In the first half of 2026, three of the world's major economies all moved to ease their sustainability disclosure requirements, yet their motivations and approaches could not be more different. For companies with export operations or a multinational footprint, understanding these differences matters just as much as knowing that all three are "easing".
The EU: Simplifying the Process but Keeping the Goal
The EU is cutting the number of mandatory disclosure datapoints in the European Sustainability Reporting Standards (ESRS) by 61%, while also narrowing the scope of companies required to comply with the Corporate Sustainability Reporting Directive (CSRD), which now applies only to companies with revenue above €450 million and more than 1,000 employees.
The key point: this is a simplification of process, not a retreat from policy goals. The double materiality principle remains untouched, and the EU continues to pursue sustainability transparency as a pillar of the European Green Deal. The European Commission itself calls this "simplification," not "deregulation."
The US: Stepping Back From Mandatory Climate Disclosure at the Federal Level
The US Securities and Exchange Commission (SEC) has formally moved to rescind the climate-related disclosure rule adopted in 2024. This is a full reversal, not a content adjustment in the way the EU is approaching things. The SEC has also dropped its anti-greenwashing rules for investment funds.
Unlike the EU, this is not an effort to reduce administrative burden while preserving the underlying objective. It reflects a change in policy stance at the highest level: climate disclosure is no longer treated as something that must be mandated at the US federal level.
Brazil: Shifting From Mandatory to Voluntary, While Keeping the ISSB Framework
On 29 May 2026, Brazil's Securities and Exchange Commission (CVM) issued Resolution 244, shifting ISSB-aligned sustainability disclosure (IFRS S1 and S2) for listed companies from mandatory to voluntary, under a "comply-or-explain" mechanism from a specified date.
This is where Brazil differs from the US: it is not abandoning the ISSB framework, only changing its legal weight. Brazilian companies are still encouraged to adopt the international standard; they are simply no longer required to, and can explain their reasons for not applying it instead of complying in full.
Why "Easing" Means Something Different in Each Market
| EU | US | Brazil |
Nature of the change | Simplifying content, keeping the goal | Fully rescinding the rule | Shifting from mandatory to voluntary |
Reference framework | Still uses ESRS, with greater interoperability with ISSB | No mandatory federal climate disclosure framework remains | Still encourages ISSB adoption |
Implication for international investors | Data still available, just leaner | Standardized federal-level data is missing | Data may lack consistency across companies |
For companies exporting or operating across multiple markets, "ESG is being eased globally" is a conclusion that can easily mislead if these three cases aren't distinguished. Partners, customers, and investors in the EU still expect full sustainability data, just collected through a leaner process. Meanwhile, the US market may see less mandatory federal-level disclosure pressure, but individual states or institutional investors can still set their own requirements.
The global ESG picture in 2026 is not simply "cooling down." It is diverging by region, each following its own logic. Companies with multinational operations need a reporting strategy flexible enough to adapt to each market, rather than a one-size-fits-all approach.

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