2026 (ROC Year 115) ESG Evaluation Guide to Top Scores: 3 AA Indicators (G-18 / G-19 / G-26) and 17 A+ Indicators Explained—From 100 to 120 Points

If you have read our previous articles, “Three Impacts of the New 2026 ESG Evaluation and How Companies Can Respond” and “2026 ESG Evaluation: The Final Review Window”, you should already be familiar with the 75 indicators, E 21% / S 31% / G 48%, the evaluation period of 1 January–31 December 2026 (ROC year 115), the sustainability report filing deadline of 2026/8/31, which is not the deadline for all evaluation materials, and the A/B/A+/AA categories.

This article will not repeat those basics.

When reviewing client drafts this year, we have more often been asked, “What must we do to move from the middle of the rankings into the top 5%?” The answer lies in the 20 bonus indicators: 3 AA and 17 A+.

For each indicator below, I use three sections: “original requirements”, “market observations”, “estimated timeline”, focusing on whichever matters most for that indicator. The reason is simple: when the biggest obstacle is unwillingness to act, more explanation of requirements will not help.

Source Statement: All indicator requirements here are taken directly from the Taiwan Stock Exchange (TWSE) official 2026 (ROC year 115), First ESG Evaluation Indicators. Wording differences—“at least” versus “must”, or “once a year” versus “annual”—may affect compliance judgements. Before publication, cross-check the latest indicator table at the TWSE ESG Evaluation Portal.

Why Do the 75 Indicators Only Earn 100 Points? Start with the Scoring Formula

TWSE's scoring formula this year is:

Total score = [E score ÷ applicable E indicators × 21%

+ S score ÷ applicable S indicators × 31%

+ G score ÷ applicable G indicators × 48%] × 100

+ AA weighted points (up to +3)

+ A+ bonus points (up to +17)

± additional adjustments (added or deducted case by case, 1 point or more; deductions stop at 0)

Important: The denominator is the number of applicable indicators, not fixed values of 16/23/36. TWSE's 2026 (ROC year 115) example uses E=16, S=23 and G=35: one G indicator is inapplicable to that company, so 36−1=35. Actual denominators vary with inapplicable indicators.

The weighted percentage scores for the three dimensions total at most 100. Meeting all 20 AA and A+ indicators adds up to 20 more points, for a maximum of 120; additional bonus items are awarded case by case, and deductions cannot take the total below 0. These 20 bonus indicators make this evaluation more discriminating than earlier versions; bonus completion can create score differences exceeding 20 points.

A Concrete Numerical Comparison

Assume Companies A and B both meet all 75 basic indicators:

Both companies write the same environmental, social and governance sections, but B's 20 additional concrete actions move it up two ranking bands.

Key point: With limited resources, checking off these 20 bonus requirements can be more valuable than expanding one response from 800 to 1500 characters.

AA is this evaluation's most distinctive design: meeting the requirements earns dimension points plus 1 additional point in the total score. All three are in G, signalling that TWSE sees these actions as dividing lines in governance transparency.

Original requirements (all 4 required; dimension points +1 total point):

1. The audit committee or a board-level functional committee, such as a risk management committee, oversees risk management; it has at least 3 members, at least half of whom are independent directors
2. 2. Risk management policies and procedures are board-approved and disclosed
3. 3. Disclose the risk management structure, procedures and operations in 2026 (ROC year 115)
4. 4. Disclose reporting frequency to the board (at least once a year) or the reporting date in the current year

Our Market Observations: Reviewing several TWSE/TPEx-listed clients in the first half, the most common issue was not the absence of a committee, but that “independent directors did not make up half the committee”, because of mid-year resignations, delayed replacement elections or counting supervisors. The next most common issue was assigning risk management to the audit committee without a separately identifiable risk item in its annual meeting minutes. Reviewers classify both as non-compliant.

Key point: G-18 tests both committee composition and whether it actually met to discuss risk during the year—not simply whether a committee exists.

Original requirements (all 3 required; dimension points +1 total point):

1. Board-approved performance evaluation rules explicitly require external evaluation at least once every three years
2. 2. Disclose the evaluation date within the past three years (2024–2026, ROC years 113–115), external institution or lead expert, basis for independence, methods (questionnaire/site visit), assessment items and date results were reported to the board
3. 3. Summarise results, including recommendations and future improvement plans

Choosing an External Evaluator: Market Fees and Assessment Frameworks

Companies undertaking their first external evaluation can refer to the “Taiwan Corporate Governance Association (CGA)”, whose publicly quoted basic fees are around NT$160,000–200,000, adjusted for size and detailed requirements. Large accounting firms or other external providers may charge around NT$300,000–800,000.

Professional institutions typically examine board effectiveness across five dimensions:

• Board composition and division of responsibilities: Are members' backgrounds diverse, and do committees fulfil their functions?
• Board direction and oversight: Does it effectively guide strategy and oversee management performance?
• Board delegation and risk management: Are delegated authorities clear and risk controls sound?
• Board communication and collaboration: Does information flow smoothly among directors and between the board and management?
• Board self-discipline and development: Directors' continuing education and implementation of ethical standards.

Original requirements (either condition qualifies; dimension points +1 total point)

1. Voluntarily disclose every director's individual remuneration details
2. After legally required disclosure for some directors, voluntarily disclose all remaining directors' individual remuneration details

This has the shortest requirements but is usually the hardest of the 3 AA indicators to implement. The obstacle is the board's attitude, not report wording.

We have encountered sustainability teams seeking full disclosure while boards—especially family businesses and major-shareholder directors—strongly object on grounds of personal data, peer comparisons or family privacy. That is precisely why TWSE values this indicator: companies willing to disclose demonstrate governance transparency a level above 90% of their peers, a powerful signal to foreign investors, sovereign wealth funds and ETF stock selectors.

Key Point: G-26 is the only AA indicator where “the disclosure barrier sits with the board, not the report”. Consider having the chair and independent directors disclose first, then extending to everyone.

Summary: None of the 3 AA indicators is solved simply by writing more. Committee composition may need changing, external evaluations need budgets, and remuneration disclosure needs board consent. Our rough assessment is that companies earning none of the 3 AA points and fewer than 10 A+ points have almost no chance of reaching the top 5% this year.

The A+ design is straightforward: Meet the basic requirements → earn dimension points; meet the additional requirement → gain 1 point in the total. The 17 indicators offer 17 points: 4 in E, 5 in S and 8 in G.

Key Point: Three environmental A+ indicators depend on external certification or verification, often taking six months to a year. Starting in April is generally too late for E-2 / E-8 / E-13 before the 8/31 filing deadline.

Governance has the most A+ indicators, divided into two very different groups: structural and disclosure requirements:

All 20 matter, but with only 3–6 months left, prioritise “low effort × high differentiation”. The ranking below draws on actual timelines from our work with listed clients over the past six months:

• E-2 External Scope 1 and 2 verification (SGS, BSI, DNV, BV; +3–6 months)
• E-8 ISO 50001 energy management certification (+6–9 months)
• E-13 ISO 14001 environmental management certification (many companies already have it; otherwise +6–9 months)
• S-12 ISO 27001 information security certification (+6–12 months)
• G-19 External board evaluation (CGA or consulting firm; +1–2 months for scheduling)

• G-10 All directors are natural persons (next board election)
• G-14 Independent directors hold at least 1/2 of seats (next board election)
• G-18 At least half the risk management committee are independent directors (charter/committee composition)
• G-30 Appoint a CSO (board resolution establishing the position)

Many companies start supplementing materials only three months before each evaluation. But ESG Evaluation is fundamentally about governance systems. The indicators test whether the company actually has a mechanism, not merely whether the report contains a paragraph about it.

Companies that move from 100 to 120 do three things: first reform governance structures (G-10/14/18/30), then disclose operating data fully (E-2/8/13, S-9/12, G-3/7/21), and finally secure verification/assurance (E-13, S-10, G-26). Start with systems, follow with data and complete quality checks; with this sequence, 120 points follows naturally.

👉 Try the SustainAI case search database free→: Search terms such as Chief Sustainability Officer, external performance evaluation and individual director remuneration to compare disclosures by listed companies that have earned bonus points