South Korea Finalizes Mandatory ESG Disclosure Roadmap — KRW10 Trillion Threshold from 2028, Safe Harbor for Three Years

South Korea's Financial Services Commission published the final roadmap for mandatory sustainability disclosure on July 8. The requirement applies first to KOSPI-listed companies with KRW10 trillion or more in consolidated assets from 2028 (based on FY2027), expands to KRW5 trillion or more from 2029, and may expand further to KRW2 trillion from 2030. ESG disclosures will be filed as legal disclosures in corporate business reports under the Financial Investment Services and Capital Markets Act — bypassing any exchange-stage process — with reports due by end of March, aligned with financial statements. The three-year safe harbor is commercially significant: civil, administrative, and criminal liability for sustainability disclosures is broadly suspended for the first three years of each company's mandatory disclosure, except for intentional greenwashing. Scope 3 emissions disclosure is deferred by three years for each category. For law firms advising Korean-listed clients or multinationals with Korean subsidiaries, the 2028 first-wave threshold and March reporting deadline are the immediate calendar entries; the safe harbor design should inform how clients approach voluntary disclosure in 2026–2027 in advance of their mandatory entry date.