from 18 March 2026 (Council of the EU, 2026; Gibson Dunn, 2026). The package rewrites the two instruments that had defined the EU's sustainability ambition. Under the amended Corporate Sustainability Reporting Directive (CSRD), mandatory reporting now applies only to companies with more than 1,000 employees and more than €450 million in net turnover, a sharp increase from the previous thresholds (Council of the EU, 2026). The Corporate Sustainability Due Diligence Directive (CSDDD) is confined to companies above 5,000 employees and €1.5 billion in turnover, with first compliance deferred to 26 July 2029 (Clifford Chance, 2026).
The changes are not merely numerical. The category of listed small and medium-sized issuers, previously due to begin reporting from 2026, has been removed from scope altogether (Clifford Chance, 2026). The obligation under the CSDDD to adopt and implement a Paris-aligned climate transition plan has been struck out; companies must still describe a plan where one exists, but the duty to act has gone (Latham & Watkins, 2025). Taken together, the reforms remove a large majority of previously covered companies from the mandatory perimeter and soften the obligations on those that remain. The European Commission frames this as competitiveness; the substance is a deliberate narrowing of one of the most ambitious disclosure regimes ever attempted.
The advance that fewer noticed
While Europe simplified, the standard built to be the global baseline kept spreading. The International Sustainability Standards Board (ISSB) issued IFRS S1 and IFRS S2 in June 2023. By 22 April 2026, 28 jurisdictions had adopted the standards on a voluntary or mandatory basis, with a further 12 preparing to do so; the cohort moving towards adoption now represents more than 60% of global gross domestic product (S&P Global, 2026). This is not a European story being retold elsewhere. It is a different architecture, anchored in securities regulation rather than corporate law, and it is consolidating fastest across Asia-Pacific.
Malaysia sits inside that wave rather than at its edge. The National Sustainability Reporting Framework (NSRF), launched by the Ministry of Finance and the Securities Commission Malaysia on 24 September 2024, adopts IFRS S1 and S2 as the national baseline (Securities Commission Malaysia, n.d.). Implementation is phased and climate-first. Group 1, comprising the largest Main Market issuers with market capitalisation of RM2 billion and above, roughly 130 companies representing more than 80% of Bursa Malaysia's market capitalisation, began reporting for annual periods starting on or after 1 January 2025 (S&P Global, 2024). Group 2, the remaining Main Market issuers, follows from 1 January 2026, and Group 3, covering ACE Market issuers and large non-listed companies with annual revenue of RM2 billion and above, from 1 January 2027 (Securities Commission Malaysia, n.d.). Reasonable assurance on Scope 1 and Scope 2 greenhouse gas emissions is scheduled for Group 1 from reporting periods beginning on or after 1 January 2027, with Scope 3 disclosure phased in over the same horizon.
The contrast is stark. In the same eighteen months that Europe lifted the floor and let most companies out, Malaysia laid a floor and began moving companies onto it.
Why this is a recomposition, not a rollback
The instinct to read these two movements as a simple win for deregulation misses the more interesting point. What is happening is a recomposition of what sustainability disclosure is for, and the two regimes answer that question differently.
The European model, built on double materiality, asked companies to report both how sustainability issues affect the business and how the business affects society and the environment. The ISSB model rests on financial materiality alone: disclose the sustainability-related risks and opportunities that could reasonably affect cash flows, access to finance, or cost of capital. The first is an accountability instrument aimed at a broad set of stakeholders; the second is an investment instrument aimed at capital providers. As Europe's impact-focused obligations contract and the investor-focused ISSB baseline expands, the global default is quietly shifting from the former towards the latter.
This matters for how the retreat should be interpreted. The EU has not concluded that climate risk is immaterial; it has concluded that its particular method of capturing impact imposed costs it was no longer willing to defend politically. The ISSB framework, by contrast, is gaining ground precisely because investors find a single, comparable, financially framed dataset useful. The two systems are also converging on interoperability at the technical level, with mapping between the European standards and IFRS S2 reducing duplicate reporting for companies caught by both. The headline of divergence conceals a quieter standardisation underneath.
What it means for Malaysian boards
For directors and sustainability leads in Malaysia, three implications follow, and none of them counsel delay.
First, the domestic clock is independent of Brussels. A Malaysian Main Market issuer's obligations flow from the NSRF and the amended Bursa listing requirements, not from the CSRD. The European simplification changes nothing about a Group 2 company's 2026 reporting period or a Group 3 company's 2027 onset. Boards that have been waiting for regulatory clarity now have it, and it points towards disclosure, not away from it.
Second, the value chain still reaches across borders, even as Europe narrows its formal scope. Large EU and multinational buyers that remain in scope of the CSRD, and those that continue voluntary reporting for investor and financing reasons, will keep requesting emissions and governance data from suppliers. A Malaysian exporter is not exempt because its European customer's threshold rose; it is simply receiving the request through commercial channels rather than statutory ones. The data demand has been privatised, not removed.
Third, capital is pricing disclosure quality regardless of mandate. The growing body of evidence linking credible sustainability reporting to financing terms is the relevant signal here, not the European headline. With the ISSB baseline becoming the lingua franca for more than 60% of the world economy by GDP, the cost of being unreadable to international investors is rising, not falling.
The problem the new architecture still has to solve
None of this resolves the credibility question that has dogged sustainability reporting from the start. A 2024 PwC global investor survey found that around 94% of institutional investors believed corporate sustainability reporting contained at least some greenwashing (PwC, 2024). A common, comparable standard helps, but a standard is only as trustworthy as its assurance. This is where Malaysia's sequencing is instructive. By scheduling reasonable assurance on Scope 1 and Scope 2 emissions for its largest issuers from 2027, the NSRF treats verification as integral rather than optional, which is the only durable answer to the greenwashing charge.
The deeper risk is not non-compliance but hollow compliance: reports that satisfy the letter of IFRS S1 and S2 while disclosing little that is decision-useful. The standards mandate a structure, governance, strategy, risk management, metrics and targets, but they cannot mandate candour. The jurisdictions that extract real value from this transition will be those whose regulators and auditors hold disclosures to a substantive test, not merely a formal one.
The analytical bottom line
The convenient reading of 2026, that ESG has run out of road, does not survive contact with the figures. One major regime contracted; a larger and more globally distributed one expanded. For Malaysian institutions the practical question is not whether the regulatory tide is going out, because in this jurisdiction it is plainly coming in, but whether they will treat disclosure as a compliance cost to be minimised or as a discipline that improves how they understand their own exposure to a changing climate and a changing capital market. The address has changed. The obligation has not.
References
Clifford Chance. (2026, February). Omnibus I: The European Union concludes CSDDD and CSRD reforms. https://www.cliffordchance.com
Council of the European Union. (2026, February 24). Council signs off simplification of sustainability reporting and due diligence requirements to boost EU competitiveness [Press release]. https://www.consilium.europa.eu
Gibson Dunn. (2026, March). Omnibus simplification of EU's sustainability rules (CSRD and CSDDD) enacted. https://www.gibsondunn.com
Latham & Watkins. (2025, December). European institutions reach agreement on sustainability omnibus. https://www.lw.com
PwC. (2024). Global investor survey 2024. PricewaterhouseCoopers.
S&P Global. (2024, December). Getting ready for NSRF: Malaysia's ISSB-aligned enhanced sustainability disclosures. https://www.spglobal.com
S&P Global. (2026, May). Where does the world stand on ISSB adoption? https://www.spglobal.com
Securities Commission Malaysia. (n.d.). National Sustainability Reporting Framework. https://www.sc.com.my/nsrf