加快可持续性披露和保证标准的司法实施

About this report. This report aims to equip policymakers and regulators1in theUK and China with recommendations for accelerating thedevelopment and implementation of high-quality sustainabilitydisclosure and assurance standards. About ACCA. We are ACCA (the Association of Chartered Certified Accountants),the only truly global professional accountancy body. Since we were founded in 1904, we’ve been breaking down barriersto the accountancy profession. Today we proudly support a diversecommunity of over257,900members and530,100future membersin180countries. By understanding the approaches, challenges and lessons learned in each other’s jurisdiction, both countriescan strengthen the coherence and credibility of their sustainability reporting – and ultimately enable smoothercross-border trade and investment. The analysis draws on insights gathered during an ACCA-convened roundtable held in November 2025which brought together participants from the UK and China, including policymakers, regulators, academia,accountancy and assurance professionals, financial institutions and corporates of different sizes, includingboth listed and unlisted entities. The roundtable participants shared their insights on the challenges they’reseeing in the UK, China or internationally and made recommendations for policymakers and regulators on howthese challenges could be overcome. These insights were supplemented by desk-based research. We’re redefining accountancy. Our cutting-edge qualifications,continuous learning and insights are respected and valued by employersin every sector. They equip individuals with the business and financeexpertise and ethical judgement to lead and drive sustainable value inorganisations and economies worldwide. Guided by our purpose and values, we’re leading the accountancyprofession for a changed world. Partnering with policymakers, standardsetters, the donor community, educators and other accountancybodies, we’re strengthening and building a profession that focuses onpeople, planet and prosperity to create value for all. The report outlines the key features of sustainability disclosure and assurance standards in the UK and Chinain relation to the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards (ISSBStandards) and the International Standard on Sustainability Assurance 5000 (ISSA 5000). It highlights sharedchallenges in the development and implementation of sustainability disclosure and assurance standards andoffers specific recommendations for policymakers and regulators. It also includes examples of actions takenin both jurisdictions.2 Find out more ataccaglobal.com Contents. Useful resources28 Acknowledgements28 References29 Executivesummary. The role of regulators and policymakers inovercoming challenges Regulators and policymakers can accelerate the effective developmentof sustainability reporting and assurance by setting realistic, maturity-based expectations and adopting a phased implementation approach.Anchoring requirements in internationally recognised frameworks – suchas the ISSB Standards and ISSA 5000 – with minimum jurisdictionalamendments promotes coherence and consistency across disclosures. A collaborative and consultative approach enables early identification ofimplementation challenges and supports learning both within and acrossjurisdictions. Providing clear guidance and practical implementationsupport, and promoting the use of digital tools, will further strengthenuptake. Setting out a transparent roadmap with defined milestones helpsorganisations plan, align and build capacity while reducing uncertaintyand associated costs. For sustainability assurance, regulators should ensure clarity ofterminology, expectations and scope so as to build confidence in themarket. Supporting a diverse and skilled assurance ecosystem, reflectingthe breadth of sustainability topics, is essential. This market shouldoperate under the supervision of an appropriate oversight body toenhance credibility and trust. The adoption of the ISSB Standards and ISSA 5000 is criticalfor enhancing comparability and consistency of sustainabilitydisclosures. Using the ISSB Standards and ISSA 5000 reducesthe risk of fragmented local requirements, and enables morecomparable, transparent, trust-worthy and decision-usefulinformation across jurisdictions – thereby reducing costs formultinational entities, facilitating international trade and givinginvestors the information they need to allocate capital effectively. In a survey for ACCA’sSustainability reporting: Trackyour progress to create decision-useful information(Machado et al. 2025), 71% of respondents identifiedregulatory compliance and the correspondinglicence to operate as a key driver for creating or usingsustainability information.3 The report also identifies the top three common challenges inthe UK and China in developing/implementing processesto create and use sustainability information: Robust and consis