A Decade of Green Accounting in Indonesia and the UK : Implementation, Challenges, and Opportunities

Green accounting is one of the important approaches in sustainability reporting, where the concept of sustainability reporting integrates environmental factors into the traditional accounting process. This integration reflects the growing global awareness that environmental degradation and climate change must be addressed not only by governments and civil society but also by the corporate sector through transparency and accountability in financial disclosures. This article aims to comparatively analyze the implementation of green accounting in Indonesia and the United Kingdom (UK), focusing on the challenges faced and the opportunities for strengthening the practice in both countries. This research uses a qualitative literature review method by collecting, synthesizing, and analyzing scientific articles, regulatory frameworks, and institutional reports published between 2016 and 2025. The results show that the UK has implemented green accounting more comprehensively and systematically, supported by strong environmental regulations, mandatory disclosure requirements, and high awareness within the private sector. The UK's implementation is closely aligned with international standards such as the Global Reporting Initiative (GRI) and the Task Force on Climate-related Financial Disclosures (TCFD), which help ensure consistency and comparability of sustainability reporting across industries. In contrast, Indonesia is still in the developmental stage regarding green accounting adoption. Several challenges persist, including limited regulatory mandates, lack of technical expertise, minimal integration of environmental indicators in corporate reporting, and low levels of awareness among SMEs and regional stakeholders. Nevertheless, the country has shown growing interest in sustainable practices, especially following the issuance of green taxonomy and the development of ESG (Environmental, Social, Governance) investment frameworks.