Korea FSC Consultation on ESG Disclosure Roadmap

We refer to the Financial Services Commission's public consultation on the ESG Disclosure Roadmap Draft announced on 25 February 2026. We welcome the opportunity to provide our perspective as a global institutional investor on the implementation timeline for South Korea's sustainability disclosure framework.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with USD 2.11 trillion (KRW 3,047.16 trillion) at 31 December 2025 invested across 68 countries, of which approximately USD 27.6 billion (KRW 39.9 trillion) was invested in the shares of 410 South Korean listed companies.

As a long-term, global investor, we consider our returns over time to be dependent on sustainable development in economic, environmental and social terms, as well as on well-functioning, legitimate and efficient markets. We need consistent, comparable, reliable and decision-useful information from companies on sustainability-related risks and opportunities that are financially material to their business. This information informs our investment decisions, risk management processes and ownership activities.

We commend Korea's comprehensive capital market reforms enhancing minority shareholder protection and transparency. The ESG disclosure roadmap complements the January 2026 reforms on English-language disclosure, executive compensation, and AGM voting results. Both governance and sustainability disclosures use the same materiality threshold (impact on company prospects), require board oversight, and connect to financial reporting. The Korean standards' requirement to disclose sustainability factors in executive remuneration directly links these reforms. Together, they strengthen investor confidence and support Korea's objectives of reducing the Korea discount and attracting international capital.

Achieving Korea’s KRW 790 trillion Climate Finance Activation Plan and 2035 NDC targets requires complete, comparable corporate climate disclosures. The Climate Finance Web Portal, Financial Emissions Platform, and Transition Finance framework depend on comprehensive emissions data, including Scope 3, to enable effective capital allocation and risk assessment. Companies seeking transition finance will need credible baseline emissions, transparent transition plans, and capital expenditure disclosures. The disclosure roadmap is therefore critical infrastructure for Korea's industrial decarbonisation, and ambitious requirements aligned with international best practice and investor needs are essential to success.

We strongly encourage Korea FSC to strengthen the roadmap, in particular by:

1. Restricting Scope 3 grace period to companies where scope 3 emissions are not material
2. Requiring companies to refer to and consider the applicability of industry-based metrics
3. Introducing mandatory limited assurance for Scope 1 and 2 emissions
4. Committing statutory disclosure within a short transition period
5. Considering phasing in all KOSPI 200 companies to ensure comprehensive coverage of companies material to international investor portfolios

Please find in the annex our detailed responses to the ESG Disclosure Roadmap Draft. They build on our August 2024 KSSB submission, where we raised similar concerns on Scope 3 emissions and industry-based metrics. Our recommendations focus on ensuring Korean companies provide the complete, comparable climate information that global investors require to support decision making and capital allocation.

We thank the FSC for this opportunity and remain available for continued dialogue.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                     

Jeanne Stampe
Policy Lead