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Climate reporting refers to the public disclosure by companies of information on their greenhouse gas (GHG) emissions, climate-related risks, opportunities, governance, strategy, and targets relating to sustainability. Listed companies in Singapore were required to report climate-related information on a "comply-or-explain" basis from the financial year 2022. A year later, climate reporting became mandatory for companies in the financial, agriculture, food and forest products, and energy sectors. The materials and buildings and transportation sector were added to this list in 2024. Other listed companies continued to report on a "comply-or-explain" basis, reflecting Singapore's measured transition towards full mandatory climate reporting aligned with global standards.
In February 2024, the Accounting and Corporate Regulatory Authority (ACRA) and SGX RegCo announced a phased roadmap requiring all listed companies to disclose their Scope 1 and Scope 2 GHG emissions from the financial year beginning 2025. Reporting on Scope 3 emissions and external assurance requirements were to be made in later stages. The roadmap extended beyond listed entities, bringing large non-listed companies within the scope in later phases. Companies in Singapore are required to make the climate-related disclosure in line with the standards set by the International Sustainability Standards Boards (ISSB) i.e. IFRS S1 on general sustainability-related disclosures and IFRS S2 on climate-related disclosures.
In an announcement/press release made by ACRA and SGX RegCo in August 2025, some of the timelines for implementing climate reporting (including external assurance) requirements have been extended to facilitate listed companies and large non-listed companies (Large NLCos) in developing reporting capabilities.
Who Must Comply?
The climate reporting requirement has been implemented in stages and applies to the following categories of companies as per the ACRA and SGX Reg Co announcement:
"1. Listed companies, with the following 3 – tier structure to phase reporting obligations –
a. Straits Times Index (STI) constituents,
b. Non-Straits Times Index (Non-STI) constituent listed companies with a market capitalisation of SGD 1 billion and above and
c. Non-Straits Times Index (Non-STI) constituent listed companies with a market capitalisation of less than SGD 1 billion.
2. Large non-listed companies (NLCos) having annual revenue of minimum SGD 1 billion and total assets of minimum SGD 0.5 billion."
Key Compliance Obligations and Timelines
The latest update from ACRA and SGX RegCo sets out how the revised climate reporting timelines will apply across various categories of companies.
| Entity | Scope 1 & 2 Reporting | Scope 3 Reporting | Other ISSB-based Disclosures | External Assurance (Scope 1 & 2) |
| STI constituents | FY2025 | FY2026 | FY2025 | FY2029 (Previously FY2027) |
| Non-STI listed ≥ SGD 1B | FY2025 | Voluntary(Previously FY 2026) | FY2028(Previously FY 2025) | FY2029(Previously FY2027) |
| Non-STI listed < SGD 1B | FY2025 | Voluntary(Previously FY 2026) | FY2030(Previously FY 2025) | FY2029(Previously FY 2025) |
| Large NLCos | FY2030(Previously FY2027) | Voluntary(Previously Voluntary (no earlier than FY 2029) | FY2030(Previously FY2027) | FY2032(Previously FY2029) |
For Straits Times Index (STI) companies, the overall timeline remains largely unchanged. The key change is that the deadline for obtaining external limited assurance on Scope 1 and Scope 2 data has been extended from FY 2027 to FY 2029. Companies will continue to report Scope 1 and Scope 2 GHG emissions and other ISSB-based climate disclosures from FY 2025, with Scope 3 emissions from FY 2026.
Non-STI listed companies with a market capitalisation of at least SGD 1 billion will follow a similar path for reporting Scope 1 and Scope 2 emissions from FY 2025. However, Scope 3 reporting, which was to begin from FY 2026, will now be voluntary until further notice. The ISSB-aligned disclosures will become mandatory from FY 2028, with external assurance requirements starting from FY 2029.
For smaller non-STI listed companies (those valued below SGD 1 billion) Scope 1 and Scope 2 emission reporting still begins in FY 2025, but Scope 3 reporting has become voluntary. However, ISSB-based disclosures are only required from FY 2030 while assurance obligations will take effect in FY 2029.
Large non-listed companies (NLCos) with at least SGD 1 billion in annual revenue and SGD 500 million in total assets will also get more time. Their starting date for Scope 1 and Scope 2 emission reporting and ISSB-aligned climate reporting has been extended from FY 2027 to FY 2030, with external assurance now required only from FY 2032. Scope 3 reporting will continue to be voluntary.
Action Items for Compliance Teams
The changes make reporting credible, fair, and sustainable. The extended timelines enable businesses which lack sufficient infrastructure to get prepared for the climate reporting. It provides an opportunity for companies to establish robust systems and governance processes rather than delay action. We have highlighted a few of the tasks that compliance teams should focus on:
- Determine the reporting category of the business, as it defines the applicable disclosure obligations and assurance deadlines.
- Prepare a compliance roadmap based on the ACRA and SGX RegCo announcement by setting key milestones for reporting. Build internal checkpoints to track progress and preparedness.
- Develop strong data management systems by putting in place processes and tools to measure, validate, and report consistently across operations. Adopt standard methods and maintain records for future assurance
- Train compliance teams on the ISSB standards and disclosure requirements through guidance provided by Enterprise Singapore (EnterpriseSG) and the Sustainability Reporting Grant by the Singapore Economic Development Board (EDB).
- Include climate reporting within the company's governance framework at the highest level. Integrate climate disclosure processes into existing audit and risk management processes.
- Monitor guidance from ACRA, SGX RegCo, Enterprise Singapore and the EDB. Review internal policies regularly to ensure alignment with updated ISSB standards and national sustainability objectives and any other regulatory requirements.
Additional Best Practices for Businesses
- Adapt to environment-friendly actions eg. waste minimisation and recycling, switching to natural gas for electricity generation, etc. (for guidance please refer to https://www.mse.gov.sg/take-action/organisations/)
- Align business practices to the Singapore green plan.
Conclusion
The revised timeline for climate reporting by ACRA and SGX RegCo is a balanced and reasonable approach based on feedback received from the Singapore Business Federation and other sources. By utilising the extended timelines, businesses can focus on developing reliable data systems and governance frameworks before the mandatory compliance kicks in. While the extension benefits smaller businesses and non-listed companies, the obligations for the STI constituent listed companies remain the same, and the Scope 1 and Scope 2 GHG emissions disclosure continues to be the fundamental obligation for every listed company from FY 2025. Hence, businesses should start early to develop their climate reporting capabilities.
How Komrisk can help?
Managing compliance is not easy, especially with the rapid evolution of environmental, social, and governance (ESG) standards. Komrisk, our technology-enabled compliance management solution, can help in streamlining the process.
Komrisk helps organisations in Singapore and beyond simplify their regulatory and internal compliance workflows. From ESG and climate-related disclosures under ACRA and SGX RegCo to broader governance and risk frameworks, Komrisk enables you to monitor, manage, and report compliance obligations efficiently. The platform supports custom checklists, automated task tracking, and data-driven dashboards, ensuring transparency and accountability across teams. In an era where sustainability and transparency create corporate trust, Komrisk empowers businesses to turn compliance from a reactive task into a strategic advantage.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
