Singapore Writes Its Own ISSB Standards: What the SFRS S2 Consultation Changes for SGX Reporters
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Singapore is giving its climate reporting regime its own rulebook. On 27 July 2026, ACRA's Interim Sustainability Standards Committee opened a public consultation on two Singapore-specific standards, a mandatory, standalone SFRS S2 for climate disclosures and a voluntary SFRS S1 for broader sustainability reporting, both built on the ISSB baseline that SGX-listed issuers already report against. The consultation closes on 25 October 2026, and the modifications it proposes will shape every Singapore climate report from here.1,2
Key takeaways
ACRA's Interim Sustainability Standards Committee is consulting from 27 July to 25 October 2026 on Singapore's first homegrown sustainability disclosure standards.
SFRS S2 (climate) would be mandatory; SFRS S1 (general sustainability) would be voluntary.
The headline design choice is climate-first: the climate-relevant requirements of IFRS S1 fold into an appendix of SFRS S2, so companies comply with a single standalone climate standard.
Three modifications stand out: the timing relief is removed, the Scope 3 relief is extended indefinitely for those not yet mandated, and mandatory SASB references become voluntary.
Scope 3 mandates themselves stay with legislation and SGX listing rules, not the standards, so the existing roadmap (STI constituents from FY2026, everyone else voluntary until further notice) stands.
01What exactly is Singapore proposing?
Two standards, one mandatory. Since FY2025, SGX-listed issuers have reported climate information against the ISSB standards directly, incorporated into the listing rules. The consultation proposes replacing that direct incorporation with Singapore's own standards, issued under the SFRS banner alongside Singapore's financial reporting standards.1,2
| Proposed standard | Based on | Status | What it covers |
|---|---|---|---|
| SFRS S2 Climate-related Disclosures |
IFRS S2, plus the climate-relevant parts of IFRS S1 as an appendix | Mandatory | Governance, strategy, risk management, metrics and targets, Scope 1 and 2 GHG emissions (Scope 3 per the legislative roadmap) |
| SFRS S1 General Requirements |
IFRS S1 | Voluntary | Sustainability-related financial disclosure beyond climate, for companies choosing to report more broadly |
The standalone-S2 architecture is the clever part. Under the ISSB's own design, applying IFRS S2 drags in IFRS S1's general requirements, a real burden for companies whose only mandate is climate. Singapore's answer is to fold the climate-relevant S1 machinery (materiality, reporting entity, connected information, judgements and estimates) into an appendix of SFRS S2, so the climate standard operates as a standalone standard. Companies reporting only climate apply one document; companies going further layer voluntary SFRS S1 on top.1,2
02Where does SFRS S2 depart from the ISSB baseline?
The departures are few, deliberate, and mostly about Singapore's phased roadmap. Three matter in practice.1,3
01The timing relief is removed
The ISSB's transition relief allowing sustainability disclosures to be published later than the financial statements is dropped. Singapore expects climate disclosures at the same time as the financial statements, consistent with the sustainability report sitting inside the annual report under the existing SGX framework.
02Scope 3 relief extended indefinitely
The ISSB's one-year Scope 3 relief becomes open-ended for companies not subject to mandatory Scope 3 reporting under Singapore's roadmap, the standards catching up with policy. Scope 3 obligations continue to be set through legislation and SGX listing rules.
03SASB references become voluntary
Where the ISSB requires companies to “refer to and consider” SASB materials when identifying disclosures, SFRS S2 proposes “may refer”, giving companies flexibility while the SASB standards themselves are revised internationally.
03Why is Singapore doing this now?
Ownership, sequencing and interoperability. Issuing national standards rather than pointing at the ISSB's gives Singapore control over effective dates, reliefs and language as the international baseline evolves, the same route taken by Australia (AASB S1/S2), and proposed in the UK (UK SRS) and elsewhere among the roughly 40 jurisdictions moving on ISSB adoption. The climate-first structure also formalises what Singapore's roadmap already does in practice: mandate climate now, keep wider sustainability reporting voluntary until the market matures.2,3
For multinationals, the alignment maths is favourable. Because SFRS S2 is IFRS S2 with targeted reliefs rather than a divergent regime, a group reporting under AASB S2 in Australia, the proposed UK SRS or IFRS S2 itself elsewhere can run one climate reporting process and map it into each jurisdiction's wrapper, provided the group tracks the small differences, timing of reporting and Scope 3 posture chief among them.
04Who should respond, and what should reporters do before 25 October?
The consultation runs to 25 October 2026, with responses via FormSG and the REACH portal. Whether or not you respond formally, the proposal changes what Singapore reporting teams should be doing this quarter.
Respond if the timing removal bites
Companies currently using the ISSB relief to publish sustainability information after the financial statements should quantify what simultaneous reporting costs them, and say so in a submission. This is the modification most likely to strain mid-market reporting calendars.
Confirm your Scope 3 posture against the roadmap
The indefinite relief follows the legislative mandate, not the standard. Non-STI issuers stay voluntary until SGX RegCo says otherwise, but banks and anchor customers running value-chain programmes will keep asking regardless. A dry-run Scope 3 inventory remains cheap insurance.
Map current disclosures to the SFRS S2 structure
For issuers already reporting against IFRS S2 under the listing rules the delta should be small, but the appendix architecture and SASB flexibility change referencing and drafting. An early gap map makes the transition an editing exercise.
Decide whether voluntary SFRS S1 is worth adopting
For companies with substantial non-climate sustainability exposure, investor-facing S1 adoption may pre-empt future mandates, and the voluntary window is the low-stakes time to build the muscle.
05Frequently asked questions
What are SFRS S1 and SFRS S2?
They are Singapore's proposed sustainability disclosure standards, developed by ACRA's Interim Sustainability Standards Committee. SFRS S2, based on IFRS S2 with the climate-relevant parts of IFRS S1 included as an appendix, would be mandatory for companies under Singapore's climate reporting regime. SFRS S1, based on IFRS S1, would be voluntary.
When does the consultation close?
25 October 2026. It opened on 27 July 2026, and responses are submitted through FormSG and the REACH consultation portal.
How do the proposed standards differ from the ISSB's?
Three main modifications: the transition relief allowing sustainability reporting later than the financial statements is removed; the Scope 3 relief is extended indefinitely for companies not subject to mandatory Scope 3 reporting under Singapore's roadmap; and mandatory references to SASB materials become voluntary. SFRS S2 is also structured to operate standalone, without requiring full application of S1.
Does this change when Singapore companies have to report?
No. The reporting timeline continues to be set by SGX listing rules and legislation: Scope 1 and 2 for all listed issuers from FY2025, full ISSB-aligned disclosure for STI constituents from FY2025 with Scope 3 from FY2026, phase-in for other issuers from FY2028 or FY2030, and external assurance from FY2029. The consultation changes which standard those reports cite, not when they are due.
Is Scope 3 reporting becoming mandatory in Singapore?
Not through these standards. Scope 3 obligations will continue to be set through legislation and SGX listing rules. Currently that means mandatory Scope 3 for STI constituents from FY2026 and voluntary reporting for all other issuers until further notice, and the proposed SFRS S2 extends its Scope 3 relief indefinitely for companies outside a mandate.
References
- ACRA, Public Consultation on Singapore's Sustainability Disclosure Standards (27 July to 25 October 2026), accessed August 2026.
- ESG Today, Singapore Releases Proposed ISSB-Aligned Sustainability Reporting Standards, 28 July 2026, accessed August 2026.
- GRC Report, Singapore Bets on Climate First as It Opens Consultation on New Disclosure Rules, accessed August 2026.
- ACRA, Sustainability Reporting and Assurance Requirements, Timeline, accessed August 2026.
This guide is general information, not legal or accounting advice. The standards described are consultation proposals and may change before finalisation; check the primary sources above for the current position.
