ACRA and SGX RegCo conducted public consultations following the International Sustainability Standards Board's (ISSB) release of the first two International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards. As a result, Singapore will implement phased mandatory Climate-related Disclosures (CRD), including Scope 1 and Scope 2 Greenhouse Gas (GHG) emissions. This requirement will apply to:

  • Publicly listed companies (PLCs) starting from FY2025 and large non-listed companies (NLCs) from FY2027.
  • Mandatory external limited assurance on Scope 1 and Scope 2 GHG emissions from FY2027 for PLCs and FY2029 for large NLCs.

Refer to the diagram below for a detailed overview of the climate reporting and assurance timeline:

Financial Year

2024

 

 

 

PLC:

  • All primary components of the Sustainability Report ("SR")(FAQ1) are to be disclosed on a "comply or explain" basis.
     
  • Mandated climate reporting, based on the Task Force on Climate-Related Financial Disclosures ("TCFD"), applies to the following industries: (a) Financial industry; (b) Agriculture; food, and forest products industry; (c) Energy industry; (d) Materials and buildings industry; or (e) Transportation industry.

2025

 

 

PLC:

  • Report IFRS S2-aligned CRD (FAQ2), including Scope 1 and Scope 2 GHG emissions.
     
  • Disclose other primary components of the SR on a "comply or explain" basis.
     
  • Issue the SR no later than 4 months after the end of the financial year.
     
  • If conducting external assurance (FAQ3), issue the SR no later than 5 months after the end of the financial year.

2026

 

 

PLC:

  • Mandatory disclosure of all primary components of the SR.
  • Issue the SR and Annual Report concurrently. 
     

Large PLC (FAQ4):

  • Report Scope 3 GHG emissions (Roadmap to be confirmed).

2027

 

 

PLC:

  • Conduct external limited assurance on Scope 1 and Scope 2 GHG emissions (further public consultation planned).
     

Large NLC (FAQ5):

  • Report IFRS S2-aligned CRD, including Scope 1 and Scope 2 GHG emissions, unless exempted (FAQ6).

2029

 

 

PLC:

  • Conduct external limited assurance on Scope 1 and Scope 2 GHG emissions.
     

Large NLC:

  • Report IFRS S2-aligned CRD, including Scope 1 and Scope 2 GHG emissions, unless exempted. (Roadmap to be confirmed)

FAQ1: What are the primary components of SR?

The six primary components of an SR are:

(1) Material ESG factors; 

(2) CRDs;

(3) Policies, practices, and performance; 

(4) Targets; 

(5) Sustainability reporting framework; and 

(6) Board statement and associated governance structure for sustainability practices.
 

FAQ2: Is IFRS S1 implemented as well?

Companies should refer to CRD-relevant sections in IFRS, such as the conceptual foundations and general requirements. A separate public consultation on the implementation of IFRS S1 beyond climate-related matters will be conducted.
 

FAQ3: What are the required scope and standards for external assurance?

The scope of external assurance for the SR may include various aspects, such as materiality assessments, data collection processes, and compliance with the SR framework or listing rules. Companies are encouraged to gradually expand the coverage of external assurance in subsequent years.

External assurance should be performed in accordance with either:

(a) A Singapore standard equivalent to ISSA 5000, such as ISAE 3000, ISAE 3410, SSAE 3000, or SSAE 3410 (Singapore equivalent), as ISSA 5000 is currently under development; or

(b) SS ISO 14064-3.
 

FAQ4: What is the threshold for larger PLCs?

The threshold has not yet been announced. However, it is expected to be determined based on a specific level of market capitalisation.
 

FAQ5: What are large NLCs?

Large NLCs are companies with an 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.
 

FAQ6: What are the exemptions from mandatory CRD for large NLCs?

A company is exempt from reporting if the parent company reports CRD using ISSB-aligned standards (e.g., ESRS) and the company is within the scope of reporting. It is exempt from reporting until FY2029 if the parent company reports CRD using other frameworks (e.g., TCFD, GRI) and the company is within the scope of reporting. NLCs exempted from reporting will also be exempted from the assurance requirement.

To find out more about how RSM’s ESG Practice team can help you on this journey, please contact our specialists: