In September, domestic green and low-carbon policies entered a phase of intensive implementation as the 15th Five-Year Plan period began, with industrial planning and carbon market system development advancing in parallel.
Plans for building a financial powerhouse, promoting small and medium-sized enterprise development, the information and communications industry, intelligent connected new energy vehicles, and the electronic information manufacturing industry were successively issued, with carbon emission intensity, energy efficiency, and carbon footprint constraints fully incorporated into industrial indicators.
On the carbon market front, the national carbon market allowance allocation plan was officially implemented, the first publication of allowance balance values for expanded industries took place, and measurement review and data quality rectification were simultaneously strengthened.
Overseas, EU disclosure rules accelerated simplification, US climate policy continued to retreat, and Germany clarified its fossil fuel phase-out timetable.
On the market side, the number of domestic ESG fund launches hit a new high for the year, while ESG bond issuance scale remained elevated.
Domestic 15th Five-Year Plan green plans were intensively issued, and the carbon market institutional system underwent comprehensive upgrading. September's domestic policies focused on advancing both industrial green transformation and carbon market quality improvement: plans for building a financial powerhouse, promoting small and medium-sized enterprise development, the information and communications industry, intelligent connected new energy vehicles, and the electronic information manufacturing industry were successively released, with carbon emission intensity, energy efficiency, and carbon footprint management requirements systematically incorporated into industrial development indicators. On the carbon market front, the 2025 and 2026 annual allowance totals and allocation plans for the national carbon market were officially implemented, carbon emission measurement reviews and technical service institution data quality rectification were simultaneously strengthened, and the carbon market data quality infrastructure continued to improve.
Overseas sustainable disclosure rules accelerated simplification, but industrial carbon constraints continued to strengthen. The revised ESRS was officially published by the EU, with mandatory data points cut by approximately 61%; SFDR revisions, CBAM expansion, and public procurement regulation reforms advanced successively, presenting a combination of "subtraction in disclosure, addition in industrial carbon constraints." The US Environmental Protection Agency finalized the repeal of power plant greenhouse gas emission rules, and the SEC proposed repealing shareholder proposal rule 14a-8, with federal-level climate regulation continuing to contract. Meanwhile, Germany released a fossil fuel phase-out roadmap, and Germany, Austria, and Luxembourg jointly funded power-to-sustainable aviation fuel, with the global long-term decarbonization direction unchanged.
Domestic ESG fund launches hit a new high for the year, while ESG bond issuance scale remained elevated. In September 2026, 31 new ESG funds were launched domestically, setting a new monthly high for the year, with ChiNext computing infrastructure ETFs becoming the main force in issuance. On the bond issuance side, 125 ESG bonds were issued in September with a scale of 191.6 billion yuan, with issuance activity also remaining at a high level for the year.
Zero-Carbon Parks, Financial Flows — Funding Needs, Financial Instruments, and Investment Opportunities for Zero-Carbon Parks
Parks are the core scenario for China's industrial decarbonization, and zero-carbon parks have entered the implementation phase. Parks serve as dual core scenarios for economic growth and carbon management. After going through stages of green industrial park creation, circular economy transformation, and carbon peak pilot projects focused on individual quality improvements, the 2024 Central Economic Work Conference proposed "establishing a batch of zero-carbon parks," and Document No. 910 issued by the National Development and Reform Commission established a standardized construction framework centered on carbon emissions per unit of energy consumption. In December 2025, the first batch of 52 national-level zero-carbon parks was announced, covering 31 provinces (autonomous regions and municipalities) and the Xinjiang Production and Construction Corps, with an estimated output value of 3.54 trillion yuan upon completion, of which 24 parks have already commenced major engineering construction, with local supporting plans and financial support policies following suit.
Zero-carbon park construction centers on green electricity and energy conservation, corresponding to hundred-billion-level zero-carbon investment. National-level acceptance uses carbon emissions per unit of energy consumption as the core constraint, with a 7-10 times reduction space compared to the current national park average of approximately 2.1 tons, accompanied by guiding indicators such as a clean energy consumption share of no less than 90%. Construction and renovation revolve around two main lines: green electricity systems and low-carbon transformation of production and auxiliary systems. The 22 national-level parks that have published investment figures involve over 700 billion yuan in industrial plus low-carbon investment. Using the Cangdong zero-carbon park's approximately 4.921 billion yuan in zero-carbon investment as an order-of-magnitude reference, the 52 parks on the national-level zero-carbon park list correspond to hundred-billion-level zero-carbon construction investment.
Multi-layered sustainable financial instruments comprehensively adapt to park construction and operation phase needs. Among debt instruments, green credit's corresponding carbon reduction support tool rate was reduced to 1.25%, with a 2026 operation quota of 800 billion yuan, providing the main funding support; ESG bonds provide medium- and long-term direct financing for park platforms. Among non-debt instruments, central budgetary investment supports zero-carbon park projects at 20% of approved total investment, green leasing assets cover park equipment investment, and normalized REITs issuance provides exit channels for new energy power stations and park properties. Domestic practice cases have verified the positive cycle of "green electricity-industry-finance" in zero-carbon parks.
Accounting First, Anchoring Net Zero — Ten Questions and Answers on Multi-Asset Portfolio Carbon Accounting
Investment carbon emission disclosure is gradually becoming a global standard, and portfolio carbon accounting is moving from optional to mandatory. On international standards, TCFD and IFRS S2 have successively required banks and asset owners to disclose financed emissions; domestically, the People's Bank of China's "Guidelines for Carbon Accounting by Financial Institutions (Trial)" provides a local institutional basis, and Shenzhen and other locations have piloted mandatory disclosure by business type. Meanwhile, A-shares have formed a significant "carbon risk premium," and quantifying carbon exposure is a prerequisite for climate stress testing and active position adjustment. From a capital flow perspective, long-term capital providers have incorporated net-zero capability into manager selection processes, with global public climate-themed fund scale reaching 710 billion US dollars, and portfolio carbon accounting is becoming a core competitiveness for asset management institutions.
Unified standards and tiered data management are the methodological keys to implementing multi-asset carbon accounting. In portfolio carbon accounting practice, one can refer to standards such as PCAF's "Financial Industry Standard," following principles of unified emission scope, unified accounting units, unified attribution methodology, and unified reporting periods. In data acquisition, following a strategy of prioritizing disclosed values, supplementing with estimated values, and tiered quality management, third-party data services can be relied upon to fill data gaps. All asset classes share the unified logic of "attribution factor × investee emissions," but different asset classes require correspondingly different approaches. All methods allocate emissions based on the "first principle" of economic share, and accounting results across asset classes can be directly aggregated to form a complete carbon account at the portfolio level.
Overseas institutional practice is already mature, and domestic portfolio carbon accounting is expected to accelerate its adoption. Driven by capital providers such as NBIM and GPIF, overseas asset management institutions' carbon accounting practices have become increasingly mature. Fidelity International, as a first-tier asset management institution in carbon accounting, has built a comprehensive carbon accounting system, with carbon intensity targets also exceeded. Domestic leading practices are concentrated in the insurance asset management sector, with China Pacific Insurance being the first to publish carbon emissions from stock and bond investment portfolios, and spreading to public funds and bank wealth management. On disclosure and target setting, it is recommended to adopt a progressive target structure of "baseline year + five-year milestones + net-zero year," forming a management closed loop linking accounting, disclosure, and emission reduction.
Economic development falling short of expectations: macroeconomic development falling short of expectations could cause corporate profits to suffer, leading to cuts in ESG investment, while consumers also focus more on prices and ignore ESG value, which is not conducive to ESG market development. ESG-related policy implementation falling short of expectations: delays in ESG-related standard system construction, lack of norms for corporate ESG practices, and downward expectations for green financial product growth could reduce investor confidence and may cause unfair market competition and moral hazard. Market sentiment and preference fluctuation risk: market sentiment and investor preferences are changeable, and ESG investment may easily lose attention in the short term due to market shifts, facing risks such as capital withdrawal and development constraints.