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ESG Quick Guide: Singapore: Mandatory climate reporting regime

Linklaters has a series of Quick Guides that provide an overview of key sustainability regimes in the UK, EU and other jurisdictions. Click here to view all our Quick Guides.

This Quick Guide deals with the mandatory climate reporting regime in Singapore, which applies to all issuers listed on the Singapore stock exchange (“SGX”) and, from FY2030, to large non-listed companies in Singapore. 

Last updated on: 18 August 2026

In a nutshell 

From FY2025, all issuers listed on the SGX (including those incorporated overseas, business trusts and real estate investment trusts) must report and file their Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions. 

For the reporting and filing of other annual climate-related disclosures (“CRDs”) using requirements aligned with the International Sustainability Standards Board (“ISSB”) standards: 

  • listed companies that are Straits Times Index (“STI”) constituents must do so from FY2025;
  • non-STI constituent listed companies with a market capitalisation of S$1 billion and above must do so from FY2028; and
  • non-STI constituent listed companies with a market capitalisation of less than S$1 billion must do so from FY2030. 

From FY2030, large non-listed companies must provide CRDs, which will be filed with the Accounting and Corporate Regulatory Authority of Singapore (“ACRA”). A large non-listed company is defined as one with annual revenue of at least S$1 billion and total assets of at least S$500 million for two financial years immediately preceding the current financial year. 

The Interim Sustainability Standards Committee (“Interim SSC”) set up by ACRA published a consultation paper in July 2026 on the exposure drafts of the Singapore Sustainability Disclosure Standards (“Singapore SDS”). The draft Singapore SDS are aligned with ISSB’s IFRS S1 and IFRS S2 “to the extent practicable”, with targeted amendments to reflect Singapore’s policy objectives and implementation context (in particular, Singapore’s “climate-first” approach). Subject to applicable legislation being passed and the standards being finalised, the Singapore SDS are expected to apply to listed companies from FY2028, and to large non-listed companies from FY2030. In the interim, listed companies will continue to report under their existing obligations under the SGX Listing Rules. 

Mandatory or voluntary? 

Mandatory

Who does it apply to?

All issuers listed on the SGX and large non-listed companies 

When does it apply?

Mandatory CRDs will be introduced in a phased approach as follows: 

Timeline for requirementsListed issuersLarge non-listed companies
CRD for Scope 1 and 2 GHG emissionsFY2025FY2030
Other ISSB-based CRD

FY2025 for listed companies that are STI constituents

FY2028 for non-STI constituent listed companies with a market capitalisation of S$1 billion and above 

FY2030 for non-STI constituent listed companies with a market capitalisation of less than S$1 billion 

FY2030
CRD for Scope 3 GHG emissions

FY2026 for listed companies  that are STI constituent

Voluntary until further notice for all other listed companies

SGX announced in September 2024 that it would review listed companies’ experience and readiness before establishing the implementation roadmap for disclosures of Scope 3 GHG emissions.

Voluntary until further notice  
External limited assurance for Scope 1 and 2 GHG emissionsFY2029FY2032
Other requirements

Other primary components of sustainability report: All listed issuers will also be required to report on the other primary components of a sustainability report (beyond CRDs) from FY2026. These other components, as set out in the Listing Rules and which are currently reported on a “comply or explain” basis only, are:

  1. material ESG factors;
  2. policies, practices and performance;
  3. targets;
  4. sustainability reporting framework; and
  5. board statement and associated governance structure for sustainability practices. 

No similar requirements (beyond CRDs) have been announced for large non-listed companies. 

External assurance: All listed issuers will be required to conduct external limited assurance on their Scope 1 and 2 GHG emissions from FY2029. Large non-listed companies will be required to do so from FY2032. The external assurance must be provided by a registered climate auditor, which can be an ACRA-registered audit firm or a testing, inspection and certification firm accredited by the Singapore Accreditation Council. External assurance should be performed in accordance with recognised assurance standards. An issuer that has conducted external assurance should disclose, in the sustainability report, that external assurance has been conducted, including the scope covered, the identity of the external assurer, the standards used, the level of assurance obtained and key findings.

Exemption for large non-listed companies with parent companies that report CRD: ACRA will exempt large non-listed companies where its parent company is already making CRDs under the following circumstances:

  1. a large non-listed company whose parent company reports CRDs using ISSB-aligned local reporting standards or equivalent standards (e.g. the European Sustainability Reporting Standards) will be exempt from reporting and filing CRD with ACRA, subject to certain conditions being fulfilled (e.g. the large non-listed company’s activities are included within the parent company’s report, which is available for public use); and
  2. a large non-listed company whose parent company reports CRDs using other international standards and frameworks (e.g. the Global Reporting Initiative Standards, TCFD ), will be exempt from reporting and filing CRDs with ACRA (subject to the same conditions as explained above) for a transitional period, during which ACRA will take into consideration global developments on the adoption and recognition of other standards and frameworks. 

ACRA will issue further guidance on the standards and frameworks deemed equivalent and those that will be accepted during and after the transitional period, in order to guide implementation. 

Future changes?

Singapore SDS to be finalised: The Interim SSC published a consultation paper in July 2026 on the exposure drafts of the Singapore SDS. The draft Singapore SDS are aligned with ISSB’s IFRS S1 and IFRS S2 “to the extent practicable”, with targeted amendments to reflect Singapore’s policy objectives and implementation context (in particular, Singapore’s “climate-first” approach). Under the proposed two-standards structure:

  • the draft SFRS S2 will be a mandatory standard covering CRDs for entities subject to Singapore’s phased mandatory climate reporting requirements; and

  • the draft SFRS S1 will be issued as a voluntary standard - entities may choose to report broader sustainability-related financial disclosures beyond climate but are not required to do so.

The climate-relevant provisions of draft SFRS S1 are incorporated into the draft SFRS S2 as Appendix D, so that the draft SFRS S2 can operate as a standalone standard. Companies subject to mandatory climate reporting will, therefore, only need to refer to SFRS S2. 

Other adjustments under the Singapore SDS include tailored transition reliefs and a requirement for a statement of compliance to align with Singapore’s implementation roadmap. 

The current SGX Listing Rules requirement to prepare ISSB-aligned CRDs is intended as an interim step pending issuance of the final Singapore SDS. The transition to the Singapore SDS is expected to be manageable given the close alignment between the draft Singapore SDS and the ISSB standards. Subject to applicable legislation being passed and the standards being finalised, the Singapore SDS are expected to apply to listed companies from FY2028, and to large non-listed companies from FY2030. In the interim, listed companies will continue to report under their existing obligations under the SGX Listing Rules.

Potential application to smaller non-listed companies: ACRA will conduct a review on the experiences of listed and larger companies, before deciding whether similar climate reporting obligations will be subsequently extended to smaller, non-listed companies. In the meantime, companies not subject to mandatory reporting can voluntarily file their climate reporting if they have prepared it in accordance with the prescribed CRD requirements.

Future consultations for other sustainability-related disclosures for listed issuers: SGX RegCo will review the application of the ISSB standards for disclosure of sustainability-related information beyond CRDs (e.g. biodiversity, human capital, etc.) in due course. Separate public consultations will also be conducted to implement IFRS S1 beyond CRDs.

Upcoming consultation on the amendment of the Companies Act 1967: The detailed disclosure obligations which will apply to large non-listed companies from FY2030 are expected to be set out in Singapore’s Companies Act 1967. ACRA will launch a public consultation on an upcoming bill proposing amendments to the Companies Act 1967 to implement these changes.  

Legislation & guidance

Interim SSC's consultation paper on the exposure drafts of the Singapore SDS (including draft SFRS S1, draft SFRS S2 and the summary of key differences from the ISSB standards)

Practice Note 7.6 (Sustainability Reporting Guide)

SGX RegCo’s initial guidance

ACRA’s initial guidance

ACRA and SGX RegCo’s announcement and guidance on the extended timelines for climate reporting requirements 

Roadmap to navigate SGX’s climate reporting timelines: SGX RegCo and the Institute of Singapore Chartered Accountants have jointly developed a roadmap (“Roadmap”) to support non-STI constituents in meeting the relevant CRD timelines by FY2028. Non-STI constituents that have until FY2030 may also adapt and are encouraged to adopt the Roadmap as soon as possible. As most issuers have already substantially adopted the TCFD recommendations, the Roadmap focuses on how a non-STI constituent which has already adopted the TCFD recommendations may implement the climate-related requirements of the ISSB Standards. The Roadmap is also intended as a reference for the board of directors or board committees to assess the progress made by listed issuers in their CRD within each subsequent sustainability report to meet the climate-reporting requirements by the applicable timeline.  

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