Stakeholder engagement and ESG in China
This research analyses China’s state-led stakeholder empowerment model for ESG integration. It identifies economic, policy, compliance, and sustainability drivers while examining channels such as shareholder activism and representative litigation. The article proposes a tiered institutionalisation framework to resolve procedural indeterminacy and strengthen collective action infrastructure within concentrated ownership structures.
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OVERVIEW
Introduction
Stakeholder engagement is a core mechanism for integrating environmental, social, and governance (ESG) considerations into corporate decision-making. This research challenges conventional views that characterize Chinese stakeholder engagement as purely formalistic due to concentrated ownership and state control. It argues that China has developed a distinct model of state-led stakeholder empowerment, constituting a pluralistic ecosystem. The scale of this stakeholder base is vast, with 27.33 million new A-share accounts opened in 2025 and total market capitalisation reaching approximately RMB 168 trillion. China also possesses the world’s largest labour force of 860 million working-age individuals.
Major stakeholder engagements in China
Engagement in China is primarily dominated by regulatory action and shareholder activism mediated through state-sanctioned channels. Controlling shareholders are the decisive factor, with empirical research suggesting a positive relationship between ownership concentration and ESG performance when concentration is below 34.2%. Institutional investors are an emerging force, with 87.5% of public funds exercising voting rights. The June 2026 AMAC Guidelines have further transitioned sustainable investment from a voluntary tool into a structured compliance operation. Employee stock ownership plans (ESOPs) have been adopted by 911 A-share companies involving over 413,000 participants as of 2023.
The state engages through direct ownership of state-owned enterprises (SOEs) and representative institutions like the China Securities Investor Service Center (CSISC). The CSISC operationalises minority-investor rights by initiating representative litigation, notably securing RMB 24.59 billion for over 50,000 investors in the Kangmei Pharmaceutical case in 2021. Board representation has been expanded by the 2023 Company Law, which mandates employee directors for firms with 300 or more employees. However, a substitution loophole allows private enterprises to exclude employee directors if they maintain a compliant supervisory board.
Public pressure serves as a mode of reputational governance, leveraging digital communication to discipline corporate behaviour. The 2025 Arc’teryx fireworks incident, which triggered accusations of ecosystem damage, resulted in ANTA Group’s stock price falling and wiping over HK$10 billion in market value. Conversely, the 2025 Shanghai school lunch scandal saw minimal regulatory intervention, highlighting that public pressure is driven by selective amplification. Trade unions and Employee Representative Congresses (ERCs) also contribute, with 31 provinces training approximately 876,000 employee environmental supervisors by 2023.
Driving forces underlying stakeholders engagements
The research identifies four interrelated drivers. Economic drivers are broadly convergent with global trends, focusing on firm value and performance. Policy drivers act as the primary organising force, distinguishing China from Western models. ESG policy is embedded within a party-state system where macro strategies, such as the Dual Carbon policy (aiming for peak emissions by 2030 and neutrality by 2060), connect directly to bureaucratic incentives. Compliance drivers often generate formalistic adherence, satisfy regulatory requirements but produce minimal substantive change. Sustainability drivers involve engagement motivated by the autonomous pursuit of sustainable development, where citizen or investor action initiates pressure that the state may later amplify.
Legal infrastructure empowerment and the way forward
The most reliable predictor of substantive outcomes is the density and coherence of legal institutional embedding. A three-tier model is identified: statutory law (Tier 1), targeted administrative regulation (Tier 2), and soft law (Tier 3). Failure in channels like employee directors and trade unions often results from nominal statutory recognition lacking procedural specification. The proposed reform agenda focuses on addressing procedural indeterminacy, building collective action infrastructure—including a potential Chinese stewardship code—and improving enforcement credibility for labour and environmental rights.
Conclusion
State-led stakeholder empowerment is a distinct governance model that uses state authority to solve collective action problems. Its central vulnerability is the gatekeeper function, where outcomes depend on state endorsement. The suggested path forward involves reducing this dependence by hardening entitlements and building enforcement credibility that does not depend on political alignment, ensuring that governance outcomes are reproducible rather than contingent.