Taiwan’s ESG regulatory landscape has undergone a transformation in recent years. The launch of the Corporate Governance 3.0 – Sustainable Development Roadmap in 2020 by the Financial Supervisory Commission (FSC) has been followed by the Sustainable Development Roadmap and the Sustainable Development Action Plans for Taiwan Stock Exchange (TWSE) and Taipei Exchange (TPEx) Listed Companies. Altogether, these initiatives have progressively expanded ESG disclosure requirements in line with international sustainability standards.
Yet one question has lingered beneath the surface: has Taiwan’s ESG framework moved beyond pure disclosure and become a genuine tool for identifying, preventing, and remedying harm to people and the environment?
Recent developments suggest that Taiwan is moving on the right track. The announcement of the Roadmap for Taiwan listed companies to align with IFRS Sustainability Disclosure Standards, which has begun to take effect this year, signals a move away from box-ticking disclosure and towards a sharper focus on whether reported ESG information reflects real changes in corporate conduct. Furthermore, the “S” in ESG has gained increasing prominence. With Taiwan’s importance in global supply chains, labour rights and, in particular, the protection of migrant workers have moved to the public spotlight in the past year.
This article first examines whether Taiwan’s ESG disclosure regime is moving beyond formal reporting towards greater corporate accountability. It then considers the growing prominence of labour and human rights issues, focusing on human rights due diligence (HRDD), migrant workers’ recruitment fees, and the prevention of forced labour. Finally, it asks whether Taiwan’s emerging vision of a more responsible ESG framework is becoming reality or remains one that appears real only from a distance.
Enhanced ESG disclosure regime
Taiwan’s ESG framework has gradually moved beyond disclosure alone towards a greater focus on substance and real-world impact. From 2026, TWSE- and TPEx-listed companies that meet certain paid-in capital thresholds will be required to include a dedicated sustainability section in their annual reports, pursuant to the Regulations Governing Information to be Published in Annual Reports of Public Companies. According to the FSC’s announcement, the requirement will be phased in as follows:
2026 – for listed companies with a paid-in capital of TWD 10 billion or more;
2027 – for listed companies with a paid-in capital of at least TWD 5 billion but no more than TWD 10 billion; and
2028 – for all other listed companies.
This new section, to be titled “Sustainability-related Financial Information”, must be prepared in accordance with IFRS S1 and S2 and submitted for board review and approval. As this information will now form part of the annual report, it will be brought within the realm of the Securities and Exchange Act regime. This means that misstatements or misleading disclosures may, in appropriate circumstances, give rise to potential securities fraud exposure where the relevant legal elements are met.
At the same time, regulators have also sought to reduce duplication. In May 2026, the TWSE amended the Taiwan Stock Exchange (TWSE) Corporation Rules Governing the Preparation and Filing of Sustainability Reports by Listed Companies to exempt companies that have already disclosed sustainability information in their annual reports from repeating equivalent disclosures under the Sustainability Accounting Standards Board and Task Force on Climate-related Financial Disclosures frameworks. The TPEx has adopted similar amendments to its rules governing corporate social responsibility reports.
Meanwhile, the Ministry of Environment has announced plans to introduce anti-greenwashing guidelines for businesses that make use of sustainability awards and labels. These guidelines are expected to take effect by the end of 2026 and will govern the use of such claims in advertising, reports, and product sales. They will be guided by three core principles: truthfulness, proportionality, and clarity. Once in force, they are likely to mark a shift towards a stricter greenwashing prevention regime, aimed at protecting consumers and investors from misleading sustainability claims.
All in all, these developments point to the direction of Taiwan’s future ESG policy: reducing duplication, improving disclosure quality, and, above all, ensuring that sustainability reporting is not merely more abundant but more credible.
Human rights due diligence
The concept of HRDD is rooted in the broader international development of business and human rights. Under the United Nations Guiding Principles on Business and Human Rights (UNGPs), businesses have a responsibility to respect human rights and are expected to work together to ensure that this standard is effectively implemented. Businesses are expected to respect human rights by carrying out ongoing HRDD to identify, prevent, mitigate, and account for how they address actual and potential adverse human rights impacts.
The Taiwan government announced its first National Action Plan on Business and Human Rights (NAP) in 2020, making it one of the earliest jurisdictions in Asia to do so. Based on the announcement, NAP would be refreshed every four years, and it is now undergoing an update.
The first NAP (NAP 1.0) was issued on May 5 2022. It focused on eight priority areas:
Strengthening human rights protection;
Human rights education;
Equality and non-discrimination;
Enhancing protections of the right to life;
Housing justice;
Climate change and human rights;
Digital human rights; and
Refugee rights protection.
The plan also set out 154 actions, each accompanied by key performance indicators, together with three rounds of implementation reviews to help ensure oversight and follow-up.
According to the NAP Final Implementation Report, NAP 1.0 has led to some meaningful developments in Taiwan. Legal and policy reforms were introduced for vulnerable groups, including, among other measures, the enactment of the Stalking and Harassment Prevention Actand steps to strengthen the identity rights and health rights of Indigenous peoples. In addition, housing support was expanded through social housing construction and the NT$30 Billion Special Programme for Expanded Rent Subsidies for unmarried youth, newlyweds, and families with young children, as well as other economically and socially disadvantaged groups. Finally, climate legislation and climate justice were brought further into focus, including through the overhaul of climate-related laws and the introduction of the Climate Change Response Act.
In January 2025, the government tasked the Ministry of Economic Affairs (MOEA) to prepare the next stage of the NAP. By October 2025, the MOEA had announced plans to introduce the Programme for Enterprises to Respect Human Rights in Supply Chains (the HR Programme), which will incorporate the concept of HRDD.
To help develop the draft, the MOEA launched a series of outreach sessions in 2025 to brief the private sector on the government’s plans and gather feedback on the proposed HR Programme. It has also signalled that listed manufacturing companies with paid-in capital of TWD 50 billion or more may be required to carry out HRDD under the HR Programme and disclose the results in their sustainability reports the following year. Drawing on Taiwan’s ESG disclosure experience and the EU’s corporate sustainability due diligence legislation, the government is likely to take a phased approach:
2026 – for manufacturing sector companies with a paid-in capital of TWD 50 billion or more;
2029 – for manufacturing sector companies with a paid-in capital of TWD 30 billion or more; and
2030 – for manufacturing sector companies with a paid-in capital of TWD 15 billion or more.
The HR Programme is structured as an ongoing process rather than a one-off compliance exercise. It begins with the formulation of a company’s human rights policy, followed by the identification and assessment of actual and potential adverse human rights impacts. These impacts may arise in three ways:
The company may cause the harm directly through its own operations (self-cause);
It may contribute to the harm through its activities or through the actions of another entity, such as an intermediary or business partner (direct contribution); or
The harm may be directly linked to the company’s operations, products, or services through a transaction, investment, or other commercial relationship, even if the company did not cause or contribute to it directly (indirect contribution).
Once the risks have been identified, the company is expected to take appropriate action to address them, monitor the effectiveness of those measures, communicate and disclose how the issues have been handled, and establish internal grievance mechanisms to provide affected persons with a channel for complaint and remedy. In this sense, HRDD is intended to function as a practical tool for prevention, mitigation, and accountability, rather than merely a reporting requirement.
Although both the updated NAP and the HR Programme are still being finalised, the focus of ESG in Taiwan has shifted from whether and how businesses should respect and disclose human rights to the more practical question of how they might demonstrate that they have done so.
Migrant workers and recruitment fees
As supply chain management becomes an increasingly important part of ESG compliance, so does the protection of migrant workers’ human rights – particularly addressing recruitment fees.
Taiwan’s legal framework already contains safeguards against exploitation by recruitment agencies. Under the Employment Service Act, recruitment agencies are prohibited from, among other things, withholding migrant workers’ documents against their will, retaining their belongings, charging deposits for job placement services, or demanding fees beyond prescribed limits or other unfair benefits.
The Ministry of Labour (MOL) has also made clear that labour brokers may not charge migrant workers brokerage or referral fees in connection with contract completion, continued employment, or transfers. Where an employer or new employer engages employment service institutions, the applicable registration and placement fees must be borne by the employer. Migrant workers may, however, be charged service fees should they engage employment service institutions to seek job vacancies on their behalf. That said, under the Standards for Fee-charging Items and Amounts of the Private Employment Services Institution, such fees are subject to statutory caps, with the monthly maximum falling from TWD 1,800 in the first year to TWD 1,500 from the third year.
The foregoing regulations apply only to fees charged by recruitment agencies in Taiwan and do not cover fees charged by recruitment agencies in migrant workers’ countries of origin. In practice, Taiwan currently regulates fees charged by agencies in the countries of origin by requiring migrant workers to sign an “Affidavit on Expenses and Wages for Foreigners Entering Taiwan to Work” before departure. The affidavit expressly provides that the fees charged by agencies in the country of origin are subject to the regulations and verification procedures of the labour-exporting country. In other words, current Taiwanese law does not directly regulate fees charged by agencies in migrant workers’ countries of origin – including by setting a fee cap – and merely requires migrant workers to sign the affidavit before departure to acknowledge these arrangements.
Implementation challenges
Despite Taiwan’s existing safeguards, implementation challenges remain. Although domestic law regulates fees charged by recruitment agencies in Taiwan, it does not directly regulate fees charged in workers’ countries of origin. This creates a gap between domestic legal requirements and the expectations reflected in the employer pays principle. High overseas recruitment fees may leave workers in debt and expose companies to human rights and supply-chain compliance risks.
These risks may also extend beyond a company’s direct operations. Large manufacturers may have difficulty identifying and addressing labour, health and safety, or environmental issues among lower-tier suppliers. Effective HRDD therefore requires companies to assess risks across relevant business relationships and establish appropriate monitoring and follow-up processes.
Access to effective grievance mechanisms presents a further challenge. A complaint channel may exist on paper but remain inaccessible if it is not multilingual, trusted by workers, or perceived as safe to use. Workers who fear retaliation or lack confidence in internal procedures may instead turn to NGOs or social media after problems have escalated. Establishing safe, credible, and accessible grievance mechanisms thus requires more than adopting formal procedures; it may also call for changes in corporate culture.
These challenges underscore the need for practical guidance to help businesses identify and address forced-labour risks – an issue addressed, in part, by the MOL’s Guidelines for Enterprises on the Prevention of Forced Labour.
Guidelines for Enterprises to Prevent Forced Labour
The MOL issued the Guidelines for Enterprises on the Prevention of Forced Labour on February 13 2026. Drawing on the UNGPs, the International Labour Organization’s international labour standards, and other international principles, the guidelines set out “Eleven Indicators of Forced Labour” as a basis for internal risk warnings and assessment. These indicators include abuse of vulnerability, restriction of movement, and excessive overtime. “Debt bondage” often lies at the centre of systematic exploitation, and to reflect this, the guidelines present the 11 indicators as a series of “concentric circles”, highlighting the way in which forced labour can extend and intensify across different layers of abuse.
The MOL also provides frameworks to help businesses prevent forced labour and navigate legal compliance.
Conclusion: from reflection to responsibility
There are grounds for optimism: Taiwan has developed a far more sophisticated sustainability reporting framework than it had only a few years ago, and climate governance, human rights considerations, sustainability reporting, and international standards are becoming increasingly embedded in corporate practice. Its ESG framework is also beginning to move beyond disclosure towards human rights due diligence and greater corporate accountability. But rules and reporting alone cannot ensure that workers are protected in practice. Recruitment fees charged in workers’ countries of origin, the risk of debt bondage, and access to effective remedies remain important challenges.
Ultimately, progress will depend on whether businesses identify and address harm throughout their supply chains – not simply whether they publish the right information – and whether Taiwan’s steps in this direction are matched by effective implementation, oversight, and meaningful remedies for those affected.
