Enhanced Sustainability Disclosure Requirements for Publicly Traded Companies
The Financial Market Council (CMF) has stepped up its requirements for sustainability information to be provided by companies that raise funds from the public. The regulator has drawn the attention of these companies to the fact that ESG (Environmental, Social, and Governance) factors, when likely to affect a company's activity, financial situation, performance, or prospects, constitute essential information that must be disclosed to investors. This requirement is also in line with the provisions of international standards IFRS S1 related to general requirements for sustainability-related financial information and IFRS S2 related to information to be provided on climate change.
Key Requirements
In this context, the CMF has invited publicly traded companies to include, in their individual and consolidated financial statements as of December 31, 2025, clear and relevant information on the main ESG factors to which they are exposed. This information must cover:
- Identified ESG risks and opportunities
- Their current or potential effects on the company's financial situation, performance, business continuity, and future prospects, whether resulting from their own activities or those of entities within their consolidation scope
Importance of Disclosure in the Context of the Carbon Border Adjustment Mechanism (CBAM)
These disclosure requirements are particularly important in the context of the entry into force of the CBAM on January 1, 2026. The CBAM is a mechanism introduced by the European Union to establish a carbon pricing system for imported products equivalent to that borne by producers established within the European Union. This mechanism may have implications for Tunisian companies exporting to the European Union, particularly in terms of costs, competitiveness, and market access.
Disclosure Requirements for Companies Affected by the CBAM
In this regard, the CMF calls on companies operating in sectors affected by the CBAM and directly or indirectly exporting to the European Union to provide information in the notes to their individual and consolidated financial statements as of December 31, 2025, that will enable investors to assess the consequences of this mechanism. This information must include:
- How specific risks related to the CBAM have been identified, assessed, and integrated into the company's or group's management
- Internal mechanisms put in place to ensure compliance with the requirements of the CBAM, particularly in terms of measuring, calculating, and reporting the carbon footprint of exported products
- An evaluation of the current and expected impacts of the CBAM on the company's or group's activity, financial situation, performance, competitiveness, export markets, and prospects
Strengthening Governance and ESG Reporting
The Financial Market Council has also invited all publicly traded companies to strengthen their ESG governance and reporting mechanisms and to work closely with their auditors to ensure the quality, reliability, and compliance of published information, in accordance with the provisions of the accounting conceptual framework and the aforementioned standards. This is another important step towards improving the quality of companies' financial publications, which will lead to better valuations by analysts.
