Thirty ESG Evaluation & Data Providers Back Japan FSA's ESG Code of Conduct

Key Takeaways

• Thirty Organizations Participating: Thirty ESG evaluation and data providers had endorsed the FSA's Code of Conduct as of June 30, 2026.
• Voluntary Framework: The code is based on a "comply or explain" model rather than mandatory legal requirements.
• Greater Transparency: Endorsing organizations are expected to publicly explain how they comply with the code's principles or why they depart from specific guidelines.

Deep Dive

Thirty ESG evaluation and data providers had endorsed Japan's Code of Conduct for ESG Evaluation and Data Providers as of June 30, 2026, according to an updated list published by the country's Financial Services Agency (FSA).

The figure is less a milestone than another measure of how the market for ESG ratings and data continues to organize itself. Investors, asset managers, companies, and regulators increasingly rely on ESG assessments to inform decisions, yet the firms producing those assessments operate with widely differing methodologies. Japan's code was created to bring greater transparency to that process without turning it into a prescriptive regulatory regime.

The code itself dates to Dec. 15, 2022, when the FSA published it following recommendations from the Technical Committee for ESG Evaluation and Data Providers. That committee, chaired by Tetsuo Kitagawa, Professor Emeritus at Aoyama Gakuin University and Specially Appointed Professor at Tokyo Metropolitan University, spent months examining the state of the ESG ratings and data market, the challenges facing both providers and users, and what standards might improve confidence in the industry. Its report was released on July 12, 2022, laying the groundwork for the framework that followed.

The FSA's latest update includes an appendix listing all organizations that have notified the regulator of their intention to endorse the code. A second worksheet identifies providers that have newly announced their endorsement or made other updates since the previous publication.

A Voluntary Standard

The code is deliberately not a regulation. Instead, it follows a "comply or explain" model. ESG evaluation and data providers that choose to endorse the framework publicly express their support and either comply with its principles and guidelines or explain why they do not follow a particular provision.

The FSA is asking for transparency rather than uniformity. Providers are expected not only to state whether they support the code but also to explain, in language readers can understand, how they apply each principle in practice or why a particular guideline does not fit their approach.

The regulator publishes the names of organizations that notify it of their endorsement, giving market participants a centralized view of which providers have committed to the framework.

How Providers Participate

Organizations seeking to endorse the code are asked to publish a statement of endorsement on their own websites and notify the FSA. They are also expected to disclose how they comply with each of the code's principles and guidelines.

When notifying the regulator, providers submit information including their names in Japanese and English, whether their endorsement applies to ESG evaluations, ESG data, or both, contact details, the web address of their public endorsement statement, and the location of their detailed compliance disclosures.

The FSA said ESG evaluation and data providers that have not yet endorsed the code remain invited to do so by notifying the agency's Sustainable Finance Office.

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