The Financial Services Agency's slides for its 28 August 2026 climate-data panel lay out when large Prime Market companies are planned to start reporting under SSBJ sustainability standards. Mandatory application is to be set by government ordinance, starting with the largest companies by market capitalisation.
| Market capitalisation | Mandatory application begins |
|---|---|
| ¥3tn or more | Year to March 2027 |
| ¥1tn to under ¥3tn | Year to March 2028 |
| ¥500bn to under ¥1tn | Year to March 2029 |
Market capitalisation is to be calculated as the average across five fiscal year-ends, under a planned Cabinet Office ordinance. Companies below ¥500bn are not yet scheduled; the slides say their treatment will be considered later. Third-party assurance becomes mandatory from the year after each group's disclosure start, with scope limited for the first two years. A planned transitional rule would let companies add SSBJ items in a correction report, filed by the half-year report deadline, for the first two years.
What the survey found
A separate FSA presentation, by an official of the climate-related risk monitoring office speaking in a personal capacity, summarised a report published in July 2026 that drew on a survey of 17 institutions among large banks, regional banks, life insurers and non-life insurers. Institutions generally treat storm and flood risk as a significant management risk, but report that past events had limited effect on lending. Cases of internal-rating downgrades from storm or flood damage were few.
The gaps are in the models. Some institutions model flood but not wind. Others do not adequately capture customers' main sites outside headquarters, supply-chain spillovers or compound disasters.
Data gaps at the roundtable
The panel's summary of discussions says flood analysis is relatively advanced, while data on landslides, windstorms, snow damage and drought is insufficient. Participants said limited information on customers' sites, logistics and supply chains constrains quantitative assessment, and that differing methods make results hard to compare. In project finance, they said, insurance premiums are rising and assets that have suffered a loss often get reduced cover. They urged institutions to use existing information rather than wait for perfect datasets.