ESG reporting to the CNV (Argentina)

Argentina has no general law requiring companies to publish a sustainability report. The real requirement comes from the capital market, and it is set by the Comisión Nacional de Valores (CNV) for issuers under the public offering regime. It rests on four pieces that are worth keeping apart.

1. Sustainability information in the annual directors' report

General Resolution 1115/2026, published in the Official Gazette on 2 March 2026, reorganises the periodic disclosure regime in Title IV of the CNV Rules (2013 consolidated text). Among other changes to deadlines and content, it adds an express requirement: the issuer's directors must disclose in the annual report their environmental or sustainability policy and the issuer's main performance indicators in that area or, where they have no such policies or indicators, explain why they consider them not relevant to their business.

This is a comply or explain mechanism, not a mandate to report under a specific standard. The resolution imposes neither GRI nor the IFRS Sustainability Disclosure Standards nor any other framework. The regime differentiates by issuer type: issuers classified as CNV SMEs fall outside this requirement.

The practical effect matters even though the wording is flexible. From this resolution onwards, having no environmental policy is no longer invisible: you have to say so in writing, to the regulator and to investors.

2. The Corporate Governance Code

General Resolution 797/2019 approved the Corporate Governance Code that issuers must report as a separate annex to the annual report, also on a comply or explain basis. It covers board conduct, risk management, ethics and stakeholder relations: the G of ESG, in practice.

3. Social, green and sustainable bonds

To label an issuance as social, green or sustainable you must follow the CNV's Guidelines for the issuance of thematic securities. The regime began with General Resolution 788/2019 and was updated by General Resolution 963/2023, which broadened and refined it. The guidelines take as their reference the ICMA principles (Green Bond Principles, Social Bond Principles, Sustainability Bond Guidelines and Sustainability-Linked Bond Principles) and the Climate Bonds Initiative taxonomy and standard, and also cover gender, blue, orange and transition bonds.

What the issuer is expected to provide:

• A documented framework setting out environmental or social objectives, project eligibility criteria, and the evaluation and management of proceeds.
• An external review: second party opinion, verification, certification or third party rating.
• An annual report on allocation of proceeds and impact over the life of the security, with quantitative indicators and the methodology used.
• For sustainability-linked bonds, key performance indicators and verified sustainability performance targets, published at least once a year.

The CNV itself states in the prospectus that it passes no judgement on the thematic label: sustaining it is the issuer's responsibility. For the general concept, see our entry on green bonds.

On the investment product side, General Resolution 885/2021 established a regime for sustainable collective investment products.

4. How the report is prepared: Technical Resolution 60

FACPCE Technical Resolution 60, on standards applicable to the preparation of sustainability information, approved in late 2025, replaces Technical Resolution 36 on the Social Balance Sheet and recognises two acceptable frameworks: the GRI Standards and the IFRS Sustainability Disclosure Standards, that is IFRS S1 and IFRS S2 from the ISSB. It leaves out the European ESRS on the grounds that they are tailored to the EU regulatory context.

One point that prevents a lot of confusion: Technical Resolution 60 does not require anyone to prepare a sustainability report, nor does it determine which entities must produce one. It says how it is prepared if it is prepared. The obligation, where it exists, comes from the regulator or from a contract. Bear in mind too that FACPCE technical resolutions are adopted by each provincial professional council, so confirm the applicable effective date with the council in your jurisdiction.

The market's pull

Alongside the rules, BYMA runs a Sustainability Index, created in 2018 with technical support from the Inter-American Development Bank and assessment by LSEG, which selects a small group of issuers leading on environmental, social, corporate governance and sustainable development performance, rebalanced annually. It also operates a Corporate Governance Panel. These are not rules, but they move expectations.

Quick comparison

Frequently asked questions

Is sustainability reporting mandatory in Argentina?

Not as a general rule. Issuers under the public offering regime do have to disclose their environmental or sustainability policy and their main performance indicators in the annual report, or explain why they are not relevant, under CNV General Resolution 1115/2026. Outside the capital market, the pressure usually comes from customers, banks and investors.

Does the CNV require IFRS S1 and S2?

No. General Resolution 1115/2026 imposes no specific reporting standard. Companies that apply the IFRS Sustainability Disclosure Standards do so voluntarily or because their parent company or their lenders require it. For regional context, see our article on IFRS S1 and S2 in Mexico.

What is the difference between TR 36 and TR 60?

Technical Resolution 36 governed the Social Balance Sheet with a local, descriptive approach. Technical Resolution 60 replaces it, shifts the terminology to sustainability information and builds on international frameworks, GRI and the IFRS Sustainability Disclosure Standards, so that the information is comparable.

What do I need to issue a green bond in Argentina?

A documented framework, project eligibility criteria, an independent external review and a commitment to publish an annual report on allocation of proceeds and impact, all in line with the CNV Guidelines for the issuance of thematic securities.

The hard part is not the rule, it is having environmental data traceable back to its source document when the auditor or external reviewer asks for it. That is where Manglai's carbon footprint solution comes in.