Singapore has committed to mandatory climate reporting for all listed companies on the Singapore Exchange (SGX). Aligned with the international ISSB standards (IFRS S1 and S2), the requirements are rolling out in phases — with the largest companies already reporting and smaller issuers preparing for their deadlines.
Following an August 2025 announcement by the Accounting and Corporate Regulatory Authority (ACRA) and SGX RegCo, several timelines were extended to give companies more time to prepare. This guide reflects the updated timelines and covers what SGX-listed companies need to know.
Singapore's Climate Reporting Framework
Singapore has adopted a jurisdiction-specific, ISSB-informed approach rather than directly transposing the ISSB standards. The framework is embedded in the SGX Listing Rules, making compliance a listing obligation for all issuers on the exchange.
The requirements cover climate-related disclosures aligned with IFRS S2, including governance, strategy, risk management, and metrics and targets. The materiality approach follows the ISSB's financial materiality lens — focusing on climate risks and opportunities that could affect the company's financial position, rather than the double materiality approach used by the EU's CSRD.
Who Must Report and When? The Updated Phase-In Timeline
SGX groups listed issuers into three categories based on market capitalisation. Following the August 2025 timeline extension, here are the current deadlines:
Scope 1 and Scope 2 GHG Emissions
All SGX-listed companies must report Scope 1 and Scope 2 greenhouse gas emissions from financial years commencing on or after 1 January 2025 (FY2025).
Full ISSB-Based Climate-Related Disclosures (CRD)
| Category | Entities | Full CRD Required From |
|---|---|---|
| Category 1 | Straits Times Index (STI) constituents (top 30 SGX-listed companies) | FY2025 |
| Category 2 | Non-STI listed companies with market cap ≥ S$1 billion | FY2028 |
| Category 3 | Non-STI listed companies with market cap < S$1 billion | FY2030 |
Scope 3 GHG Emissions
- STI constituents: Mandatory from FY2026
- All other listed companies: Voluntary until further notice
External Assurance
- Limited assurance on Scope 1 and 2 emissions: Deferred to FY2029 for all listed companies
- Large non-listed companies (covered under separate ACRA requirements): Limited assurance deferred to FY2032
Large Non-Listed Companies
ACRA has also introduced climate reporting requirements for large non-listed companies. ISSB-based CRD (including Scope 1 and 2 emissions) are deferred to FY2030 for these entities, with Scope 3 remaining voluntary.
What the SGX Climate Report Must Include
For companies required to make full ISSB-based climate-related disclosures, the reporting follows the same four-pillar structure as IFRS S2:
Governance
Describe the board's oversight of climate-related risks and opportunities. Include how climate considerations are integrated into the entity's governance structure, decision-making, and management responsibilities.
Strategy
Identify the climate-related risks and opportunities that could affect the company's business model, strategy, and financial planning. This includes assessing the resilience of your strategy under different climate scenarios.
Risk Management
Explain how climate-related risks are identified, assessed, prioritised, and monitored. Describe how these processes integrate with the entity's overall risk management framework.
Metrics and Targets
Report quantitative metrics including GHG emissions (Scope 1, 2, and where applicable, Scope 3), climate-related targets, and progress against those targets. Include industry-specific metrics where relevant.
The Materiality Assessment for SGX Climate Reporting
The materiality assessment is at the core of determining which climate risks and opportunities your company needs to disclose. Under the ISSB-aligned framework, materiality is assessed from a financial perspective: a climate matter is material if it could reasonably be expected to influence investor decisions.
How to Approach the Assessment
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Map your climate risk landscape. Consider physical risks (flooding, extreme heat, water stress), transition risks (carbon pricing, regulatory changes, shifting consumer preferences), and opportunities (clean energy, efficiency gains, new products and markets).
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Evaluate sector-specific risks. Singapore's economy spans financial services, real estate (REITs), shipping, technology, and commodities. Each sector has distinct climate exposures. The ISSB's industry-based guidance derived from SASB standards provides useful starting points — see our detailed guides for financial services and real estate & REITs.
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Assess financial materiality. For each identified risk or opportunity, determine whether it could affect your cash flows, access to finance, or cost of capital. Consider short, medium, and long-term time horizons.
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Document your process. Even though external assurance is deferred to FY2029, building a documented, repeatable assessment process now will reduce the burden later and strengthen stakeholder confidence.
The SME Sustainability Reporting Programme
Singapore's government-backed SME Sustainability Reporting Programme (SME SRP) is driving adoption among non-listed small and medium enterprises. While not directly tied to the SGX listing rules, the programme creates additional demand for structured materiality assessment capabilities across the market.
Practical Steps to Prepare
For Category 2 Companies (Full CRD from FY2028)
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Begin with Scope 1 and 2 data. Since emissions reporting is already mandatory from FY2025, ensure your GHG inventory is robust. Use this as a foundation for broader climate disclosures.
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Conduct a gap analysis against IFRS S2. Compare your current sustainability disclosures against the full ISSB requirements. Identify where you need to build new processes — particularly around scenario analysis and risk management integration.
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Run a structured materiality assessment. Identify which climate risks and opportunities are financially material to your business. This assessment will drive what you disclose and how you prioritise your preparation efforts.
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Engage your board. Climate governance is a core disclosure requirement. Ensure your board has the knowledge and structures to oversee climate-related matters effectively.
For Category 3 Companies (Full CRD from FY2030)
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Don't delay until 2030. The Scope 1 and 2 reporting requirement already applies from FY2025. Use this as a stepping stone toward full compliance.
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Learn from Category 1 and 2 reporters. By the time your deadline arrives, there will be several years of SGX climate reports to benchmark against. Study how peers in your sector approach their disclosures.
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Build internal capabilities. Invest in sustainability data collection, cross-functional coordination, and climate risk literacy across your organisation.
How Materiality Master Can Help
Materiality Master offers a structured, step-by-step workflow for conducting ISSB-aligned materiality assessments. The platform helps you systematically identify climate-related risks and opportunities, evaluate their financial materiality, and produce documented outputs ready for your SGX climate report.
For consulting firms serving multiple SGX-listed clients across different categories, the multi-client dashboard enables efficient, consistent delivery at scale. Learn more about SGX materiality assessments or see pricing and plans.
Frequently Asked Questions
Does SGX require double materiality?
No. Singapore's framework follows the ISSB's financial materiality approach — assessing how climate-related matters affect the company's financial position. It does not require impact materiality (how the company affects the environment), which is the additional dimension in the EU's double materiality framework.
Are Scope 3 emissions mandatory for all SGX-listed companies?
Currently, Scope 3 is mandatory only for STI constituents from FY2026. For all other listed companies, Scope 3 reporting remains voluntary. The timeline for extending Scope 3 requirements to other categories has not been confirmed.
What assurance requirements apply?
External limited assurance on Scope 1 and 2 GHG emissions has been deferred to FY2029 for all SGX-listed companies. This gives issuers time to mature their data collection and reporting processes before third-party verification is required.
What about non-listed companies in Singapore?
Large non-listed companies will be required to report ISSB-based climate disclosures from FY2030 under ACRA requirements. Scope 3 emissions remain voluntary for non-listed entities, and limited assurance is deferred to FY2032.
