The Corporate & Commercial Law Society Blog, HNLU

Tag: ESG

  • ESG Labels, Real Impact: Accountability and Incentives in India’s ESG Debt Securities Market

    ESG Labels, Real Impact: Accountability and Incentives in India’s ESG Debt Securities Market

    BY ANSHIKA SAH AND ABHAVYA SHARAN, FOURTH – YEAR STUDENTS AT RMLNLU, LUCKNOW

    INTRODUCTION

    Using the term “sustainability” merely as a marketing label, without any supporting regulations or uniform standards, results in purpose-washing and, consequently, loss of credibility in sustainable finance and corporate practices. In recent times, there has been a rapid increase in the ESG finance landscape across the globe, with the market projected to reach approximately $7.02 trillion in 2025. However, a litany of high-profile purpose-washing cases has made this market vulnerable to increased scrutiny over credibility and enforcement.

    India’s exploration into this      arena has gained momentum with the release of a dedicated Framework for Environment, Social and Governance (‘ESG’) Debt Securities (other than green debt securities) by the Securities and Exchange Board of India (‘SEBI’). This article examines the proposed framework and discusses      the strategic incentives involved for Indian corporates in integrating ESG considerations in their core business strategies. By analyzing the challenges involved in the implementation of the same, the article concludes with a few policy recommendations to address these challenges for a more comprehensive and better-suited framework.

    OVERVIEW OF THE FRAMEWORK 

    While India has had an environmental bond program since 2015, the newer instruments lacked the consistent regulation they required. SEBI in June 2025 introduced a comprehensive framework (‘the framework’)     , redefining ESG Debt Securities to include social bonds, sustainability bonds, and Sustainability-linked bonds or (‘SLBs’), as the demand for sustainable finance grew. In social bonds, funds are used for projects addressing social issues, such as affordable housing and job creation     , whereas in sustainability bonds, funds are raised for a combination of green and social projects. SLBs, on the other hand, are tied to the issuer achieving certain pre-set sustainability goals. These bonds guide private investment towards achieving the United Nations’ Sustainable Development Goals (‘SDGs’). They also provide investors with a practical means to combine financial gains with environmental and social benefits. The significance and momentum of these instruments are highlighted by the      expanding global ESG bond market, while India’s own issuance of over USD 13.07 billion on IFSC exchanges by the end of September. Globally accepted and recognised standards, like the Climate Bonds Standard, ASEAN standards, EU Green Bond Standard, and International Capital Market Association (‘ICMA’) Principles, must be followed by these ESG Debt securities to protect against the risks of ‘purpose-washing’ and guarantee comparability.

    ENFORCEMENT AND ACCOUNTABILITY MECHANISMS  

    Disclosure, reporting, and third-party review are significant prerequisites. Transparency needs to be maintained by the issuers, and quantifiable proof of impact has to be provided under the new framework. Significant information, such as how the proceeds are going to be utilised, target population, project selection, and whether the bond will finance new or ongoing projects, needs to be disclosed. For SLBs, issuers must specify the key performance indicators (‘KPIs’) and sustainability performance targets (‘SPTs’). There has to be constant reporting subsequent to the issue of securities of the fund allocation progress, and its impact on the environment and society.

    An independent third-party review is a mandatory requirement in order to ensure that, after the issue, the bonds are accurately classified into the four categories which are ‘green bonds’, ‘social bonds’, ‘sustainability bonds’ and ‘sustainability-linked bonds’ and to confirm that disclosures and results align with the commitments made. For this, the issuer must have a review by an independent third-party with relevant expertise, such as SEBI-registered ESG ratings providers. In order to combat non-compliance, SEBI has also included safeguards like early redemption clauses and penalties. Such provisions enable investors to redeem their securities if a try-out is attempted to purpose-wash or if the commitments entered into are not met.

    Purpose-washing is defined as making false, misleading, unsubstantiated, or otherwise incomplete claims about a bond’s purpose, often by misrepresenting how the money will be used. SEBI’s rules are explicitly designed to combat this by mandating that social or sustainability bonds must fund only the projects and objectives disclosed at the time of issue, and any deviation must be disclosed immediately.      SLBs carry a heightened risk of purpose-washing as compared to green or sustainability bonds, owing to their structure of performance-based incentives, as issuers may set low or easily attainable KPIs simply to label instruments as sustainability-linked, without delivering meaningful impact. SEBI’s earlier February 2023 Green Bond Guidelines mandated ‘dos and don’ts’ to combat greenwashing by prohibiting misleading labels, data cherry-picking, and unverified environmental assertions. However, one of the most glaring issues is the implicit exclusion of SLBs from the applicability of measures to mitigate purpose-washing, given the international standard of penalizing non-compliance.

    INCENTIVE FOR ESG INTEGRATION

    The new framework by SEBI      incentivizes Indian companies to integrate ESG considerations into their core strategies. With the global ESG asset pool sizing up to more than $35 trillion, the framework positions India to tap into this pool, to attract global capital and long-term finance. This is evident from Larson & Toubro’s debut ESG bond, which demonstrated huge investor demand and received a AAA CRISIL rating, and was priced at a lower interest rate      of 6.35%, compared to 6.45–6.50% for similar non-ESG instruments in the secondary market, indicating clear financial advantages for compliant issuers.

    Further, SEBI’s requirement of standard ESG disclosure through the Business Responsibility and Sustainability Reporting (‘BRSR’) core and the proposed India-specific ESG parameters improve the scope of sectoral comparison while aligning ESG reporting with domestic priorities. A higher ESG rating encourages businesses to improve corporate governance and performance because it signals increased market credibility and a lower cost of capital. Leading examples are Infosys and L&T, which have incorporated ESG principles in their core business strategies to gain a competitive edge by leveraging innovation and sustainability.

    Furthermore, businesses can use their credible ESG governance and disclosure practices to gain access to global markets and secure preferred vendor status with multinational buyers, particularly in export-driven industries like automobiles, electronics, textiles, etc. Moreover, Developmental Financial Institutions (‘DFIs’) like NABARD and SIDBI also provide facilities like concessional finance and targeted incentive schemes for companies that demonstrate ESG performance and compliance with SEBI’s framework.

    COUNTER ARGUMENTS AND CHALLENGES IN THE INDIAN MARKET

    Despite the benefits, as the ESG finance market expands, it presents significant challenges for issuers. One primary challenge is that there is no universally accepted definition for ‘Social’ or ‘Sustainable’, leading to a lack of clarity in application and also inhibiting standardization. Issuers run the risk of being falsely accused of purpose-washing in the absence of any uniform standards. Huge compliance costs for third-party verification and detailed disclosure requirements are compounded by this, which may discourage small and first-time issuers from participating because they often lack the infrastructure and budget to meet these requirements. Additionally, the ESG-rating market is highly fragmented and opaque, which makes it difficult for investors to evaluate and contrast the issuances across sectors. Investor confidence is further undermined by a lack of standard evaluation tools and unclear information on impact metrics.

    Although some critics have expressed concerns that the introduction of rigid taxonomies and standard KPIs may hinder innovation, and possibly put small and regional issuers at a disadvantage. Though valid, these concerns do not negate the broader need for uniformity in general. The same could be addressed through a phased implementation of the framework, starting with voluntary compliance and then gradually moving towards mandatory requirements. Similarly, inference can be drawn from the EU’s experience with the Green Taxonomy, which demonstrated that proportionality and standardization can go hand-in-hand.

    PROPOSED REFORMS TO STRENGTHEN THE FRAMEWORK

    However, this is only the beginning, and there is scope to counter these obstacles and to turn them into an opportunity to strengthen the ESG Finance landscape in India by learning from global best practices and tailoring them to suit India’s development needs. SEBI should move beyond international standards and introduce an India-specific ESG taxonomy tailored to national priorities and SDG commitments. This could draw inspiration from the EU Green Taxonomy but be adapted for India’s socio-economic development. For this, SEBI should promote the use of sector-specific templates and model KPIs to enable comparison without compromising local relevance. Though the disclosure burden is high and compliance requirements are complex, it must be noted that these are essential to eliminate the misuse of ESG labelling or purpose washing and ensure genuine impact is made. Leveraging public infrastructure and targeted support from DFIs like NABARD, SIDBI, etc., should be sought to alleviate this burden. Moreover, coalitions of the private sector, like the Confederation of Indian Industries (CII) and the Federation of Indian Chambers of Commerce and Industry (FICCI), can assist in ESG-related capacity building and provide technical and financial support.

    A central ESG oversight body under SEBI should be created to monitor disclosure, enforce accountability, ensure market discipline, and serve as an institutional safeguard for all the different stakeholders. Penalties for non-compliance should be clearly articulated to deter purpose-washing. Credit rating agencies must be mandated to follow a uniform ESG-scoring criterion. Additionally, integrating the ESG Bond market with blockchain technology and the smart contract system can enhance transparency and automate compliance by tracking the use of proceeds in real-time.

    CONCLUSION

    The framework is a timely step in aligning the Indian financial market with the UN SDGs and introduces baseline standards, opening a pathway for credible ESG capital mobilization. While it is built on good intent, this will all be meaningful when it is backed by strong enforcement and accountability mechanisms that go beyond mere disclosure formalities. The current framework leaves several gaps that require further attention. For India to become a global hub for sustainable financing, its ESG regulatory infrastructure must be built on pillars of credible enforcement, integrity, real impact, and alignment with sustainable principles.

  • India’s Social Stock Exchange: How Compliance Strains Impact NPOs and Social Impact Assessors?

    India’s Social Stock Exchange: How Compliance Strains Impact NPOs and Social Impact Assessors?

    BY DHARSHAN GOVINTH R AND SIDDHARTH VERMA, FOURTH- YEAR AT GNLU, GANDHINAGAR

    INTRODUCTION

    India’s Social Stock Exchange (‘SSE’) is a trend-setting initiative introduced by the Securities and Exchange Board of India (‘SEBI’) in 2022, which by aiming to align capital markets and philanthropic purposes intended to give a fund-raising ground for non-profit organizations (‘NPO’) and other social entities. But this initiative is displaying some strains especially after the SEBI circular issued in late September 2025 which made some modifications in SSE’s compliance framework bringing forth the credibility-capacity paradox, which would be examined in this research work.

    This article explores this paradox of credibility and capacity, by first outlining the recent modification brought out by SEBI. Secondly it is followed by a thorough analysis of the modified compliance architecture is done to assess as to what makes this framework problematic. Thirdly, an analysis of SSEs in different countries is done to highlight upon potential modifications which can be done in India.  Finally, it gives some ideas of reform to balance the rigor and inclusivity in the present framework.

    THE MODIFIED FRAMEWORK AND ITS FAULTLINES

      The circular of SEBI has established a compliance framework, where the modifications as follows are of significance. The circular mandates 31st October of each year as the deadline to submit a duly verified Annual Impact Report (‘AIR’) by all fundraising non-profits. It also mandates those non-profits which have been registered on SSE but haven’t listed their securities to submit a self-reported AIR covering 67% of the program expenditure. Then, there is a mandate that all the above AIRs need to be assessed by Social Impact Assessors (‘SIA’).

      Although initially these modifications may show that there is a sense of strengthened transparency, three problems emerge upon implementation. Firstly, the dual-track approach—which creates unequal degrees of credibility by having separate compliance requirements for two types of NPOs. Secondly, there is a problem of supply-demand as the limited supply of SIAs (approximately 1,000 nationwide) is insufficient to meet demand as hundreds of NPOs enter the SSE. Finally, smaller NGOs with tighter finances are disproportionately affected by compliance expenses, such as audit fees and data gathering. These concerns need to be analyzed further inorder to determine whether the SSE can provide both accountability and inclusivity.

      HOW THE PRESENT COMPLIANCE ARCHITECTURE LEADS TO CREDIBILITY-CAPACITY PARADOX?

        The present modification of the compliance framework by SEBI has in its core, the aim to grow the trust of the investors by means of mandating independent verifications. Nevertheless, this framework exhibits inconsistencies which need to be undone. The first gap that is visible is the problem of credibility. This modification proposes a dual-track SEBI’s modification institutes a dual-track compliance: NPOs that raise funds must file an auditor-verified AIR, whereas SSE-registered entities that have not listed securities (mostly smaller NPOs) may submit a self-verified AIR. This distinction creates a clear credibility gap where investors and donors will reasonably rely on audited AIRs, effectively privileging well-resourced organisations and marginalising smaller, self-reporting grassroots NPOs that lack access to auditors or the capacity to procure independent verification. Another issue is the mandatory coverage of 67% of the program expense in the AIR by the non-listed NPOs , which on one hand may lead to extensive coverage of the financials of those NPOs, but on the other hand pose a heavy operational burden on these NPOs which manages diverse programmes.  The expenses of fulfilling this duty may be unaffordable for NPOs without baseline data or technological resources.

        Moving from the issue of credibility, the challenge of capacity—stemming from the scarcity of SIAs—presents a more significant concern. The industry faces a supply-demand mismatch as there are only around 1,000 qualified assessors across India in self-regulatory organizations (‘SRO’) like ICAI, ICSI, ICMAI, etc., who are selected through qualification examinations conducted by National Institute of Securities Market. The problem is that compliance becomes contingent not on the diligence of NPOs but on the availability of auditors.

        Financial strain completes the triad of challenges. Impact audits are resource-intensive, requiring field verification, outcome measurement, and translation of qualitative change into quantifiable indicators. These tasks incur substantial fees, particularly in rural or remote contexts. Unlike corporations conducting corporate social responsibility activities (‘CSR’), which under Section 135 of Companies Act 2013 caps impact assessment costs at 2% of project outlay or ₹50 lakh, SSE-listed NPOs do not enjoy any such relief. The absence of stronger fiscal offsets weakens the fundraising advantage of SSE listing, making the cost-benefit calculus unfavorable for many small organizations.

        These dynamics create what may be described as a credibility–capacity paradox. The SSE rightly seeks to establish credibility through rigour, but the costs of compliance risk exclude the very grassroots non-profit organizations it was designed to support. Larger, urban, and professionalized NPOs may adapt, but smaller entities operating at the community level may find participation infeasible. Nevertheless, it would be reductive to see the SSE’s framework as wholly burdensome. Its emphasis on independent audits is a landmark reform that aligns India with global best practices in social finance. The challenge is to recalibrate the balance so that transparency does not come at the expense of inclusivity.

        LEARNING FROM GLOBAL SSES: AVOIDING EXCLUSIONS, BUILDING INCLUSION

          India’s SSE is not the first of its kind. Looking at examples of abroad helps us see what works and what doesn’t. For instance, Brazil’s SSE, established in 2003 raised funds for about 188 projects but mostly attracted larger NPOs, leaving smaller groups behind. In the same way, the SSE of UK, established in 2013 favored professional entities as it operated more as a directory than a true exchange, raising €400 million. Both examples show how heavy compliance rules can narrow participation leaving small NPOs and eventually these SSEs failed to be in the operation in due time.

          The SSEs of Canada and Singapore, both established in 2013 also set strict listing criteria but unlike the above, paired them with direct NPO support, including capacity-building and fundraising assistance, especially for small scale NPOs. This made compliance more manageable. India can learn that it can prevent these exclusions of certain non-profits and create an SSE that is both legitimate and inclusive by combining strict audit regulations with phased requirements and financial support.

          BRIDGING GAPS THROUGH REFORM: MAKING INDIA’S SSE MORE EQUITABLE

          A multi-pronged reform agenda can address these tensions. Firstly, SEBI could ease compliance costs for small NGOs by creating a centralized digital platform with standardized reporting templates and promoting shared auditor networks to spread expenses. Further, in order to breakdown entry barriers to smaller NPOs, a phased-tier system of compliance could be implemented to the requirements for audits in the initial years. This phased tier system can be achieved for instance by first mandating 40-50% of coverage of expenditures in the audit in the initial years and then gradually rising the threshold to the 67% requirement as per the recent modification to ease compliance.

          Secondly, the creation of a SSE Capacity Fund, which could be funded by CSR allocations would be a viable step for reducing the burden of compliance and to preserve the resources of NPOs which are already limited. These subsidies and grants through these funds could maintain both financial stability and accountability of NPOs.

          Third, SROs have to develop professional capacities in a short time, which could be done by the increase in accelerated certification programmes among people who have pertinent experience. In addition, in order to protect credibility, the SROs must require the auditors to undergo rotation and then make sure that the advisory and auditory functions are never combined. Lastly, expenditure on digital infrastructure will help diminish compliance costs greatly. This could be done for instance by establishing a common platform of data collection and impact reporting which might allow small NPOs to be prepared to comply effectively. These systems could assist in bridging the gap between the professional audit requirements and the small capacity of smaller NPOs.

          CONCLUSION

          India’s SSE has undoubtedly increased the credibility of the social sector by instituting mandatory audits and transparent reporting for listed social enterprises, thereby strengthening the confidence of investors and donors. This is a significant achievement in formalizing social finance. However, this audit-driven transparency also illustrates a “credibility–capacity paradox”: rigorous accountability measures, while necessary, impose high compliance burdens on smaller grassroots nonprofits with limited resources. If there is no support or mitigation mechanisms, the SSE may inadvertently narrow the field of participants and undermine its inclusive mission. In contrast, international peers show more balanced regulatory models, thereby showing a way forward for India as well. For instance, Canada’s SSE combines stringent vetting with tailored capacity-building programs, and Singapore’s SSE employs a social-impact framework and supportive ecosystem to enforce accountability while nurturing small social enterprises. Ultimately, a mature SSE should balance oversight with inclusivity and support. If India implements this balance, which it lacks, its SSE could be an equitable, inclusive, digitally integrated and resource-efficient platform in the coming decade. Such an SSE would leverage digital reporting to cut costs and uphold rigorous transparency standards, while genuinely empowering grassroots impact.

        1. Sustainable Finance: Deconstructing SEBI’s Framework for ESG Debt Securities

          Sustainable Finance: Deconstructing SEBI’s Framework for ESG Debt Securities

          VIDUSHI AND AADARSH GAUTAM, FIFTH -YEAR STUDENTS AT NLUD, NEW DELHI

          INTRODUCTION

          On June 5, 2025, the Securities and Exchange Board of India (‘SEBI’), in its Circular titled “Framework for Environment, Social and Governance (ESG) Debt Securities (other than green debt securities)” (‘Circular’) has come out with an operational framework Circular for issuance of social bonds, sustainability bonds and sustainability-linked bonds, which together will be known as Environment, Social and Governance (“ESG”) debt securities. Before this amendment and the introduction of the ESG Framework, SEBI had formally recognised only green bonds. While the regulatory landscape in India was initially focused solely on green bonds, market practices had already begun embracing broader ESG categories. This Circular is significant as it will help issuers to raise money for more sustainable projects, assisting in closing the funding gap for the Sustainable Development Goals.

          The Circular is part of a larger regulatory trajectory that began with SEBI’s consultation paper released on August 16, 2024. The consultation paper had proposed to expand the scope of the sustainable finance framework in the Indian securities market, recognising the growing global demand for capital mobilization to achieve the 2030 Sustainable Development Goals (“SDGs”). It had set the stage for subsequent amendments to the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021 through the SEBI (Issue and Listing of Non-Convertible Securities) (Third Amendment) Regulations, 2024, which formally introduced the definition of ESG Debt Securities under Regulation 2(1)(oa). This blog analyses how the Circular operationalises these regulatory intentions to create a structured ecosystem for the issuance and listing of a broader class of ESG debt instruments in India.

          UNDERSTANDING ESG DEBT SECURITIES

          ESG Debt Securities in their definition include green debt securities (“GDS”), social bonds, sustainability bonds, and sustainability-linked bonds. While GDS have already been defined under Regulation 2(1)(q) of NCS Regulations, with effect from date of release, SEBI’s new Circular governs the issuance and definition of ESG Debt Securities, excluding GDS. The definition is deliberately wide to encompass advancements in international standards encompassing the International Capital Market Association (ICMA) Principles, the Climate Bonds Standard, and the ASEAN Standards among others. This permit the incorporation of additional categories of ESG Debt Securities as designated internationally and by SEBI periodically. Thus, if any activity qualifies internationally to ESG Standards, it will be able to secure the tag in India, too. These international standards are also relevant for issuers for adherence to initial and continuous disclosures for issuance of ESG Debt Securities as will be discussed later in this blog.

          This Circular provides the definition of social bonds as a way for firms to gain finances for initiatives that positively benefit society. For example, governments may involve projects aimed at improving water supply, supplying necessities like medical care and education, ensuring food security, and improving fundamental infrastructure. Similarly, sustainability bonds are defined as made for the purpose of financing green and social projects. They acknowledge the convergence of environmental and social goals. For instance, in 2020, Alphabet Inc., Google’s parent organisation, made the prominent move of offering a USD 5.75 billion bond in support of sustainability. Part of these bonds went to finance green buildings and electric transport, demonstrating how sustainability bonds can be multipurpose.

          Besides, under this framework, sustainability-linked bonds (“SLBs”) are very different from bonds tied to the use of funds. They do not depend on a single project but are based on the issuer’s continuous ESG achievements. The issuers make forward-looking commitments to enhance their sustainability by using Key Performance Indicators (“KPIs”) and comparing their outcomes with their agreed-upon Sustainability Performance Targets (“SPTs”). Even though the proceeds from these bonds are flexible, the issuance process is only credible if the issuer is able to accomplish the set goals.

          As ESG bonds are distinct in their manner of use of investment obtained, separate obligations and requirements are laid down by the Circular for these bonds as will be explored next.

          THE PROPOSED REGULATORY FRAMEWORK

          At the outset, an issuer desirous of issuing these social bonds, sustainable bonds or SLBs have to comply with initial disclosure requirements, continuous disclosure obligations and appoint independent third-party certifiers as per the Circular. The issuance of social and sustainable bonds requires adherence to requirements as per Annexure A and for SLBs as per Annexure B. The primary aim behind the requirements remains transparency and investor protection. For instance, as per Annexure A, the initial disclosure regarding how the project benefits the public put an end to the raising of money for projects without adequate information and instil trust in investors. Significantly, the Circular provides for the qualification of a third-party reviewer by mandating independence, expertise and lack of any conflict of interest. It is to be highlighted that while the presence of third-party reviewers remains essential and a step forward in right direction, the regulations governing ESG credit rating agencies are still evolving to enhance clarity and transparency and are at a comparatively nascent stage. The ability of reviewers to provide accurate and tailored reviews rather than template ones remains untested and the Circular does not provide guidelines that could ensure it.

          In addition to the above requirements, as per Annexure B, SLBs need to comply to certain unique requirements due to the forward-looking, performance-oriented characteristics of these instruments. During the issuance phase, issuers must furnish exhaustive information on chosen KPIs, encompassing definitions, calculation benchmarks, while elucidating the justification for picking such KPIs. Similar to the framework for social and sustainable bonds, an independent third-party need to be appointed to verify the credibility of the selected KPIs and SPTs. If there is any change in the method by which the company sets or measures KPIs or SPTs, this information has to be examined and notified. This strict structure guarantees that SLBs are both ambitious and transparent, providing investors with a reliable means to evaluate issuers’ ESG performance over the course of time.

          ACTION MEETS AMBITION: ELIMINATING PURPOSE-WASHING

          One of the significant change brought by the framework is to ensure that the instruments are “true to their labels”. The issuer is not allowed to use any misleading labels, hide any negative effects or choose to only highlight positive outcomes without informing negative aspects. Herein, to prevent purpose washing, that is misleadingly portraying of funds as impact investments, the regulator mandates that the funds and their utilisation to meet the agreed ESG objectives are continuously monitored. Any misuse of the allocated funds has to be immediately reported and the debenture holders’ have the right to early redemption.

          The mandatory nature of impact reporting by the issuer ensures to provide clear and transparent assessments of the outcomes of their ESG labelled initiatives. Such report shall include both qualitative (explaining narratives, approaches, case studies and contexts of social impact) and quantitative indicators (specific metrics and measurable data, such as carbon emissions reduced, of the social impact) and should be supplemented by third party verification. As a result, SEBI ensures to create a culture of responsibility that extends beyond initial issuance and to the complete lifecycle of the management. These mechanisms ensures a comprehensive framework of safeguards aimed at protecting investors and maintaining the integrity of India’s sustainable finance ecosystem.

          THE WAY FORWARD

          SEBI’s ESG Debt Securities Framework is a relevant and progressive regulatory advancement that broadens India’s sustainable finance repertoire beyond green bonds to encompass social, sustainability, and sustainability-linked bonds. The Circular enhances market integrity and connects India’s ESG debt landscape with global best practices by incorporating stringent disclosure standards, and protections against purpose-washing. The industry has welcomed Larsen & Toubro’s announcement of a Rs 500 crore ESG Bond issue, marking it as the first Indian corporation to undertake such an initiative under the newly established SEBI ESG and sustainability-linked bond framework. With the need to strengthen certain aspects including third-party reviews, as implementation progresses, strong enforcement, market awareness, and alignment with international standards will be essential to realising the framework’s full potential.