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)