Before You File: Common ESG Report Deficiencies, FY2024 Review Results and Corporate Examples

Updated 6 October 2026. Updated FY2024 review priorities and the ESG Evaluation name, retaining company examples from earlier years.

This article summarises the Taiwan Stock Exchange (TWSE) and Taipei Exchange (TPEx) publication issued in May 2026, FY2024 Sustainability Report Review Results and Disclosure Recommendations, explaining review priorities and common deficiencies. Examples from past corporate reports help companies check disclosure content, preparation processes and compliance requirements.

Who May Be Selected for Review?

In principle, every TWSE/TPEx-listed company's sustainability report is subject to a sample review by TWSE or TPEx at least once every five years to ensure compliance with relevant rules and guidance. In addition to routine sampling, regulators apply a risk-based approach, using the high-risk ESG characteristics shown below to intensify review of selected companies.

For example, a company that was a high carbon emitter in the previous year, received Labour Standards Act penalties, or experienced a cybersecurity incident may be selected using these environmental, social or governance risk indicators.

High-Risk Characteristics Across the Three ESG Areas:

The diagram above shows high-risk characteristics across the three ESG areas (source: November 2024 review materials). For the at-least-once-every-five-years and risk-based sampling principles, see pages 8–9 of the May 2026 review presentation.

Regulatory Review Content and Priorities

TWSE and TPEx sustainability report reviews cover general requirements and specific topics. Key points for each are outlined below:

• General review:

1. Refer to GRI 2: General Disclosures and disclose all relevant requirements. GRI 2-1–2-5 cannot be omitted; explain reasons for omitting other disclosures.
2. Refer to GRI 3: Material Topics to explain how material topics were determined and disclose the results.
3. Refer to Article 4-1 of the Rules Governing the Preparation and Filing of Sustainability Reports to disclose climate information.
4. If sustainability disclosure indicators have been issued for the company's industry, disclose all of them in full.

• Specific topics:

1. For each material topic, refer to the corresponding GRI Topic Standards.

FY2024 Review Results: 9 GRI General Disclosure Deficiencies

The May 2026 presentation lists statistics for 9 GRI 2 deficiency categories, including 137 instances for remuneration policies, 129 for annual total compensation ratios and 102 for collective bargaining agreements. These 9 categories cover GRI General Disclosures; they do not represent all types of review deficiencies.

• GRI 2-19 Remuneration Policies: Explain how executive remuneration links to sustainability targets and performance.
• GRI 2-21 Annual Total Compensation Ratio: Apply the standard's formulas and explain the calculation basis.
• GRI 2-30 Collective Bargaining Agreements: Explain coverage and working conditions for employees not covered.
• GRI 2-7 Employees: Disclose headcount categories, calculation methods and significant fluctuations.
• GRI 2-27 Compliance with Laws and Regulations: Disclose significant non-compliance, penalty statistics and the criteria used.
• GRI 2-14 Role of the Highest Governance Body in Sustainability Reporting: Explain the highest governance body's responsibility for reviewing and approving the report.
• GRI 2-17 Collective Knowledge of the Highest Governance Body: Explain measures to enhance directors' sustainability knowledge and capabilities.
• GRI 2-4 Restatements of Information: Explain reasons for restatements and their effects.
• GRI 2-5 External Assurance: Clearly identify the scope of information subject to external assurance.

Companies must also check that material topics, climate-related information, industry sustainability indicators and significant ESG events are fully disclosed. Source: FY2024 Sustainability Report Review Results and Disclosure Recommendations; further reading: FY2024 Review Results Explained.

Common Deficiencies from Past Reviews and Corporate Report Examples

The following 13 checks draw on review materials from earlier years, paired with 2023 corporate sustainability report examples. They illustrate common issues and disclosure approaches for self-assessment against current standards and each company's applicable requirements.

(1) Failing to Refer to the Latest GRI Standards

Common deficiency: The report does not state that it was prepared with reference to the latest GRI Standards. Using outdated GRI disclosures will result in regulators requiring the report to be restated.

Better disclosure: Refer to the current GRI version—GRI 2021—and state which standards were used in the report.

Report example:

Source: China Airlines 2023 Sustainability Report, p.4

(2) Failing to Use a GRI Content Index

Common deficiency: The report lacks a GRI content index or omits material topics from it. Material topic information must also be fully disclosed in the report.

Better disclosure: Include a GRI content index in the appendix, clearly indicating the relevant chapters and pages for each disclosure. GRI 2-1–2-5 are basic disclosures that cannot be omitted; provide specific reasons for any omitted disclosures elsewhere in GRI 2.

For example, if no information was restated under GRI 2-4, explicitly state “No restatements of information this year” in the index instead of omitting the disclosure.

For material topics, list all corresponding GRI Topic Standards, ensure each disclosure is addressed specifically in the report, and identify the location of the content.

Report example:

Source: Taiwan Cement 2023 Sustainability Report, pp.190, 193

(3) Failing to Explain Differences from Financial Reporting Boundaries (GRI 2-2)

Common deficiency: The report does not explain differences between its disclosure scope and the subsidiaries included in consolidated financial statements.

Better disclosure: Clearly explain any differences from consolidated financial reporting boundaries. If Company A's financial statements include all subsidiaries but its sustainability report covers only headquarters, explicitly state that subsidiaries are excluded. Alternatively, follow the example below by providing a link to consolidated financial statements for stakeholders.

Report example:

Source: China Steel 2023 Sustainability Report, p.1

(4) Failing to State Third-Party Assurance Status (GRI 2-5)

Common deficiency: The report does not indicate whether each disclosure has received third-party assurance.

Better disclosure: If the report is externally verified or assured, clearly identify the provider, standards and level of assurance, and link to the assurance report or statement.

Report example:

Source: China Airlines 2023 Sustainability Report, p.5

(5) Failing to Disclose the Industry (GRI 2-6)

Common deficiency: The report does not identify the company's industry.

Better disclosure: Clearly state the industry classification with reference to the Taiwan Stock Exchange's industry categories.

Report example:

Source: E.SUN Financial Holding 2023 Sustainability Report, p.14

(6) Failing to Disclose Employment Types by Region and Headcount Changes (GRI 2-7)

Common deficiency 1: The report omits regional breakdowns of full-time, part-time and other employment types.

Better disclosure: Classify employees by region based on company locations and present the numbers of full-time, part-time and other employee types.

Report example:

Source: International CSRC Investment Holdings 2023 Sustainability Report, p.108

Common deficiency 2: The report omits significant headcount fluctuations during the reporting period compared with the previous year.

Better disclosure: Explain significant changes in employee numbers and their causes. If none occurred, explicitly state “No significant headcount fluctuations” rather than leave the issue unaddressed.

Report example:

Source: Asia Cement 2023 Sustainability Report, p.87

(7) Failing to Disclose Measures to Enhance Directors' ESG Capabilities (GRI 2-17)

Common deficiency: The report omits directors' ESG training or other measures to strengthen their ESG capabilities.

Better disclosure: Explain whether directors' training, seminars or professional development covered ESG. Where it did, describe the content and hours to meet the disclosure requirement.

Report example:

Source: International CSRC Investment Holdings 2023 Sustainability Report, p.26

(8) Failing to Disclose Links Between Senior Remuneration and Sustainability Targets (GRI 2-19)

Common deficiency: The report omits remuneration policies for the highest governance body and senior executives and does not explain links to the company's sustainability targets and performance.

Better disclosure: Identify executive remuneration components linked to environmental, social or governance performance, including their weightings, assessment methods and connection to sustainability targets. If no link exists, explicitly state “The company does not currently link remuneration to sustainability targets” rather than omit the subject.

Report example:

Source: President Chain Store Corporation 2023 Sustainability Report, p.45

(9) Failing to Disclose Annual Total Compensation Ratios or Reasons for Omission (GRI 2-21)

Common deficiency: Incorrect formulas are used, or GRI 2-21 annual total compensation ratios are omitted without explanation.

Better disclosure:

Companies must disclose both of the following:

• The ratio of the highest-paid individual's annual total compensation to the median annual total compensation of all other employees
• The ratio of the percentage change in the highest-paid individual's annual total compensation to the median percentage change for all other employees

Note: For other employees' annual total compensation, calculate the median percentage change by first calculating each employee's percentage change, then taking the median of those values. Do not simply compare the median compensation figures for the two years.

Report example:

Source: Formosa Plastics Corporation 2023 Sustainability Report, p.126

(10) Failing to Define Significant Non-Compliance (GRI 2-27)

Common deficiency: The report does not define significant instances of non-compliance or explain the judgement basis and assessment criteria.

Better disclosure: Explain the company's criteria for significant non-compliance. For example, under the rules for verifying and disclosing material information by listed companies, a single incident with cumulative fines of NT$1 million or more is treated as significant non-compliance.

Report example:

Source: LITE-ON Technology 2023 Sustainability Report, p.46

(11) Failing to Explain Collective Bargaining Agreements and Employee Protections (GRI 2-30)

Common deficiency: The report does not explain why no collective bargaining agreement exists or describe protections or alternative arrangements for working conditions of employees without such agreements.

Better disclosure: (where no union exists, or a union exists but no collective bargaining agreement has been signed):

Explain why no collective bargaining agreement has been signed, such as no union having been formed or no proposal from the union. Describe safeguards or alternative measures protecting working conditions and labour rights.

Report example:

Source: E.SUN Financial Holding 2023 Sustainability Report, p.146

Better disclosure: (where a collective bargaining agreement has been signed):

Explain the agreement's scope and percentage of employees covered, along with working-condition protections for those not covered, ensuring basic rights for all employees.

Report example:

Source: Asia Cement 2023 Sustainability Report, p.93

(12) Failing to Disclose the Scope of Material Topic Impacts (GRI 3-3)

Common deficiency: The report does not disclose the scope of each material topic's actual impacts inside and outside the company.

Better disclosure:

Describe positive and negative impacts on the economy, environment and society, indicating whether they arise directly from company operations or upstream/downstream in the value chain, and describe the main value chain activities.

Report example:

Source: Taishin Financial Holding 2023 Sustainability Report, pp.24, 26

(13) Failing to Disclose Industry Sustainability Indicators

Common deficiency: Fourteen specified industries must disclose additional sustainability indicators. Omitting an index table from the appendix will be recorded as a deficiency.

Better disclosure: Disclose the relevant indicators for the company's specified industry and include an appendix index showing the location of each disclosure to improve completeness and accessibility.

Report example:

Source: China Steel 2023 Sustainability Report, p.154

Strengthen Sustainability Information Controls Through Systematic Management

Regulators review sustainability reports regularly to ensure information quality, consistency and traceability. As requirements become more rigorous, preparing reports in Word and Excel makes source management difficult and lacks change records, increasing the risk of data errors, inconsistent information and unclear accountability.

Many companies have therefore adopted digital systems, using permissions, version control and review workflows to improve preparation efficiency while also strengthening transparency and compliance and establishing sustainability information controls.

Sustaihub's Syber Sustainability Management System offers three key capabilities to help companies ensure information accuracy:

1. History logs and review workflows: Improve data reliability
2. Cross-departmental data integration and real-time updates: Resolve fragmented data
3. Multi-level permission controls: Strengthen sustainability information and data security

Use the Syber Sustainability Management System to achieve compliance and improve internal efficiency without extensive time and staffing costs. With comprehensive sustainability support, it is an ideal collaboration platform for corporate sustainability reports.

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Sources: FY2024 Sustainability Report Review Results and Disclosure Recommendations, ESG Evaluation Framework and History.

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