The UK and China are converging on how they regulate sustainability disclosure and assurance, according to a new ACCA report based on a roundtable with policymakers, regulators, auditors and businesses from both countries.
Both markets have built their national rules around the same global scaffolding: the ISSB’s disclosure standards and the IAASB’s ISSA 5000 assurance standard. China has added its own layer on top, including a double materiality requirement and locally relevant topics such as rural revitalisation and anti-corruption; the UK’s version stays close to the ISSB text with only minor tweaks.
The report’s central argument is pacing. Rolling out mandatory disclosure and assurance too fast, it warns, risks overwhelming smaller preparers and producing poor-quality reports that undermine investor trust rather than build it. Its recommendations: phase requirements in gradually, publish a clear roadmap with firm milestones, invest in guidance and training to close a persistent skills gap, and widen the assurance market beyond the handful of large firms that currently dominate it, particularly the Big Four in the UK.
It also calls on the two governments to deepen cooperation through existing channels like the UK-China Economic and Financial Dialogue, arguing that closer alignment would cut duplicated effort and smooth cross-border trade and investment.
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