Regulatory update

The landscape of sustainability regulations in Singapore has evolved significantly over the past decade, especially for companies listed on the Singapore Exchange (SGX). The following is an overview of the regulatory developments and expectations around sustainability reporting in Singapore as of 2024.

The SGX Regulation (SGX RegCo) introduced sustainability reporting for listed issuers on a voluntary basis in 2011, marking a shift towards increased corporate transparency on ESG issues. By 2016, the guidelines were made mandatory on a 'comply or explain' basis, requiring issuers to include the following six components in their reports:

1.    Material ESG factors - to identify ESG factors that impact the company's performance.
2.    Climate-related disclosures - to detail risks and opportunities posed by climate change.
3.    Policies, practices and performance - to outline specific actions taken and outcomes.
4.    Targets – to set and track progress toward sustainability goals.
5.    Sustainability reporting framework – to align disclosures with recognised frameworks.
6.    Board statement and associated governance structure for sustainability practices – to demonstrate accountability for sustainability practices.

2024 improvements to SGX RegCo sustainability reporting requirements

In response to widespread support from several rounds of public and market consultation, SGX RegCo has progressively strengthened its sustainability reporting framework, including significant updates announced in September 2024

These changes will provide listed issuers clarity through a more comprehensive framework for disclosing sustainability-related financial information, including climate-related risks and opportunities. This enhancement builds upon the mandatory sustainability reporting regime announced by SGX RegCo in 2016. In 2021, they also introduced a roadmap to help issuers provide climate-related disclosures.

Moving forward, this is what to expect in the next five years:

  • Mandatory climate-related disclosures (FY2025) – All listed issuers will be required to incorporate IFRS ISSB standards for climate-related disclosures.
    Full integration of six core components (FY2026) – Sustainability reports must include all six primary components (listed above), reinforcing comprehensive ESG reporting across listed companies. 
  • Scope 3 emissions disclosures for large issuers (FY2026) – Large issuers will be expected to disclose their Scope 3 emissions. SGX RegCo plans to provide sufficient notice ahead of this requirement to facilitate compliance.
  • Simultaneous publication of sustainability and annual reports (FY2026) – Issuers must publish their sustainability report alongside the annual report. If the sustainability report is externally assured, companies must publish within five months after the end of the financial year (EOFY). Issuers have four months post-EOFY to publish the SR if not externally assured.
  • Alignment to International Sustainability Standards Board (ISSB) standards – Commencing from financial year 2025, issuers must start incorporating the climate-related requirements in the ISSB standards. Other primary components of a sustainability report are to be disclosed on a 'comply or explain' basis. 

SGX Regulatory Enhancement regime - an overview


 


Key market insights:

Singapore’s shift towards sustainability is propelled by key legislative and regulatory frameworks aimed at reducing environmental impact, promoting resource efficiency, and supporting a circular economy. Below are some of the key initiatives that are driving this transformation: 

  • Introduced by the Ministry of Environment and Water Resources (MEWR) in October 2019. 
  • Provides legislative enforcement for regulatory measures managing waste streams with high generation and low recycling rates. 
  • Targets three critical waste streams: 
    • E-waste 
    • Food waste 
    • Packaging waste (including plastics) 
  • Requires companies to submit annual data on their packaging and report on reduce, reuse, recycle (3R) plans. 
  • Companies must provide information on the packaging that they introduce into Singapore annually, broken down according to type of packaging material (e.g. Plastic, paper, metal, glass), packaging form (e.g. Carrier bags, bottles) and corresponding weights. 
  • Administered by the National Environment Agency (NEA). 
  • Commenced on 1 July 2020. 
  • Promotes corporate awareness around packaging waste, encouraging companies to reduce packaging usage, which can lead to both cost savings and operational flexibility.
  • The MPR applies to companies meeting all of the following criteria: 
    • Operate a business supplying regulated goods within Singapore 
    • Has an annual turnover of > S$10m 
    • Imports or uses specified packaging. 
  • Launched in 2021 under the RSA and administered by the NEA.  
  • Ensures regulated electronics are responsibly collected and treated to recover valuable resources. 
  • Companies manufacturing or importing regulated electrical and electronic products for the Singapore market must ensure responsible collection and recycling of e-waste. 
  • Retailers of regulated consumer products are required to provide free, one-for-one take-back service for e-waste during product delivery. 
  • Large retailers are required to establish in-store e-waste collection points for information, communication, and technology (ICT) equipment.
  • All collected e-waste must be sent to licensed recyclers for proper treatment.
  • Singapore is assessing the feasibility of extending EPR to cover additional types of packaging waste (as of October 2024, no further updates). 

Singapore’s dependency on energy imports, limited land size, and position as a regional finance hub pose interesting challenges to its economic and sustainability ambitions. The introduction of sustainability reporting requirements for publicly listed companies, the development of a national green taxonomy, and stringent building efficiency goals (such as the 80-80-80 plan by 2030 under the Singapore green building masterplan) underscore Singapore's commitment to addressing these issues in an integrated manner. 

Singapore is primarily challenged by two critical carbon-intensive sectors: the significant embodied carbon emissions in the built environment and the energy requirements of data centres, a key enabler of a digitalised future economy. 

The enhancements to Singapore’s sustainability reporting regime mean that disclosures on the sustainability performance of data centres and embodied carbon may face more scrutiny. At the same time, ongoing refinements to science-based target-setting standards, such as the Science Based Targets Initiative’s (SBTi) building sector standard, will reshape how companies in Singapore approach and report their environmental impacts in the built environment, making reporting a vital tool for demonstrating corporate responsibility and resilience. 

Between 2020 and 2060, the world will build an estimated 2.6 trillion square feet of new building floor area (Architecture 2030.) This is a problem because the built environment is responsible for about 42% of annual global emissions. 27% of emissions come from building operations (energy used in heating, cooling, and powering buildings), and 15% are from the embodied carbon of materials (arising from the production, transportation, and installation of building materials). 

Embodied carbon is the emissions associated with materials and construction processes throughout the whole lifecycle of a building or infrastructure. This includes all emissions from material production and construction phases (upfront carbon), maintenance, repair and refurbishment (use-stage embodied carbon), demolition, deconstruction and material processing/disposal (end of life carbon). 

To meet the 1.5°C climate target set by international agreements, all carbon dioxide (CO) emissions from the built environment must be eliminated by 2040. 

In Singapore, almost 40% of emissions over a building’s lifetime are from embodied carbon due to short life cycles stemming from Singapore’s faster rate of urban renewal relative to other cities. To manage this, the SGBMP has also launched an ‘80-80-80' by 2030 plan to green 80% of all buildings by gross floor area, improve energy efficiency of best-in-class green buildings over 2005 levels by 80%, and ensure 80% of new developments are Super Low Energy (SLE) buildings by 2030. 

To establish data baselines, the Singapore Building Carbon Calculator was also launched in 2023 to aid developers and consultants in measuring localised embodied carbon. 

In lieu of this, identifying consistent organisational boundaries around embodied carbon will be a key challenge facing sustainability reporters with multiple assets in multiple jurisdictions. Additionally, sustainability reporters will have to pay attention to how they consolidate their investments in assets in order to align disclosures around embodied carbon with sustainability disclosure standards such as the ISSB Standards.   

Accounting for more than 60% of Southeast Asia’s data centre market, Singapore is home to 87 data centres (DCs), playing a critical role in the region’s digital infrastructure. DCs use significant amounts of energy, accounting for 1.5% of global electricity use. Additionally, energy is needed for more than just operations, as DCs often overheat and require cool air to regulate servers. As global temperatures continue to rise, keeping DCs cool in Singapore's tropical climate presents many challenges. 

In 2019, the government imposed a moratorium on DC development to allow for time to evaluate how to manage the industry’s growth in a sustainable manner. The moratorium was only lifted in 2022 and now, Singapore aims to add at least 300 megawatts of DC capacity in the near term.

To manage this, Singapore is exploring immersion cooling for DCs and launched the Green Data Centre Roadmap (GDCR) in May 2024 to identify pathways for managing operational emissions from data centres. Singapore will also update the Green Mark certification of DCs in Singapore which sets the energy efficiency and sustainability benchmarks for the DC industry. 

Between 2019 and 2023, disclosures of climate risk by Singaporean public companies have significantly increased. Similarly to sustainability reporting, the SGX introduced mandatory climate-related reporting requirements on a ‘comply or explain’ basis starting in 2022. 

This regulatory push has driven companies to enhance their transparency and accountability regarding climate risks. Additionally, there has been a growing recognition among businesses of the importance of sustainability for long-term value creation and investor trust. The adoption of international frameworks like the Taskforce on Climate-Related Financial Disclosures (TCFD) has also provided a structured approach for companies to report on climate risks and opportunities. 

This is driven by the increasing demand from investors for robust climate-related information, pressuring companies to improve their disclosures. These combined efforts have led to a substantial rise in climate risk disclosures among Singaporean public companies during this period. 

ESG at RSM - Singapore

Bennett Wong - Associate Director, ESG, Singapore

As ESG and climate-related regulations evolve at a rapid pace, businesses operating in regional hubs like Singapore must remain agile and proactive. The changing landscape of sustainability reporting, driven by both local mandates and global frameworks, requires companies to integrate ESG considerations into their core strategies. Those that embrace this shift early will not only comply with regulations but will also gain a competitive advantage.

Explore the evolving sustainability regulatory landscape shaping key APAC countries, highlighting significant reforms and emerging policies.