ESG 정보공시 제도의 수렴과 분화 - 국가 간 비교와 중국의 법제적 개선 경로 -

Under the “Dual Carbon” Strategy and the Global Transition to Sustainable Governance, ESG (Environmental, Social, and Governance) disclosure is rapidly evolving from a voluntary corporate practice into a legally mandated obligation. This shift positions ESG disclosure as a critical institutional instrument for fostering green capital markets and enhancing corporate transparency. This article conducts a systematic comparative analysis of the ESG disclosure legal frameworks in major economies—specifically the European Union, the United States, the United Kingdom, Japan, and South Korea—examining their formative contexts, normative structures, and enforcement mechanisms to distill the core characteristics of distinct regulatory models. The research reveals a prevailing trend among leading international jurisdictions: the establishment of disclosure systems characterized by legal primacy, standardized requirements, coordinated oversight, and mandatory third-party assurance. In contrast, China currently occupies a critical transitional phase, shifting from policy-driven guidance towards rule-of-law governance. Its existing framework exhibits significant deficiencies, including an insufficient legal foundation, fragmented standards, and disparate disclosure quality. To address these challenges, the article proposes a four-dimensional optimization strategy encompassing: Legislative Framework Development, Standard Consolidation, Mandatory External Assurance, and Technological Enablement. These recommendations aim to propel China towards constructing a systematic, standardized, rigorously enforceable, and internationally aligned ESG disclosure legal architecture, thereby serving the dual objectives of advancing green finance development and modernizing corporate sustainable governance.