Climate Change Regulation 2025

Last Updated July 04, 2025

Taiwan

Law and Practice

Authors



Lee and Li Attorneys-at-Law was established 60 years ago and today, it is the largest law firm in Taiwan. It is a full-service firm with extensive experience in handling a wide range of legal matters, including corporate governance, labour and employment, M&A transactions, project development, project finance, and dispute resolution. Lee and Li supports businesses as they seek to achieve net zero and strengthen their resilience by incorporating sustainability into their daily business. With its robust experience, the firm has built up the capabilities to provide advice on comprehensive sustainability management and implementation, as well as compliance.

Although Taiwan is not a party to any multilateral climate change agreements due to its international status, it remains one of the most committed participants in the global effort to combat climate change. For example, Taiwan has actively joined the global efforts and pledged to achieve net-zero emissions by 2050.

The Taiwanese government has long collaborated with non-government organisations to showcase Taiwan’s achievements in mitigation and its future goals in combating carbon emissions. In recent years, both the government and several private sector corporations have successfully organised events and participated in sessions at international climate conferences. For example, the Taiwanese government hosted a total of 37 high-level bilateral or expert talks with like-minded countries and international organisations at COP29 in November 2024. The parties discussed a variety of topics that encompassed carbon diplomacy, climate policy, carbon pricing, energy transition, and climate rule of law, signalling once again the government’s commitment to joining forces with the global community to address climate change issues.

Aside from attending international climate change conferences, Taiwan’s international climate initiatives are primarily advanced through bilateral dialogues and collaborations. For example, the Taiwanese government has provided technical support and capacity-building assistance to its diplomatic allies in Central America and Africa, focusing on disaster prevention, climate-resilient crops, and smart agriculture. Beyond government efforts, non-government actors play a vibrant and influential role in climate action. This includes active participation from the private sector, academia, and civil society groups.

While there is not yet a formal regional climate change legal regime in East Asia, the Taiwanese government has participated in several discussions with regional organisations such as Asia-Pacific Economic Cooperation (APEC) with regard to initiatives related to climate change. For example, the deputy minister of the Ministry of Economic Affairs contributed to the 2024 APEC Energy Ministerial Meeting to share Taiwan’s case on just energy transition and deepen regional dialogue on hydrogen energy, which was later endorsed by the members.

Climate Policy Framework

On 30 March 2022, the Taiwanese government announced the 2050 Net Zero Pathway, where the government pledged to reach net-zero emissions by 2050 by focusing on four main objectives for transition – energy, industry, lifestyle and social – as well as two foundations in governance, namely technology R&D and climate legislation.

Later that year, the government released the Phased Goals and Actions Toward Net-Zero Transition (“Action Plan 1.0”), which included the National Long-Term Roadmap for GHG Reduction and 12 key strategies so as to implement the 2050 Net Zero Pathway. The 12 key strategies encompass innovative energy, carbon sinks, green finance and just transition, among others, each of which is accompanied by its respective goals, benefits and strategic measures. In addition, under the roadmap, the goal of the government was to reduce greenhouse gas (GHG) emissions to 10% below the level of year 2005 (reference year) in 2025, with a new target announced by the government every five years. The 12 key strategies were later re-optimised to six Major Sector Carbon Reduction Flagship Projects under the follow-up action plan, Taiwan’s Comprehensive Carbon Reduction Action Plan (“Action Plan 2.0”), announced on 23 January 2025.

Under Action Plan 2.0, the 12 key strategies will be adopted by the six major sectors – the energy, manufacturing, transportation, residential and commercial, agricultural, and environment sectors — with six key innovative mechanisms, which are technological innovation, financial support, carbon pricing, regulatory adjustment, green collar talent, and community driven, to systematically integrate carbon reduction efforts across sectors, while ensuring comprehensive financial planning and support. The end goal is to achieve the four major transitions envisaged in Action Plan 1.0, which are reaching towards a more diversified energy transition, innovative industrial transition, a lower-carbon lifestyle transition, and a more resilient social transition.

As part of the 2050 Net Zero Pathway, the Greenhouse Gas Reduction and Management Act (GGRMA), the key legislation governing the reduction of GHGs in Taiwan, went through a major overhaul in 2022 and has now been renamed the Climate Change Response Act (CCRA), which took effect on 15 February 2023. The CCRA expands on the regulatory boundaries of the GGRMA, and codifies the commitment of the 2050 net zero goal.

In accordance with the CCRA, the Science and Technology Council (STC) and the Ministry of Environment are under a mandate to jointly publish a national scientific report on climate change periodically, focusing on climate change science, impacts (trends and future projections), and adaptation.

Since 2009, the Taiwan Climate Change Projection Information and Adaptation Knowledge Platform (TCCIP), led by the STC and the National Science and Technology Center for Disaster Reduction, alongside a team of scientific experts, has been conducting long-term climate change research. In its latest phase, the TCCIP aims to enhance cross-level and cross-sector adaptation efforts through climate-related studies, supporting Taiwan’s Sustainable Development Goals (SDGs). Additionally, the platform is committed to proactively addressing the climate emergency and strengthening Taiwan’s systemic resilience.

The above provides the policy, scientific and legal foundation for Taiwan’s climate regime, serving as the basis for the development of more detailed area- and sector-specific policies, climate science research, and legal instruments.

Nationally Determined Contribution

Although Taiwan is not obliged under the Paris Agreement to submit a nationally determined contribution (NDC), the Taiwanese government voluntarily did so following the adoption of the United Nations Framework Convention on Climate Change (UNFCCC) Decision 1/CP.20 (“Lima Call for Climate Action”) in 2014. Taiwan subsequently released its intended nationally determined contribution (INDC) in December 2015.

Taiwan’s initial nationally determined contribution was thus based on its 2015 INDC, which set a target to reduce net emissions by 20% against the reference year (2005) by 2030 (NDC 1.0). Under the mandate of the GGRMA, the Ministry of Environment updated the NDC in 2022, aiming to enhance the reduction target to 24% plus/minus 1% by 2030 (NDC 2.0), to be implemented through Action Plan 1.0.

Further, under the mandate of the CCRA, the Ministry of Environment proposed a draft enhanced target of 28% plus/minus 2% by 2030 (NDC 3.0) in December 2024, which the government will strive to achieve through Action Plan 2.0. In its release, the government pointed out that the reason behind the target being plus/minus 2% in NDC 3.0, instead of the plus/minus 1% mentioned in the NDC 2.0, is due to the possible changes in climate issues in response to new international political and economic situations, bottlenecks and breakthroughs in the latest global climate technologies, as well as domestic electricity demand for AI, signalling that each release was carefully calculated.

Moreover, the president announced a draft of the “National New Carbon Reduction Target” at the National Climate Change Countermeasures Committee for the first time, proposing the GHG emission reduction goal for 2032 and 2035 of 32% plus/minus 2% and 38% plus/minus 2% against the reference year (2005), respectively.

Environmental rights are not a fundamental right enumerated under Taiwan’s Constitution. The closest mention of environmental right can be seen under paragraph 2, Article 10 of the Amendment Articles of the Constitution, which stipulates that environmental and ecological protection will be given equal consideration with economic and technological development. Although not formally recognised by the court, this constitutional mandate echoes the object and purpose clause of the CCRA and may serve as a foundational principle underpinning Taiwan’s climate change legislation.

On 1 July 2015, the GGRMA was enacted in response to the Paris Agreement. It was later renamed the CCRA on 15 February 2023. The CCRA’s key features include:

  • the codification of the net zero emissions goal by 2050 into law;
  • an enhanced GHG accounting and verification system;
  • a new chapter on climate adaptation, emphasising climate risk assessment; and
  • the introduction of a carbon fee.

The CCRA now serves as the primary regulatory framework for climate legislation in Taiwan. Following its enactment, additional agency-level regulations have been gradually promulgated. Over the next one to two years, the most-anticipated regulations are (i) a cap-and-trade mechanism; and (ii) the establishment of a carbon border adjustment mechanism to complement the carbon fee regime.

As Taiwan is not a contracting party to the Paris Agreement, it has not actively participated in the implementation of the market and non-market mechanisms under Article 6 of the Paris Agreement. Nevertheless, Taiwan has developed its own domestic carbon market system (for further discussion, see 5.1 Carbon Markets). Whether Taiwan’s domestic carbon market aligns with the standards established for the Paris Agreement’s Article 6.4 mechanism remains to be seen.

National Development Council

The National Development Council under the Executive Yuan played a pivotal role in constructing the 2050 Net Zero Pathway, and the accompanying Action Plan 1.0 and 2.0. In addition, it was the initial planner of the national adaptation plan.

National Council for Sustainable Development

According to Article 10 of the CCRA, the National Council for Sustainable Development is mandated to co-ordinate, assign, or integrate basic policies for national climate change response and major important strategies for cross-sectoral climate change response affairs. The council is currently led by the premier of the Executive Yuan, who commences an annual meeting to discuss the overall progress in the implementation of the action plans proposed by the National Development Council.

Ministry of Environment

The Ministry of Environment, formerly known as the Environmental Protection Administration, is the central-level administrative agency in charge of promulgating regulations under the CCRA, proposing NDCs, and devising national policies in response to climate change.

Ministry of Economic Affairs

The Ministry of Economic Affairs is the central-level administrative agency primarily responsible for promoting energy transition to support a green industrial transformation.

Financial Supervisory Commission

On the financial front, the Financial Supervisory Commission has prioritised green finance as a key strategy to achieve net zero emissions, implementing several policies to support sustainable finance development. Notably, the Green Finance Action Plan 3.0, launched in September 2022, promotes collaboration among financial institutions through the Financial Industry Net Zero Working Group to facilitate idea exchange and provide guidance. Building on this, the latest Green and Transition Finance Action Plan, released on 29 October 2024, continues to encourage co-operation between financial institutions and enterprises, while introducing funding to support corporate net zero transformation and urging greater disclosure of nature-related financial information.

Similar to the global trend, climate change-related litigation has gradually become a new strand of case law in Taiwan. These lawsuits fall under the subset of framework litigation, challenging the Taiwanese government’s overarching climate policies, insufficient ambition, and inadequate implementation of its climate commitments. Leading environmental NGOs in Taiwan involved in such litigation include Greenpeace, the Environmental Jurists Association, and the Environmental Rights Foundation, which often collaborate with private individuals.

A constitutional lawsuit brought by a group of plaintiffs is currently pending before Taiwan’s Constitutional Court, challenging the government’s failure to establish short-term and mid-term GHG emission reduction targets and the NDC determination process as unconstitutional. This case has been regarded as Taiwan’s equivalent of the Neubauer case in Germany.

Another case relevant to Taiwan’s NDC was brought by a group of youth climate activists in the Taipei High Administrative Court, arguing that the government’s failure to actively address climate change will impose an undue burden on future generations, and is therefore a violation of intergenerational equity enshrined in the Constitution.

Among the cases, only one has completed the full legal process to date. Greenpeace East Asia and others v Ministry of Economic Affairs, dubbed as the first climate litigation in Taiwan, focused on the major electricity users (MEU) rule established under the Renewable Energy Development Act and its implementing regulations. The MEU rule, promulgated by the Ministry of Economic Affairs in 2021, mandates that corporations meeting a certain electricity consumption threshold are required to increase their use of renewable energy. The plaintiffs challenged the MEU threshold, set at a contract capacity of 5,000 kW, arguing that it was too high and consequently exempted a large number of high electricity users, undermining Taiwan’s GHG emissions targets. The court dismissed the case on the grounds that the plaintiffs lacked standing to sue – that is, under Taiwan administrative law, they did not have the legal right to compel administrative agencies to issue or amend regulations.

Key regulatory mechanisms regarding mitigation are as follows:

National GHG Emission Reduction Targets

According to Article 10 of the CCRA, Taiwan’s central government is required to convene a consulting group comprising representatives from central and local government authorities, scholars, experts and NGOs to discuss the five-year phase-in national regulatory targets (ie, Taiwan’s interim GHG emission reduction goals) through a public hearing process. This consultation must be completed at least two years before the start of the next phase, and the approved results must be made publicly available following endorsement by the Executive Yuan.

Each phase-in national regulatory target should include:

  • the overall phase-in national regulatory target;
  • sector-specific targets for energy, manufacturing, business and residential sectors, transportation, agriculture, and the environment; and
  • targets for the electricity carbon emission factor.

GHG Emissions Accounting and Verification Requirements

Under the authority of Article 21 of the CCRA, the Ministry of Environment has promulgated the Regulations Governing the Accounting, Registration, and Verification of Greenhouse Gas Emissions. According to these regulations, businesses operating in specified sectors are required to account for, report and, where applicable, verify their GHG emissions annually within designated timelines. The Ministry of Environment has established and periodically updated a list of industries subject to mandatory GHG accounting and reporting, reflecting the strengthening of national emissions reduction targets. In its latest announcement, the Ministry of Environment expanded this requirement to cover 20 industries/sectors, with reporting thresholds varying by industry/sector. Affected industries must disclose both Scope 1 and Scope 2 emissions, while disclosure of Scope 3 emissions is voluntary.

Carbon Fee

On 29 August 2024, the Ministry of Environment promulgated three key components of the carbon fee regime, which are collectively known as the “three arrows” of the carbon fee framework:

  • the Regulations Governing the Collection of Carbon Fees;
  • the Designated Greenhouse Gas Reduction Goals for Entities Subject to Carbon Fees; and
  • the Regulations for Administration of Self-Determined Reduction Plans.

The current fee rate is set at TWD300 per tCO₂e, with two preferential rates of TWD100 per tCO₂e and TWD50 per tCO₂e available.

Under these regulations, starting in May 2026, a carbon fee will apply to electricity and gas supply businesses, as well as manufacturing sectors emitting over 25,000 tons of Scope 1 and Scope 2 GHG annually. Businesses subject to the carbon fee may apply to the Ministry of Environment for a preferential rate by submitting a self-determined reduction plan that commits to achieving the designated GHG reduction targets.

Prior to the enactment of climate change legislation, the Executive Yuan established a national task force in 2010 to address the growing challenges of climate change adaptation. This task force developed the Climate Change Adaptation Policy Guidelines, which were approved in 2012, leading to the creation of the first National Climate Change Adaptation Action Plan (國家氣候變遷調適行動計畫) (2013–2017) in 2014.

After the GGRMA was enacted, the Ministry of Environment (then the Environment Protection Administration) was under a mandate to formulate the Guidelines for National Actions in response to Climate Change (國家因應氣候變遷行動綱領), including establishing the guiding principles of adaption policies. Under the framework of the Guidelines for National Actions in response to Climate Change, the National Development Council, along with other administrative agencies, promulgated the National Climate Change Adaptation Action Program (國家氣候變遷調適行動方案) (2018–2022) in 2019. Under the amended CCRA, the Ministry of Environment published the National Climate Change Response Adaptation Action Plan (國家氣候變遷調適行動計畫) (2023–2026) in 2023, outlining various strategies and assessment on pursuing the nation’s adaptation and resilience in the context of climate change.

According to Article 19 of the CCRA, the relevant administrative agencies should update their adaptation action programmes for matters within their charge every four years, and the Ministry of Environment should, in accordance with the Guidelines for National Actions in response to Climate Change, consolidate the adaptation action programmes and promulgate the national climate change response adaptation action plan to address capacity building and risk assessment in relation to adaptation under Article 17 of the CCRA.

To date, most provisions under the adaptation chapter of the CCRA primarily require the government to assess the impacts of climate change and strengthen capacity building for adaptation, without explicitly linking adaptation to NDCs or specific environmental permits and authorisations. However, adaptation is inherently connected to various aspects of natural resource management, and each relevant regulation may include requirements that align with the concept of climate change adaptation.

As noted in 2.3 Bilateral/Multilateral Co-Operation, since Taiwan is not a contracting party to the Paris Agreement, it has not actively participated in the implementation of the market and non-market mechanisms under Article 6 of the Paris Agreement. Nonetheless, Taiwan has established its own domestic carbon market system through the GGRMA and, more recently, the CCRA.

Overall, the CCRA embraces a parallel carbon market framework by adopting, on the one hand, a voluntary emission reduction (VER) programme and, on the other hand, a cap-and-trade scheme. However, the timeline of implementation of the latter will be subsequent to the former.

VER Programme

Under the CCRA, both public and private sectors may submit voluntary reduction projects to implement GHG emission-reduction measures and apply to the Ministry of Environment for approval to obtain emission-reduction credits for their partially or totally reduced GHG emissions. These credits must be used in accordance with the requirements and timeframes established by the ministry. To further advance the VER programme, the Ministry of Environment amended the Regulations Governing Greenhouse Gas Voluntary Emission Reduction Projects on 12 October 2023. Credits obtained under the approved VER programmes may now be used to offset emissions from newly installed facilities, emissions subject to carbon fees, emissions subject to carbon border adjustments, and excess emissions under the cap-and-trade scheme.

To streamline credit trading in Taiwan, the Ministry of Environment promulgated the Regulations Governing the Trading, Auction, and Transfer of GHG Emission Reduction Credits on 1 July 2024. Under said regulations, two types of transactions are established via the Taiwan Carbon Solution Exchange (TCX): negotiated transactions, which are conducted without the trading platform’s matching function, and fixed-price transactions, which are carried out through placing and ordering processes.

Cap-and-Trade Scheme

The CCRA is establishing a cap-and-trade scheme for GHG emissions, allowing for the allocation, auctioning and trading of emission allowances. As of September 2025, this scheme has not yet been implemented, and therefore businesses have not been allocated any GHG emission allowances.

Voluntary Carbon Market

Although not specifically regulated under the CCRA, both public and private sectors in Taiwan participate in voluntary carbon markets by trading carbon credits through bilateral agreements or via the domestic carbon exchange, Taiwan Carbon Solution Exchange (TCX), which was established by the Taiwanese government in August 2023.

Taiwan Carbon Solution Exchange

TCX currently has two platforms, one for domestic carbon credits (ie, those issued through the programmes under the GGRMA and/or the CCRA) and the other for international carbon credits (ie, those issued by international carbon verification and accreditation bodies). For more information regarding the TCX and its associated platforms, see this link.

Based on an earlier analysis from the Administration of Small and Medium Enterprise, Ministry of Economic Affairs in December 2023, the EU’s Carbon Border Adjustment Mechanism (CBAM) will hit the steel and aluminium industries in Taiwan the hardest, both of which are targeted on the initial list of the CBAM. The Taiwanese government estimated that the most impacted industry, namely the steel industry, is likely to pay fees of approximately TWD1.19 billion to TWD9.11 billion each year, accounting for approximately 2.4% to 20% of the industry’s trade volume. Although it concluded that the overall proportion would not be high, it was still a considerable burden for the relevant companies.

Subject to the development of the CBAM reform under the EU Omnibus Package and forthcoming negotiations with the EU, the Taiwanese government anticipates that the implementation of the carbon fee may be recognised as deductible under the EU’s CBAM, thereby mitigating its impact on the affected industries. 

Task Force on Climate-Related Financial Disclosures (TCFD)

In 2020, the Taiwan Stock Exchange (TWSE) and Taipei Exchange (TPEx), under instruction from the Financial Supervisory Commission, started to require companies listed on their platforms to disclose climate-related information in their company sustainability reports in accordance with TWSE and TPEx rules (see 6.4 ESG Reporting and Climate Change), which mirror the reporting framework of the Task Force on Climate-Related Financial Disclosures (TCFD).

In addition to the TCFD, the sustainability reporting requirements of the TWSE and TPEx for listed companies also incorporate standards and guidelines established by the Global Reporting Initiative (GRI) and the Sustainability Accounting Standards Board (SASB).

Listed companies and financial institutions are also required to disclose the same climate-related information in their annual reports in accordance with the Securities and Exchange Act and its ancillary regulations.

Companies are also required to disclose the same climate-related information in their prospectuses when offering or issuing securities.

International Financial Reporting Standards (IFRS)

On 17 August 2023, the Financial Supervisory Commission announced that, starting from 2026, listed companies that reach a certain threshold in paid-in capital will be required to prepare annual reports that fully align with both International Financial Reporting Standards (IFRS) S1 and S2. The Financial Supervisory Commission proposed to apply the requirements in three phases starting in 2026 (for listed companies with a paid-in capital of TWD10 billion or more), 2027 (for listed companies with a paid-in capital of at least TWD5 billion, but less than TWD10 billion), and 2028 (all listed companies).

In Taiwan, the law does not explicitly address directors’ personal liability concerning the impacts of climate change either on or of their companies. However, since companies are permitted to incorporate social and environmental objectives into their articles of incorporation, directors who fail to uphold these commitments may be held liable for breaching their fiduciary duties. Furthermore, shareholders have the right to initiate lawsuits against directors, either on behalf of the company or individually (derivative suits), subject to procedural requirements and the specific nature of the allegations. However, in reality, the personal liability of directors for climate change impacts is a relatively new concept and remains untested in Taiwan.

Taiwan’s civil society has long been attentive to infrastructural investments that may affect the environment or contribute to climate change. Recently, referendums were held regarding the approval of third and fourth LNG terminals in the region, which could potentially impact the coastal ecosystem. Additionally, any development meeting the criteria outlined in Article 5 of the Environmental Impact Assessment Act should undergo an EIA. In recent years, several lawsuits have been filed by NGOs and local residents challenging the adequacy of EIAs for certain infrastructure projects, arguing that they failed to properly consider climate change impacts, both in terms of mitigation and adaptation. An overhaul of the EIA legal framework is expected to address this pressing issue.

In recent years, NGOs in Taiwan have advocated for fossil fuel divestment by financial institutions; however, this movement has yet to gain significant momentum. Meanwhile, financing arrangements that may negatively impact climate change continue to be overseen by the Financial Supervisory Commission through a soft-law approach.

Theoretically speaking, it is possible that shareholders or a parent company may be liable for climate change damage, if they abuse the corporate structure to evade liabilities under the doctrine of “piercing the corporate veil” under the Taiwan Company Act.

There has not been any known case where the shareholders or a parent company have been held liable for climate change damage. This remains, as yet, an untested issue in Taiwan.

In Taiwan, currently only companies listed on the TWSE and TPEx are required to prepare sustainability reports under the TWSE Corporation Rules Governing the Preparation and Filing of Sustainability Reports by Listed Companies, and the TPEx Rules Governing the Preparation and Filing of Corporate Social Responsibility Reports by Listed Companies. See 6.1 Climate Financial Reporting for more details.

In Taiwan, there is no law or regulation that specifically requires that climate change due diligence be conducted on M&A, finance and property transactions in relation to climate change or sustainability. In practice, this is rarely conducted.

The development of renewable energy is central to Taiwan’s 2050 Net Zero Pathway. In 2016, the Taiwanese government adopted a new energy policy to initiate a nationwide energy transition aimed at phasing out coal and nuclear power, while increasing the use of natural gas as a bridging fuel alongside renewable energy. The Energy Transition White Paper (2020) outlines the detailed implementation of this policy, prioritising energy security and GHG emissions reduction.

The progress of Taiwan’s renewable energy policy is evident in the rapid expansion of offshore wind farms and solar projects, supported by the Renewable Energy Development Act. More recently, the government has tended to actively promote small hydropower generation and geothermal energy, both of which are among the 12 key strategies to achieve the 2050 net zero goal.

Meanwhile, a renewable energy certificate (“T-REC”) scheme has been implemented alongside the introduction of corporate power purchase agreements (CPPAs). As of September 2025, a total of 9,800,748 T-RECs have been issued, with 8,937,406 T-RECs traded through the T-REC Trading Platform. CPPAs and T-RECs have become key instruments for companies in Taiwan to meet their 100% renewable energy (RE100) targets and various supply chain commitments.

To promote “green” growth, the Ministry of Environment introduced the Implementation Plan for Strengthening Investment in Green Growth and Net Zero Industries, which was approved by the National Development Fund, a special government-established fund, on 29 November 2024. Under this plan, the National Development Fund will allocate TWD10 billion to establish the Green Growth Fund, aimed at boosting investment in net-zero, sustainable and emerging industries. The initiative seeks to attract private capital for joint investment, create more green jobs, and drive new momentum for Taiwan’s green growth. As of July 2025, the first group of 12 private investors, including investment companies, private equity funds and asset management firms, partnered with the National Development Fund to support this plan. The Ministry of Environment will next begin selecting suitable investment targets and matching these with the investors.

Lee and Li Attorneys-at-Law

8F, No 555, Section 4
Zhongxiao East Road
Taipei 110055
Taiwan
ROC

+886-2-2763-8000

+886-2-2766-5566

attorneys@leeandli.com www.leeandli.com/EN
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Authors



Lee and Li Attorneys-at-Law was established 60 years ago and today, it is the largest law firm in Taiwan. It is a full-service firm with extensive experience in handling a wide range of legal matters, including corporate governance, labour and employment, M&A transactions, project development, project finance, and dispute resolution. Lee and Li supports businesses as they seek to achieve net zero and strengthen their resilience by incorporating sustainability into their daily business. With its robust experience, the firm has built up the capabilities to provide advice on comprehensive sustainability management and implementation, as well as compliance.

Emissions Accounting and Verification

The Climate Change Response Act (CCRA) mandates that businesses designated by the Ministry of Environment report their greenhouse gas (GHG) emissions annually by submitting relevant data to the ministry’s registry. For designated industries, the data must also be verified by a certified verification institute. The Ministry of Environment publishes the list of in-scope businesses in the Businesses Subject to Accounting and Registration of Greenhouse Gas Emission Sources (the “Emission Sources List”).

For entities on the Emission Sources List, mandatory disclosure covers Scope 1 and Scope 2 emissions, while reporting of Scope 3 emissions is encouraged but not compulsory. The list includes, among others: (i) all businesses in Taiwan with Scope 1 GHG emissions of 25,000 tonnes or more per year; and (ii) all manufacturing businesses in Taiwan whose combined Scope 1 and Scope 2 emissions reach 25,000 tonnes annually. In March 2025, the ministry amended the Emission Sources List to expand coverage to additional sectors, including IT services, retail businesses, hotels and hospitals that meet the respective thresholds. However, these newly added industries are not required to have their GHG accounting results verified.

Accepted measurement methodologies under the Regulations for Management of Inventory and Registration of Greenhouse Gas (the “Management Regulations”) include the emission factors method, mass balance method, direct measurement, and other methods approved by the Ministry of Environment. Regulated businesses must submit their GHG emissions accounting reports by 30 April each year, with verification (if applicable) due by 31 October.

On 29 August 2025, the Ministry of Environment announced a draft amendment to the Management Regulations, proposing more detailed requirements regarding accounting methods and the content of accounting reports.

Carbon Fee

The primary regulatory mechanism for achieving the 2050 net zero target, as well as the phased GHG emission reduction targets under the CCRA, is the carbon fee. According to Article 28 of the CCRA, the Ministry of Environment is authorised to impose a carbon fee on Scope 1 and Scope 2 emissions from GHG emission sources in a phased manner. Under Article 29 of the CCRA, GHG emission sources subject to the carbon fee that effectively reduce emissions and meet targets set by the ministry – through measures such as switching to low-carbon fuels, implementing negative-emission technologies, improving energy efficiency, utilising renewable energy, or optimising processes – may submit a self-determined reduction plan to the Ministry of Environment to apply for a preferential fee rate.

To implement the carbon fee, on 29 August 2024, (i) the Regulations Governing the Collection of Carbon Fees; (ii) the Designated Greenhouse Gas Reduction Goals for Entities Subject to Carbon Fees; and (iii) the Regulations for Administration of Self-Determined Reduction Plans were promulgated by the Ministry of Environment and came into effect.

Currently, electricity companies, gas suppliers, and manufacturing businesses emitting over 25,000 tonnes of Scope 1 and Scope 2 emissions annually will be subject to a carbon fee. Starting in May 2026, these businesses will be required to pay the carbon fee based on their emissions from the previous year.

The carbon fee is calculated based on the following formula:

carbon fee = emission volume × applicable rate.

The emission volume is calculated as follows:

emission volume = (annual emission volume – K) × emission adjustment co-efficient, where:

  • K = 25,000 tonnes (except for businesses with a high-carbon leakage risk, where K = 0); and
  • the emission adjustment co-efficient = 1 by default.

However, for businesses with a high-carbon leakage risk that have an approved self-determined reduction plan from the Ministry of Environment, the co-efficient is reduced to 0.2 in Phase 1, 0.4 in Phase 2, and 0.6 in Phase 3. The scope of businesses with a high-carbon leakage risk has not yet been finalised by the Ministry of Environment.

The current applicable carbon fee rate is TWD300 (approximately USD9.34) per tCO₂e. Additionally, two other preferential rates and their respective qualification criteria are summarised as follows:

  • Rate A: TWD50 (approximately USD1.56) per tCO₂e applies to emission sources that submit a self-determined reduction plan and achieve the industry-specific reduction targets set by the Ministry of Environment, which are aligned with internationally recognised science-based goals. Currently, the reduction targets for 2030 relative to 2021 are 25.2% for the steel industry, 22.3% for the cement industry, and 42% for other industries.
  • Rate B: TWD100 (approximately USD3.11) per tCO₂e applies to emission sources that submit a self-determined reduction plan and achieve the technology benchmark’s designated reduction rate.

Overall, the carbon fee regulations do not mandate that regulated businesses set climate targets. However, they encourage these businesses to voluntarily develop GHG emission reduction plans and establish GHG reduction targets for 2030, following the self-determined reduction plan guidelines issued by the Ministry of Environment. By doing so, businesses may qualify for a preferential carbon fee rate as a reward for meeting their GHG reduction goals.

The carbon levies collected from these business entities will be deposited into the Greenhouse Gas Management Fund. This fund will be dedicated to providing incentives for investments in GHG reduction technologies, enhancing climate change adaptation efforts, and supporting a just transition, among other initiatives, in accordance with Article 33 of the CCRA.

Disclosure of Sustainability-Related Information

In Taiwan, only listed companies are currently required to disclose sustainability-related information in their sustainability reports and annual reports. These reports follow a hybrid reporting framework that integrates the standards of the Global Reporting Initiative (GRI), the Sustainability Accounting Standards Board (SASB), and the Task Force on Climate-Related Financial Disclosures (TCFD). Aligning with international trends, the Financial Supervisory Commission released a roadmap in August 2023 to guide listed companies in adopting the International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards.

Based on the roadmap, listed companies that reach a certain threshold in paid-in capital will be required to fully align with both IFRS S1 and S2. Specifically, listed companies with a paid-in capital of TWD10 billion or more will be obliged to report under IFRS S1 and S2 starting in 2026, while listed companies with a paid-in capital of at least TWD5 billion but less than TWD10 billion, and other listed companies, will be obliged to do so in 2027 and 2028 respectively. The Financial Supervisory Commission has further announced that it will fully adopt the IFRS S1 and S2 without any changes to the standards.

Against this backdrop, Taiwan’s listed companies’ sustainability-related information will finally align with, and be comparable to, that of the international community, as IFRS S1 and S2 are the product of years of consolidation between different reporting frameworks.

In May 2025, the Financial Supervisory Commission announced an advance notice with regard to the draft amendments to the Regulations Governing Information to be Published in Annual Reports of Public Companies, the major legislation governing the submission of annual reports. In this announcement, the Financial Supervisory Commission will require listed companies to also prepare sustainability-related financial information in accordance with the IFRS S1 and S2.

Lee and Li Attorneys-at-Law

8F, No 555, Section 4
Zhongxiao East Road
Taipei 110055
Taiwan
ROC

+886-2-2763-8000

+886-2-2766-5566

attorneys@leeandli.com www.leeandli.com/EN
Author Business Card

Law and Practice

Authors



Lee and Li Attorneys-at-Law was established 60 years ago and today, it is the largest law firm in Taiwan. It is a full-service firm with extensive experience in handling a wide range of legal matters, including corporate governance, labour and employment, M&A transactions, project development, project finance, and dispute resolution. Lee and Li supports businesses as they seek to achieve net zero and strengthen their resilience by incorporating sustainability into their daily business. With its robust experience, the firm has built up the capabilities to provide advice on comprehensive sustainability management and implementation, as well as compliance.

Trends and Developments

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Lee and Li Attorneys-at-Law was established 60 years ago and today, it is the largest law firm in Taiwan. It is a full-service firm with extensive experience in handling a wide range of legal matters, including corporate governance, labour and employment, M&A transactions, project development, project finance, and dispute resolution. Lee and Li supports businesses as they seek to achieve net zero and strengthen their resilience by incorporating sustainability into their daily business. With its robust experience, the firm has built up the capabilities to provide advice on comprehensive sustainability management and implementation, as well as compliance.

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