Comparative review on ESG disclosure framework in Asia: Singapore, Hong Kong, and Malaysia against EU benchmarks

Abstract

Driven by intensifying investor scrutiny and cross-border regulatory spillover, the demand for globally comparable sustainability reporting has sharpened. This study investigates why ESG disclosure frameworks diverge across Asia-Pacific jurisdictions, specifically examining how historical policy continuity shapes current configurations in Hong Kong, Singapore, and Malaysia relative to the EU's ESRSs. A qualitative comparative analysis is employed, systematically mapping each Asian framework against the ESRSs across mandatory scope, assurance requirements, sectoral coverage, and phased implementation. The concept of policy continuity serves as the central analytical lens, enabling a process-oriented interpretation of institutional evolution rather than a static gap assessment. Asian frameworks demonstrate marked heterogeneity, with voluntary approaches, staggered roadmaps, and narrower sectoral applications contrasting with the EU's comprehensive mandatory regime. Policy continuity emerges as a double-edged instrument in that it preserves regulatory predictability and local stakeholder trust, yet simultaneously anchors legacy practices that impede rapid alignment with the EU's accelerating trajectory. Divergent reporting standards are fundamentally embedded in each jurisdiction's unique institutional layering. The analysis confirms that path dependency does not preclude deliberate recalibration, but substantive convergence demands intentional, periodic policy interventions. Regulators should conduct structured gap analyses and evidence-based periodic reviews of domestic guidelines. Strategically balancing local developmental priorities with global norms will enhance cross-jurisdictional comparability, strengthen international investor confidence, and reduce compliance fragmentation for multinational enterprises operating across these markets.