Sustainability reporting has moved from an SGX-listed company concern to a Singapore-wide compliance topic. From FY 2025 onwards, the Singapore Exchange (SGX) requires all listed issuers to publish climate-related disclosures aligned with the International Sustainability Standards Board (ISSB) framework. Large non-listed companies follow on a phased timeline. Suppliers to listed customers are increasingly being pulled into scope-3 emissions reporting requests.
This guide explains what Singapore’s sustainability reporting regime looks like in 2026, who is in scope when, what disclosures are required, and how SMEs that are not directly in scope still find themselves preparing data for customer requests.
1. The Regulatory Architecture
Singapore’s sustainability reporting framework rests on four pillars:
- SGX Mainboard Rules 711A, 711B, and Practice Note 7.6 — mandatory sustainability reporting for all listed issuers.
- ISSB IFRS S1 and IFRS S2 — adopted by SGX as the disclosure baseline from FY 2025.
- ACRA-led requirements for large non-listed companies — phased adoption announced under the Sustainability Reporting Advisory Committee (SRAC) recommendations, accepted by the government in 2024.
- Carbon Tax Act 2018 — separate but related reporting regime for facility-level emissions above the 25,000 tCO2e threshold.
For everyday corporate operators, the most important shift is that ISSB S2 (climate) is now the mandatory floor — replacing the older TCFD-style narrative disclosures with quantitative, audit-ready data.
2. SGX-Listed Company Requirements — FY 2025 Onwards
2.1 Climate Disclosures Mandatory for All Listed Issuers
From FY 2025, every SGX-listed issuer must publish climate-related disclosures aligned with IFRS S2. Sector-specific guidance applies to financial services, agriculture/food/forest products, energy, materials/buildings, and transportation, which became mandatory earliest.
2.2 Scope 1, 2, and (Phased) Scope 3 Emissions
Listed issuers must disclose:
- Scope 1 — direct emissions from owned or controlled sources (e.g. on-site combustion, company vehicles).
- Scope 2 — indirect emissions from purchased electricity and energy.
- Scope 3 — indirect emissions across the value chain. Reporting on Scope 3 has been phased in, with the largest issuers reporting from FY 2026 and broader application thereafter.
Methodologies must align with the GHG Protocol. The challenge for most issuers is Scope 3 — it requires data from suppliers, customers, and downstream users that most companies have never collected systematically.
2.3 Assurance Requirements
External limited assurance over Scope 1 and Scope 2 emissions data became mandatory from FY 2027. Reasonable assurance (the higher audit standard) is on the longer-term roadmap. Assurance providers must be accredited under the Singapore Accreditation Council scheme or equivalent.
3. Large Non-Listed Companies — Phased Adoption
The Singapore government, accepting SRAC’s 2024 recommendations, has committed to phasing ISSB-aligned sustainability reporting onto large non-listed companies from FY 2027. The thresholds (subject to final ACRA rule-making) target:
- Companies with annual revenue ≥ S$1 billion
- Companies with total assets ≥ S$500 million
The first reporting cycle for in-scope non-listed companies will likely be the FY 2027 financial year, with reports published in 2028. Smaller companies remain outside the mandatory regime but should plan for indirect impact through customer Scope 3 requests.
4. Carbon Tax Compliance — Separate but Related
Singapore imposes a carbon tax on emissions facilities above 25,000 tCO2e per year under the Carbon Pricing Act 2018. For 2024 and 2025, the rate stood at S$25/tCO2e, rising to S$45 in 2026–2027 and on track for S$50–80 by 2030.
Carbon tax reporting is plant-level and quantitative — verified by a registered verifier under the National Environment Agency (NEA) scheme. The data feeds into both the carbon tax filing and the company’s sustainability disclosures.
5. The Indirect Impact on SMEs — Customer Scope 3 Requests
SMEs that are not in direct scope still face downstream pressure. When a listed customer prepares Scope 3 emissions reporting, it requests emissions data from major suppliers. Failure to provide credible data risks losing the contract.
Common SME-side asks:
- Annual Scope 1 and Scope 2 emissions, ideally with methodology disclosed.
- Energy consumption by source (grid electricity, on-site renewables, diesel, etc.).
- Net-zero commitments and interim targets.
- Supplier code-of-conduct attestations.
For SMEs, even a basic in-house emissions tracker (Excel-based, vendor-supplied, or built on grant-supported tooling) is now table stakes for B2B contracts with listed customers.
6. Practical Implementation Steps
Step 1 — Materiality Assessment
Identify the climate-related risks and opportunities most relevant to the business. For an F&B operator the material topics differ from those of a logistics company. ISSB S1 requires materiality to be applied through an “enterprise value” lens — what affects financial outcomes.
Step 2 — Build the Data Inventory
Compile activity data for Scope 1 and Scope 2 (electricity bills, fuel receipts, refrigerant gas records). Use grid emission factors from the Energy Market Authority (EMA) for Scope 2.
Step 3 — Set Targets and Disclose
Set absolute or intensity-based reduction targets. Disclose the methodology, baseline, and assumptions. Targets without a credible plan are increasingly called out by readers.
Step 4 — Governance Disclosure
ISSB S1/S2 require disclosure of board oversight, management responsibility, and how climate considerations enter strategy and capital allocation. Even small companies should document board-level discussion.
Step 5 — Independent Assurance (When Required)
Engage a Singapore Accreditation Council-accredited assurance provider for Scope 1 and Scope 2 limited assurance. For most non-listed companies, this is voluntary today but expected to become mandatory progressively.
7. Government Support and Grants
Several support schemes ease the cost of building sustainability capability:
- Productivity Solutions Grant (PSG) — funds pre-approved sustainability software including emissions trackers and ESG reporting tools.
- Enterprise Singapore’s Enterprise Sustainability Programme — training and capability-building for SMEs.
- Sustainability Bond/Loan Grant Scheme (administered by MAS) — for issuers of green and sustainability-linked debt.
- SkillsFuture Singapore-supported courses on sustainability reporting and carbon accounting.
8. The Audit Layer — How Sustainability Data Affects Financial Statements
Two cross-overs deserve attention:
- Provisions and impairments. Climate-related risks may trigger impairment of long-lived assets under FRS 36. Coal-related infrastructure, emissions-intensive production lines, and properties in physical-risk zones are common candidates.
- Going concern. Auditors are required to consider climate-related risks when assessing going concern. SGX-listed boards now routinely include climate risk in going-concern memos.
For more on annual reporting interaction, see our ACRA Annual Return guide.
9. Common Pitfalls
- Disclosure without data. Narrative climate commentary without quantitative emissions data is no longer sufficient.
- Greenwashing exposure. Unsupported “carbon neutral” or “net zero” claims attract regulator scrutiny under the new Code on Environmental Claims (Advertising Standards Authority of Singapore).
- Outsourcing the assessment. Boards that delegate ISSB compliance entirely to consultants miss the governance integration the standards demand.
- Ignoring the Scope 3 wave. SMEs treating sustainability as “not for us” find themselves blocked from new tenders.
10. Conclusion
Sustainability reporting in Singapore is no longer a listed-company concern alone. The combination of SGX mandatory ISSB adoption, the carbon tax framework, and the phased extension to large non-listed companies — alongside customer-driven Scope 3 requests — means most growing businesses need a credible emissions baseline within the next 12 to 24 months.
If you would like help scoping a sustainability reporting baseline, identifying relevant grants, or coordinating assurance, write to [email protected]. We work with sustainability specialists and can integrate the data points back into your accounting and tax workflow.
— The Editorial Team, Raffles Corporate Services