Аңдатпа
Contemporary ESG (Environmental, Social, and Governance) regulation creates costs and risks for businesses, which are associated with the stringency of requirements. This article demonstrates that the key source of these problems is the fragmentation of legal regulation, the inconsistency of reporting standards, and the methodological heterogeneity of ESG indices. Based on a comparative legal analysis of eight jurisdictions (the US, EU, China, India, Brazil, Russia, South Africa, and Kazakhstan), three models of ESG regulation are identified: prescriptive, market-oriented, and state-centralized. It is shown that extraterritorial pressure (CBAM, CSDDD) and internal regulatory conflicts (for example, in the US) greatly increase compliance costs, especially for developing economies. High divergence in corporate ESG ratings (up to 50–60%) has been empirically confirmed, making global indices of limited applicability for regulatory purposes. In response to these identified issues, a country-specific ESG index, integrated into a closed-loop feedback management system, has been proposed. A two-tier methodology has been developed: calculating a company index (taking into account regulatory burden, extraterritorial pressure, and adaptability) and aggregating it into a country index based on macrostatistics with the possibility of transitioning to Big Data aggregation, including the use of digital SaaS platforms for managing production and environmental data. The results can be used by national regulators to improve the comparability of ESG data and differentiate government support measures.