Abstract
Against the backdrop of a global climate agenda and the widespread adoption of sustainable development concepts, ESG (Environmental, Social, Governance) principles are becoming the central criteria of international investment decisions. The purpose of the study is to systematically analyse ESG regulatory models established in the EU, the USA and the Asia-Pacific region, identify criteria for their effectiveness, and propose a hybrid regulatory model for Kazakhstan. The main research directions include: comparative analysis of mandatory and voluntary disclosure standards; examination of the content and effectiveness of SFDR, CSRD, EU Taxonomy and ISSB S1/ S2 standards; case-study analysis of leading corporations’ ESG practices (Ørsted, DBS Bank); and assessment of Kazakhstan’s regulatory environment based on SWOT analysis. The scientific significance of the work lies in developing a new typology of ESG regulatory models through a ‘mandatory space – institutional capacity’ matrix that accounts for regional specifics. Regression analysis confirmed a positive relationship between the mandatory nature of ESG regulation and company performance (β=0.42, p<0.01); the level of institutional capacity acts as a moderating factor. The practical significance lies in proposing a phased roadmap for implementing a hybrid regulatory model for 2024–2031 for the AIFC, ARDFM and major companies. The results make a concrete contribution to improving public policy in the field of green finance development.