Quick Guide: Key Sustainability Disclosure Regimes: Singapore: Mandatory climate reporting regime

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. 

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

• 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. 

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.  

• 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 

• Blog post - Mandatory climate reporting for listed and large non-listed companies in Singapore
• Blog post - Singapore Exchange Regulation publishes response to the public consultation on mandatory climate-related reporting requirements
• Blog post – Singapore: extended timelines for most climate reporting requirements for listed and large non-listed companies 
• Quick Guide on ISSB standards