Climate Disclosure in the Global South

This Chapter examines the emerging landscape of corporate climate disclosure in the Global South, focusing on Brazil, India, China, and South Africa (“BICS”), and compares the adoption of international standards by the largest economies in both the Global South and North. We analyse these early developments in view of three perspectives on Global South regulatory tendencies: (i) the resistance view, predicting opposition to climate change measures due to developmental concerns, (ii) the foreign influence view, suggesting greater susceptibility to international standards, and (iii) the legal heterodoxy view, positing that Global South jurisdictions develop legal innovations incorporating broader public policy objectives. We find diverse patterns combining elements of all three views.  

Strikingly, all ten jurisdictions examined in the Global South and North have adopted some form of corporate climate disclosure in the last decade. However, following the withdrawal of the U.S. Securities and Exchange Commission’s defence for its climate rule in 2025, the U.S. stands out as the only major jurisdiction lacking a dedicated federal climate disclosure framework. Consistent with the foreign influence view, Brazil was the first jurisdiction worldwide to adopt ISSB standards, while China modified these standards to include double materiality. We also observe evidence of legal heterodoxy, with South Africa and India implementing pioneering frameworks for sustainability reporting that anticipated the European Union’s emphasis on double materiality. While Global South jurisdictions fall behind EU standards, they often exceed U.S. and Japanese requirements, thereby contradicting a strong version of the resistance view in this area.