On 27 July 2026, Singapore’s Sustainability Reporting Advisory Committee published draft exposure texts for the country’s own Singapore Sustainability Disclosure Standards (SDS), opening a public consultation that runs until 25 October 2026. If your company has been telling itself that sustainability reporting is a large-company, SGX-listed problem, this consultation is the moment to check that assumption, because the draft standards extend, on a phased basis, to large non-listed companies too.
What the Draft Standards Contain
The draft SDS mirror the two-standard structure used by the International Sustainability Standards Board (ISSB):
| Standard | Based On | Covers |
|---|---|---|
| SFRS S1 | IFRS S1 | General requirements for disclosure of sustainability-related financial information |
| SFRS S2 | IFRS S2 | Climate-related disclosures, including Scope 1, 2 and 3 greenhouse gas emissions |
Singapore’s approach diverges from the ISSB framework in one important respect: the draft standards propose making only the climate-specific standard (SFRS S2) mandatory, while the broader general sustainability standard (SFRS S1) remains voluntary. This is a deliberate, narrower starting point than the full ISSB suite, reflecting feedback that many companies are not yet ready to report on the full range of sustainability topics S1 would otherwise require.
The Timeline That Matters for Large Non-Listed Companies
SGX-listed companies are already on a mandatory climate reporting glide path. The new development is the treatment of large non-listed companies, broadly those with annual revenue above the threshold ACRA has proposed. Under the current draft:
- Mandatory Scope 1 and Scope 2 emissions reporting for large non-listed companies has been pushed back to financial years commencing on or after 1 January 2030 (from an originally floated FY2027 start);
- Scope 3 (value chain) emissions reporting remains voluntary for now, for both listed and large non-listed companies; and
- External assurance over Scope 1 and Scope 2 disclosures has been deferred to FY2032 (from an originally floated FY2029 start).
In other words, the regulator has given large non-listed companies more runway than earlier proposals suggested, but the direction of travel is unchanged: mandatory climate disclosure is coming, and 2030 is closer than it looks once you account for the systems, data collection and internal training a company needs to have in place before the first reporting year actually begins.
Why Smaller Companies Should Still Pay Attention
Even if your company falls well below the “large non-listed company” revenue threshold, three things make this consultation relevant now rather than in 2029:
Supply chain pressure arrives before the regulation does. If your customers are SGX-listed companies or large non-listed companies preparing for FY2030, they will increasingly ask suppliers, including SMEs, for Scope 3 emissions data well before that date, because a listed company’s own Scope 3 disclosure is only as good as the data its suppliers can provide.
Financing and grant conditions are shifting in parallel. Singapore banks and Enterprise Singapore have both been layering sustainability criteria into financing terms and grant conditions. Companies that already have a handle on their emissions profile tend to fare better in these conversations, and it connects directly to the broader compliance obligations businesses already track through the Singapore company compliance calendar.
The consultation window is your chance to shape the outcome. The public consultation runs to 25 October 2026. Trade associations and individual companies can, and do, submit feedback that changes thresholds, timelines and scope before the final standards are issued.
Practical Steps for Directors Now
- Check whether your company, or a parent or subsidiary in your group, meets the “large non-listed company” revenue threshold under the draft rules.
- If you supply goods or services to SGX-listed or large non-listed customers, start a basic inventory of your Scope 1 and Scope 2 emissions now, even informally, so you are not starting from zero when a customer asks.
- Review your carbon tax position if you operate facilities that fall within the Carbon Pricing Act’s scope, since carbon tax and sustainability disclosure obligations increasingly draw on the same underlying emissions data.
- Consider submitting feedback to the consultation through your industry association, particularly on the practicality of the FY2030 timeline for your sector.
- Build sustainability reporting readiness into your existing annual compliance planning rather than treating it as a separate, later project.
How Raffles Corporate Services Can Help
We help Singapore companies keep their statutory and regulatory compliance calendar under control, and as sustainability disclosure obligations phase in, that calendar is only going to get more complex. If you want a clearer picture of where your company sits relative to the draft SDS thresholds and timeline, or you want help coordinating your compliance planning across ACRA, IRAS and this new sustainability regime, our team can help.
Related reading: Singapore Carbon Tax: What Every Business Needs to Know and Singapore Company Compliance Calendar.
Source: ACRA, Public Consultation on Singapore’s Sustainability Disclosure Standards, 27 July 2026 (consultation closes 25 October 2026).
The Editorial Team, Raffles Corporate Services