SGX Climate Reporting Requirements: A Phased Roadmap for Singapore Issuers, FY2025–FY2030

Singapore's mandatory climate reporting regime is no longer a future obligation, it is live. Every SGX-listed company must report Scope 1 and Scope 2 greenhouse gas emissions for financial years beginning on or after 1 January 2025, Straits Times Index (STI) constituents must already publish full ISSB-aligned climate disclosures, and the rest of the market, including large private companies, phases in through FY2030.¹

Last updated 16 July 2026. Reflects the SGX RegCo and ACRA timeline extensions announced on 25 August 2025 and ACRA's requirements timeline as updated on 3 July 2026.

Who must report climate information to SGX, and when?

The regime has one architect and two regulators. Singapore's roadmap was designed by the Sustainability Reporting Advisory Committee (SRAC), set up by the Accounting and Corporate Regulatory Authority (ACRA) and SGX RegCo, whose recommendations the Government accepted in February 2024.⁵ SGX RegCo then amended its listing rules with effect from 1 January 2025 to incorporate the ISSB standards into the sustainability reporting framework.¹ After the August 2025 recalibration, the obligations fall into four tiers.^3,4

Mind the "FY" convention. "FY2025" means financial years commencing on or after 1 January 2025, so an issuer with a 31 March year end enters the regime with the year beginning 1 April 2025, reporting in 2026–27. FY2025 disclosures are therefore being published right now, in 2026.¹

The timeline below is the single most useful planning picture for a board or sustainability committee.

What changed in August 2025, and what did not?

The original roadmap was more aggressive. The SRAC plan, consulted on by SGX RegCo in March 2024, would have required all listed issuers to make full IFRS S1/S2-aligned climate disclosures from FY2025, larger issuers to report Scope 3 from FY2026, assurance from FY2027, and large non-listed companies to start from FY2027.^5,6 Citing the uncertain global economic environment and the uneven readiness of smaller issuers, ACRA and SGX RegCo moved most of those deadlines on 25 August 2025, while the FY2025 obligations already in force stayed put.^3,11

Three points are worth stressing, because they are commonly misread:

• Nothing about FY2025 was relaxed. Scope 1 and 2 reporting for all issuers, and full ISSB-aligned climate reporting for STI constituents, proceed as planned. If your FY2025 report has not yet been filed, the requirement is current, not upcoming.
• Scope 3 was narrowed, not delayed, for the largest issuers. STI constituents still report Scope 3 from FY2026. What changed is that the planned extension to other issuers with market capitalisation of S$1 billion or more was shelved: for every non-STI issuer, Scope 3 is now voluntary until further notice, with SGX RegCo expected to review readiness and give advance notice before mandating it.^1,3
• Assurance moved by two years, not away. External limited assurance on Scope 1 and 2 emissions now starts in FY2029 for all listed issuers and FY2032 for large non-listed companies.⁴

The practical takeaway: treat the extension as extra runway to build the reporting machinery, not as a reprieve from building it.

What does IFRS S1/S2-aligned disclosure mean under SGX listing rules?

The ISSB standards are now the baseline. Since 1 January 2025, SGX's listing rules and Practice Note 7.6 (the Sustainability Reporting Guide) require climate reporting prepared on the basis of IFRS S2, together with the climate-relevant provisions of IFRS S1, the ISSB's two inaugural standards.^1,2 This replaced the previous TCFD-based requirement that had applied on a comply-or-explain basis since FY2022, and mandatorily for issuers in high-impact industries thereafter. Issuers are not required to make a formal statement of full compliance with the ISSB standards, but the disclosures themselves must be prepared using them as the baseline.^1,8

Alignment raises the bar over TCFD in four ways. Emissions must ultimately be measured under the GHG Protocol Corporate Standard and disaggregated by scope. Climate resilience must be assessed using scenario analysis. Disclosures must connect to the financial statements, quantifying current and anticipated financial effects where practicable. And industry-based metrics, drawing on the SASB standards, must be considered.⁹ The reporting entity must be the same as for the financial statements, which pulls consolidated subsidiaries into the emissions boundary.

Which transition reliefs can Singapore issuers use?

SGX RegCo adopted the ISSB's reliefs largely intact. In an issuer's first year of ISSB-aligned reporting it may: omit Scope 3 emissions; continue using its existing GHG measurement methods rather than switching immediately to the GHG Protocol; and omit comparative prior-period information.¹ Two permanent proportionality mechanisms also apply: scenario analysis may be carried out using an approach commensurate with the issuer's circumstances and capabilities, and issuers need only use "all reasonable and supportable information available without undue cost or effort", a phrase worth quoting to any adviser who insists that a small-cap needs an enterprise-grade climate model in year one.¹

When must the sustainability report be published?

Four months, or five with assurance. The sustainability report must be issued together with the annual report, within four months of the financial year end, or within five months where the issuer obtains external assurance on the report.¹ For a December year end, that means 30 April, or 31 May with assurance. Until mandatory assurance arrives in FY2029, every issuer's sustainability reporting process must instead be subject to internal review by its internal audit function, with audit committee oversight, a governance requirement that examiners of FY2025 reports will expect to see evidenced, not merely asserted.^1,2

What are the four primary components of an ISSB-aligned climate disclosure?

IFRS S2 inherits the TCFD's architecture. Every climate disclosure is organised around four pillars: governance (board oversight of climate risk; management roles, skills and incentives), strategy (climate risks and opportunities, their financial effects, and a scenario-based resilience assessment), risk management (how climate risks are identified, assessed and integrated into enterprise risk management), and metrics and targets (Scope 1, 2 and, where required, 3 emissions, industry-based metrics, and climate targets with progress against them).⁹

SGX's Sustainability Reporting Guide expects issuers to address all four, alongside the other primary components of the sustainability report: material ESG factors; policies, practices and performance; targets; the reporting framework; and the board statement.² Two of these pillars, strategy (scenario analysis) and metrics and targets, are where Singapore issuers are demonstrably weakest, as SGX RegCo's own review data shows below.

Scope 1 and 2 now, Scope 3 phased: what is the SGX Scope 3 timeline?

Scope 3 follows a deliberately narrow path. Scope 1 (direct) and Scope 2 (purchased energy) emissions are mandatory for every listed issuer from FY2025. Scope 3, the fifteen categories of value-chain emissions defined by the GHG Protocol, from purchased goods and services to use of sold products and investments, is mandatory for STI constituents from FY2026 (first disclosures in reports published in 2027) and voluntary for everyone else until further notice.^3,4

The caution is grounded in evidence. The Climate Reporting Review published by SGX RegCo and the NUS Business School's Centre for Governance and Sustainability in March 2025 examined 529 listed issuers: 97% had begun climate reporting, but only 29% disclosed Scope 3 emissions, and only 28% provided all eleven recommended climate disclosures. Among issuers with market capitalisation above S$1 billion, Scope 3 disclosure reached 64%; among those below S$300 million, just 22%.⁷

Voluntary does not mean optional in substance. An issuer that has already disclosed Scope 3 is expected to continue, and banks and anchor customers running their own IFRS S2 or CSRD programmes are increasingly requesting value-chain data from Singapore suppliers regardless of listing-rule status.

Scope 3 also has the longest lead time of anything in the regime. Building supplier data collection, choosing estimation methods for each of the fifteen categories and documenting them defensibly typically takes more than one reporting cycle, which is precisely why SGX RegCo committed to a readiness review and advance notice before extending the mandate.¹ Teams that treat FY2026–FY2027 as a dry-run period, calculating Scope 3 internally before publishing, will be in a far stronger position than those that wait for the rule. This is where purpose-built tooling earns its keep: EcoLedger's carbon accounting module covers all fifteen Scope 3 categories alongside Scope 1 and 2, so materiality screening and method upgrades happen inside one auditable system rather than a sprawl of spreadsheets.

What are the external assurance requirements, and what applies in the meantime?

Assurance starts in FY2029. From FY2029, all listed issuers must obtain external limited assurance on Scope 1 and Scope 2 emissions; large non-listed companies follow from FY2032.^3,4 Assurance must be provided by an ACRA-registered audit firm or an accredited testing, inspection and certification (TIC) body, applying recognised standards, in practice ISSA 5000 or ISAE 3000/3410, and the report must identify the assurer, the standard applied, the level of assurance and the findings.¹⁰

Three reporting cycles away sounds comfortable. It is not, for one reason: assurance is retrospective. An assurance practitioner in 2030 will ask how FY2029 emissions were calculated, and will test the consistency of methods, organisational boundaries and emission factors against prior years. Issuers whose FY2025–FY2028 figures rest on undocumented spreadsheets will face restatements at exactly the moment the numbers become subject to opinion.

The pre-assurance discipline the rules already demand, internal audit review, with audit committee oversight¹, is best treated as a rehearsal. Maintain an evidence file for every reported figure, from activity data through to methodology and sign-off, so that limited assurance in FY2029 is a verification exercise rather than an archaeology project.

When do large non-listed companies in Singapore have to report?

The regime reaches beyond the exchange. Under the roadmap accepted by the Government in 2024 and recalibrated in August 2025, large non-listed companies will make ISSB-aligned climate disclosures, including Scope 1 and 2 emissions, from FY2030, with external limited assurance from FY2032. Scope 3 remains voluntary.^4,5 The test is a two-limb size threshold, and both limbs must be met:

The large non-listed company test. A company meeting only one limb, say, S$1.2 billion revenue on S$400 million of assets, is outside the regime; a company meeting both reports from FY2030 and adds external limited assurance on Scope 1 and 2 from FY2032.

A parent-report exemption is available. A company escapes the obligation where its parent already prepares an ISSB-aligned (or equivalent, such as ESRS-based) sustainability report that is publicly available and consolidates the Singapore entity's activities; a transitional exemption is contemplated for parents reporting under other international frameworks while regulators assess convergence.^4,10

Note that this limb of the regime will be administered by ACRA and implemented through legislation; the operative details remain subject to the legislative process, so large private companies should treat FY2030 as the planning assumption and watch for the implementing amendments.

How does Singapore's approach compare with Hong Kong and Malaysia?

Regional context matters for groups operating across ASEAN and Greater China, because a Singapore issuer's subsidiaries or peers may face earlier, or later, obligations elsewhere. All three markets are converging on the ISSB standards, but on different clocks and with different first cohorts.^12,13

The Scope 3 and assurance clocks also differ. In Hong Kong, Main Board issuers report Scope 1 and 2 from FY2025 with the other new climate disclosures on a comply-or-explain basis; Hang Seng Composite LargeCap constituents move to fully mandatory disclosure, including Scope 3, with reasonable-information reliefs, from FY2026, and the December 2024 roadmap targets full ISSB adoption for listed and significant publicly accountable entities by 2028.¹² Assurance is not yet mandated under HKEX listing rules. In Malaysia, the National Sustainability Reporting Framework lets each group defer Scope 3 for its first two annual reporting periods (three for Group 3), and a Sustainability Assurance Framework is under development.^13,14

The pattern is consistent across all three markets: emissions first, largest companies first, assurance last. But Singapore is alone in making Scope 1 and 2 mandatory for every issuer from FY2025, including the smallest Catalist company.⁴

First-report checklist: what should a Singapore issuer do now?

For teams preparing an FY2025 or FY2026 report, or a non-STI issuer using the runway to FY2028/FY2030 well, the sequence below reflects both the rules and the gaps regulators keep finding.

• Confirm your tier and dates. STI constituent, non-STI above or below S$1 billion market capitalisation, or large non-listed company. Map your financial year end to the four-month (or five-month, with assurance) filing deadline.¹
• Fix the reporting boundary. Align the sustainability reporting entity with the consolidated financial statements, and document the organisational boundary chosen for GHG accounting (operational control is the common choice).
• Build the Scope 1 and 2 inventory properly. Identify emission sources by entity and site, select emission factors and record them, and calculate Scope 2 using location-based figures (with market-based where instruments exist). The year-one relief lets you keep existing measurement methods, but plan the move to full GHG Protocol alignment now.¹
• Draft against all four pillars. Governance and risk-management disclosures cost little and score badly across the market; a candid description of board oversight and how climate risk enters the ERM cycle immediately lifts a report above the median.⁷
• Run a proportionate scenario analysis. A qualitative assessment against at least two scenarios (for example, a below-2°C pathway and a current-policies pathway) satisfies the standard's proportionality mechanisms in early years, provided the method and assumptions are documented.¹
• Set at least one credible target. Targets are among the weakest disclosure areas in SGX RegCo's reviews; a target with a base year, a scope and interim milestones beats an aspiration without arithmetic.⁷
• Screen Scope 3 even if you need not publish it. A materiality screen across the fifteen categories tells you where your value-chain exposure sits and what data you must start requesting from suppliers.
• Stand up the internal review. Brief internal audit early, agree the review scope with the audit committee, and keep evidence for every disclosed figure, the habit that makes FY2029 assurance uneventful.
• Plan comparatives from year two. The no-comparatives relief expires after the first year; lock methods down so year-on-year movements reflect performance, not methodology drift.

Done in that order, the first report becomes a foundation rather than a scramble, and each later phase of the roadmap lands on infrastructure that already exists.

Which gaps has SGX RegCo flagged in issuer climate reports?

The joint SGX RegCo–NUS reviews are the closest thing issuers have to an examiner's report, and the findings are consistent. The March 2025 review found that while 97% of issuers had begun climate reporting (up from 73% two years earlier), the weakest disclosures were climate scenario analysis, integration of climate risk into risk management, and climate targets, with Scope 3 disclosure at 29% overall and only 36% of issuers in the mandated high-impact industries providing all eleven recommended disclosures.⁷ SGX RegCo has paired the criticism with capacity-building support, but the direction is unambiguous: as reporting moves from TCFD-based to ISSB-based, boilerplate that survived comply-or-explain will not survive a regime with defined disclosure objectives and, eventually, external assurance.

The recurring failure mode beneath all of these is the same: disclosures asserted without an evidence trail. Scenario analysis "considered" but not described; targets announced without base-year data; emissions totals that cannot be decomposed to source level. That is an infrastructure problem more than an ambition problem, and it is the reason financial-grade process (documented methods, versioned data, a register linking every figure to its evidence) is the single highest-return investment a newly regulated issuer can make before FY2029.

Frequently asked questions

When does SGX climate reporting become mandatory?

All SGX-listed issuers must report Scope 1 and Scope 2 greenhouse gas emissions from FY2025, with the first reports published in 2026. Straits Times Index (STI) constituents must also make full IFRS S1/S2-aligned climate disclosures from FY2025. Other issuers phase in the remaining climate disclosures from FY2028 (market capitalisation of S$1 billion or more) or FY2030 (below S$1 billion).

Do all SGX-listed companies have to report Scope 3 emissions?

No. Only STI constituents must report Scope 3 emissions, from FY2026. For all other listed issuers Scope 3 reporting is voluntary until further notice, following the August 2025 timeline extension by SGX RegCo and ACRA. Issuers already disclosing Scope 3 are expected to continue doing so.

When is external assurance required for SGX sustainability reports?

External limited assurance on Scope 1 and Scope 2 emissions becomes mandatory for listed issuers from FY2029 (deferred from the originally planned FY2027), and for large non-listed companies from FY2032. Assurance must be performed by an ACRA-registered audit firm or an accredited testing, inspection and certification body. Until then, sustainability reports must undergo internal review by the issuer's internal audit function.

Do private companies in Singapore have to do climate reporting?

Large non-listed companies, those with annual revenue of at least S$1 billion and total assets of at least S$500 million, are due to make ISSB-aligned climate disclosures, including Scope 1 and 2 emissions, from FY2030 under a regime administered by ACRA. An exemption is available where a parent company already publishes an equivalent, ISSB-aligned sustainability report covering the subsidiary.

What is the deadline for publishing an SGX sustainability report?

Issuers must publish the sustainability report together with the annual report, within four months of the financial year end. Issuers that obtain external assurance have up to five months. For a 31 December year end, that means 30 April or 31 May of the following year.

Which standards apply to SGX climate reporting, TCFD or ISSB?

From FY2025, SGX listing rules require climate reporting based on the ISSB standards, IFRS S2 and the climate-related provisions of IFRS S1, replacing the earlier TCFD-based requirement. Because IFRS S2 builds directly on the TCFD's four pillars, work done under TCFD carries over, but ISSB alignment demands more granular, decision-useful and financially connected disclosure.

What transition reliefs are available in the first year of ISSB-aligned reporting?

In the first year of ISSB-aligned reporting, SGX allows issuers to omit Scope 3 emissions, to continue using their existing GHG measurement methods rather than moving immediately to the GHG Protocol, and to omit comparative prior-period information. Ongoing proportionality mechanisms also apply: scenario analysis commensurate with the issuer's capabilities, and use of all reasonable and supportable information available without undue cost or effort.

References

1. SGX RegCo, Sustainability Reporting: Enhancing Consistency and Comparability, Response to Consultation (rule amendments effective 1 January 2025), accessed July 2026.
2. SGX Rulebook, Practice Note 7.6, Sustainability Reporting Guide, accessed July 2026.
3. ACRA and SGX RegCo, Extended Timelines for Most Climate Reporting Requirements to Support Companies, 25 August 2025, accessed July 2026.
4. ACRA, Sustainability Reporting and Assurance Requirements, Timeline (updated 3 July 2026), accessed July 2026.
5. ACRA, Response to Public Consultation on the Climate Reporting and Assurance Roadmap for Singapore, February 2024, accessed July 2026.
6. SGX RegCo, Consultation Paper on Sustainability Reporting: Enhancing Consistency and Comparability, March 2024, accessed July 2026.
7. SGX RegCo and NUS Business School Centre for Governance and Sustainability, Climate Reporting Review 2024 (published March 2025), accessed July 2026.
8. IFRS Foundation, Jurisdictional Snapshot: Singapore, accessed July 2026.
9. Latham & Watkins, SGX RegCo to Incorporate IFRS Standards Into Mandatory Climate Reporting Rules, accessed July 2026.
10. Linklaters Sustainable Futures, ESG Quick Guide, Singapore: Mandatory Climate Reporting Regime, accessed July 2026.
11. Allen & Gledhill, ACRA and SGX RegCo Extend Timelines for Most Climate Reporting Requirements, accessed July 2026.
12. Norton Rose Fulbright, Embracing the Global Trend of ISSB Standards: New Climate Disclosure Regime under HKSE Listing Rules, accessed July 2026.
13. Securities Commission Malaysia, National Sustainability Reporting Framework (NSRF), accessed July 2026.
14. IFRS Foundation, Jurisdictional Profile: Malaysia (updated June 2025), accessed July 2026.

This guide is general information, not legal or assurance advice. Requirements described as under consultation or subject to legislation may change; check the primary sources above for the current position.