ESG Law and Corporate Sustainability Compliance in Asia: A Systematic Review of Regulatory Frameworks and Enforcement Gaps

During the period 2021-2026 ESG reporting shifted from guidance to law in the capital market in Asia. Now, listed companies in Malaysia, India, Singapore and Indonesia are mandated to disclose sustainability data, with three of them being based on the International Sustainability Standards Board (ISSB)'s IFRS S1 and S2. The rules that establish the duty to report, however, are not the rules that enforce the duty to report. In this paper, a PRISMA-guided systematic review of the legal and regulatory and empirical record of these jurisdictions for 2015-2026 is reported and compared with the European Union (EU) benchmark. The review reveals that convergence in Asia is pushed predominantly by the ISSB and not by the EU Corporate Sustainability Reporting Directive; that the focus of scholarship is on disclosures to be made, with a much less developed strand of scholarship on liability, assurance and enforcement; that the benchmark of convergence has moved faster than the literature on the 2025-2026 retrenchment including the EU Omnibus I Directive; and that the strand of scholarship that deals with the duties of directors in the context of climate risk is the least developed. It suggests that convergence be tested in the "enforceable content of the law" and not just in its "language.