TRW & Co · Trade, Regulation & ESG
Sustainability Reporting in Singapore
Sustainability reporting in Singapore is a listing obligation for every SGX issuer and a growing expectation for large private companies and borrowers. Climate disclosures are moving to ISSB-aligned standards on a timetable revised in August 2025. This guide explains what is fixed, what depends on your category and how to build a report that stands up to scrutiny.
Key pointWhatever your category, every SGX-listed issuer must report Scope 1 and Scope 2 emissions for financial years beginning in 2025; everything else in the climate timetable now depends on STI status and market capitalisation, so recheck your category each year.
At a glance
Rules 711A and 711B
Every SGX-listed issuer must publish an annual sustainability report covering material ESG factors, climate disclosures, policies, targets, framework and a board statement.
Scope 1 and 2 fixed
All listed issuers must report Scope 1 and Scope 2 emissions for financial years beginning in 2025, regardless of the staged timetable for other disclosures.
August 2025 update
SGX and ACRA staged ISSB-aligned disclosures and Scope 3 by STI status and market-cap tier, deferred external assurance to FY2029, and extended timelines for large non-listed companies.
Large non-listed threshold
The 2024 roadmap defined large non-listed companies as those with annual revenue of at least S$1 billion and total assets of at least S$500 million.
Board owns the report
Practice Note 7.6 places ultimate responsibility on the board, expects an internal review of the reporting process and requires a board statement.
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What sustainability reporting in Singapore covers
Sustainability reporting in Singapore means the annual public disclosure of how a company identifies and manages its material environmental, social and governance factors, and, increasingly, a structured set of climate disclosures aligned with the International Sustainability Standards Board (ISSB) standards. For listed issuers it is a listing obligation with a fixed format. For other companies it is driven by lenders, investors, customers and, for the largest non-listed companies, a planned statutory regime.
The work sits between finance, operations, legal and the board. Data must be collected from sites and suppliers, methodologies must be documented, targets must be defensible and the board must approve a statement it actually understands. The legal risk is not only missing a requirement; it is publishing statements that later prove inaccurate or that imply commitments the company cannot meet.
The timetable changed in 2025, which means many reporting plans written in 2024 are now out of date. This guide sets out what is fixed, what depends on your category and how to build a report that can withstand scrutiny.
The legal and regulatory framework
For SGX-listed issuers, the obligation comes from the Listing Rules, principally Rule 711A, which requires an annual sustainability report, and Rule 711B, which sets its primary components. The detail is in Practice Note 7.6, the Sustainability Reporting Guide, which explains materiality, the board statement, internal review and the treatment of climate disclosures.
The primary components are: material ESG factors and why they are material; climate-related disclosures; policies, practices and performance; targets; the reporting framework used; and a board statement. Issuers must also apply a sustainability lens to governance, which links the report to the Code of Corporate Governance 2018 and to the board's oversight duties.
Climate reporting has moved on two tracks. SGX has progressively required climate disclosures from listed issuers since FY2022, beginning on a comply-or-explain basis and making them mandatory for higher-risk industries. Separately, ACRA and SGX worked with the Sustainability Reporting Advisory Committee on a roadmap for ISSB-aligned climate reporting by listed companies and large non-listed companies.
The 2024 roadmap and the 25 August 2025 update
The roadmap announced in February 2024 required listed issuers to make ISSB-aligned climate disclosures from FY2025, with Scope 3 emissions to follow, and extended mandatory climate reporting to large non-listed companies, defined as those with annual revenue of at least S$1 billion and total assets of at least S$500 million. External limited assurance on Scope 1 and Scope 2 emissions was to be phased in later.
On 25 August 2025, SGX and ACRA announced a revised and staged timetable. All listed issuers must still report Scope 1 and Scope 2 greenhouse gas emissions for financial years beginning in 2025. The start dates for the fuller ISSB-aligned disclosures and Scope 3 reporting now depend on the issuer's category, including whether it is a Straits Times Index constituent and its market capitalisation tier, external limited assurance on Scope 1 and Scope 2 emissions was deferred to FY2029 for all listed issuers, and the timeline for large non-listed companies was extended to FY2030.
| Requirement | Who | Status in 2026 |
|---|---|---|
| Annual sustainability report with board statement | All SGX-listed issuers | Standing obligation under Rules 711A and 711B |
| Scope 1 and Scope 2 emissions | All SGX-listed issuers | Required for financial years beginning in 2025 |
| Fuller ISSB-aligned climate disclosures | Listed issuers by category | Staged by STI status and market-cap tier |
| Scope 3 emissions | Listed issuers by category | Later and staged; check your category |
| External limited assurance | All SGX-listed issuers | Deferred to FY2029 |
| Mandatory climate reporting | Large non-listed companies | Timeline extended in August 2025 |
| Climate and environmental risk management | MAS-regulated financial institutions | MAS guidelines, plus transition planning expectations |
The practical consequence is that each issuer should check its category against the August 2025 announcement at a fixed point each year and record the conclusion. STI membership and market capitalisation change, and with them the start date of certain disclosures.
The financial sector overlay
Banks, insurers and asset managers face a further layer. MAS's Guidelines on Environmental Risk Management set expectations on governance, risk management and disclosure of environmental risk, and MAS has issued guidelines on transition planning for financial institutions. The Singapore-Asia Taxonomy gives a common language for green and transition activities. Corporates borrowing from these institutions increasingly receive data requests that mirror these expectations.
Core metrics, training and timing
SGX has published a list of core ESG metrics that issuers are encouraged to use as a starting point, covering areas such as emissions, energy, water, waste, workforce diversity, health and safety, board composition and anti-corruption. They are not a substitute for a materiality assessment, but reviewers expect an explanation where a common metric is omitted.
SGX also requires directors to undergo sustainability training, which matters for new appointees, and expects the sustainability report to be issued within the deadline set by the Listing Rules relative to the financial year end. The company secretary should hold the training records and the publication timetable as part of the governance file. Our company secretarial and statutory filings team can integrate these into the annual compliance calendar.
Sustainability reporting in Singapore for non-listed companies and borrowers
Private companies often assume sustainability reporting in Singapore is a listed-company issue. In practice, many of them already report, because a bank, an investor or a multinational customer requires it. Sustainability-linked loans set key performance indicators that must be measured and reported, often with external verification. Private equity and venture investors ask portfolio companies for ESG data to meet their own fund disclosures. Large customers push emissions questionnaires down the supply chain because they need Scope 3 data for their own reports.
The contractual route can be more demanding than the listing route. A loan agreement may impose a margin step-up if a target is missed or a report is late, and a customer contract may treat a false sustainability statement as a breach. These consequences arise under contract law rather than SGX rules, so legal review of the commitments matters as much as the data.
For companies close to the large non-listed thresholds, now is the time to build data systems. Even with the extended timeline, the effort needed to produce reliable emissions data, documented methods and board oversight is the same, and doing it voluntarily first gives management time to fix weaknesses before obligations bite. Investors in private equity transactions increasingly test these capabilities in due diligence.
The key reporting decisions
Good sustainability reporting in Singapore depends on a handful of decisions made early in the cycle. Each has legal as well as technical consequences.
Category and scope
Confirm which requirements apply to your category for the year, and define the reporting entity and organisational boundary. A boundary that differs from the financial statements must be explained.
Materiality
Identify material ESG factors through a documented process with stakeholder input. Practice Note 7.6 expects the reasons for materiality to be explained, and the assessment to be reviewed periodically.
Framework choice
Choose and name the reporting framework, typically ISSB standards for climate and GRI or similar for wider ESG. Mixing frameworks without explanation creates gaps reviewers notice.
Targets and transition plans
Targets become public commitments. Set them with an evidence base and a pathway, and describe dependencies honestly, because later revisions will be compared against the original statement.
Scope 3 approach
Where Scope 3 is not yet required, decide whether to disclose qualitatively, publish estimates or wait. Early estimates often change substantially and become baselines others compare against.
Assurance
Decide whether to seek voluntary assurance before it is mandatory. Early assurance tests data controls and reduces the risk of restatement once mandatory assurance begins.
The sustainability report is a disclosure document. It should be prepared with the same discipline, review and evidence as any other statement investors rely on.
The reporting cycle, step by step
The sequence below suits a listed issuer preparing its annual report. Non-listed companies preparing for future obligations or responding to lender requests can use the same structure.
- Confirm requirements. Check category, framework and any SGX or ACRA updates, and record the applicable requirements in a reporting plan approved by management.
- Refresh materiality. Review material factors against business changes, stakeholder feedback and peer practice, and document why each factor is or is not material.
- Collect and control data. Gather Scope 1 and 2 data from fuel and electricity records at every site, plus other metrics, with documented methods, emission factors and owner sign-offs.
- Draft with legal review. Draft disclosures, then review claims, targets and forward-looking statements for accuracy, consistency with financial statements and appropriate qualification.
- Internal review. Carry out the internal review of the reporting process that Practice Note 7.6 expects, typically through internal audit, and close out findings.
- Board consideration. Give the board a pack covering material factors, data controls, estimates and open issues, and minute its discussion before it approves the board statement.
- Assure and publish. Complete any external assurance, publish within the SGX deadline and file supporting evidence so the next cycle starts from a clean base.
Documents and evidence behind the report
When a disclosure is challenged, by a regulator, an investor or a journalist, the company's defence is its evidence file. That file should include:
- The reporting plan recording category, applicable requirements and framework choices for the year.
- The materiality assessment, stakeholder inputs and the reasons for including or excluding each factor.
- Emissions inventories with boundaries, activity data, emission factors and calculation workbooks.
- Policies, target-setting papers and the evidence base for any transition plan or net-zero commitment.
- Internal review or internal audit reports and evidence that findings were addressed.
- Board and committee papers and minutes showing how the board considered the report.
- Assurance engagement letters and reports, where assurance was obtained.
- A claims register linking each public sustainability statement, including marketing, to its supporting evidence.
Keep one claims register. Statements in the sustainability report, investor presentations, product marketing and tender responses often drift apart. A single register that links each claim to its evidence and approver is the simplest way to keep sustainability reporting in Singapore consistent with what sales and investor relations teams are saying.
Risks and common mistakes
Planning against an outdated timetable
Many issuers built their plans on the February 2024 roadmap. The 25 August 2025 update changed start dates for several requirements, depending on category. Plans that were not refreshed may commit resources to disclosures not yet required, or, more seriously, overlook the fixed Scope 1 and 2 requirement for all listed issuers. Re-run the gap analysis against the current announcement, record the result, and assign someone to monitor SGX and ACRA updates during the year.
A board statement without board engagement
Practice Note 7.6 makes the board responsible for the sustainability report. Boards that approve a statement without seeing how material factors were chosen, how data was controlled or what estimates were used struggle to show genuine oversight if the report is later questioned. Minutes should record discussion and challenge, not just approval. Our ESG governance team helps design the board process and briefing packs.
Targets that become liabilities
A published net-zero or reduction target is a forward-looking statement. If it is not supported by a credible pathway, or if dependencies such as technology, policy or carbon credits are not disclosed, it may later be criticised as misleading. Use clear qualifications, explain assumptions, report progress honestly and explain any change to a target rather than quietly dropping it.
Greenwashing in consumer-facing claims
Claims made to consumers are assessed under the Consumer Protection (Fair Trading) Act 2003. CCS has issued a guide on clear and accurate product claims that expects claims to be truthful, clear, complete and supported by evidence. Marketing copy that goes beyond the sustainability report creates inconsistency that is easy to expose. Review consumer claims against the same evidence as the report.
Restating figures without explanation
Early climate data is often revised as methods improve. Restatements are acceptable when explained, but silent changes to baselines undermine trust and can raise disclosure concerns. Keep methodology notes, explain what changed and why, and show the effect on prior figures. Where an error is material, consider whether it needs correcting before the next report.
Boundaries that do not match the financial statements
ISSB-aligned reporting expects climate information to relate to the same reporting entity as the financial statements. Groups that report emissions only for wholly owned Singapore sites, while consolidating regional joint ventures and leased facilities financially, create a mismatch that analysts quickly notice. Decide early whether the operational control, financial control or equity share approach is used for emissions, explain it, and show which entities and sites fall inside and outside the boundary. Changes to the boundary following acquisitions or disposals should be disclosed with their effect on comparatives, so that apparent reductions are not simply the result of selling a high-emitting business.
The cross-border angle
Sustainability reporting in Singapore rarely stands alone for regional groups. A Singapore-listed company with operations in Bangladesh, China or Vietnam must collect data from those sites to the standard its Singapore report requires, even where local law asks for less.
Groups with European operations or customers may also be affected by EU sustainability reporting and due diligence rules, which have their own scope tests and timetables, and UK-linked groups face UK disclosure expectations. Because Singapore has aligned its climate reporting with ISSB standards, much of the work can be shared, but scope, boundaries and assurance requirements differ. China has introduced its own sustainability disclosure guidelines for listed companies, and the UAE has its own climate-related requirements.
Where a foreign parent already reports, the Singapore issuer can use group systems and data but must meet its own SGX obligations for its own reporting perimeter, with its own board statement. We coordinate with counsel in the relevant jurisdictions so that one data set supports several reports without conflicting statements.
How TRW & Co helps
We advise boards, company secretaries, sustainability and finance teams on sustainability reporting in Singapore. Where Singapore court or tribunal representation is required, we work alongside Singapore-qualified counsel.
Requirements and gap analysis
We confirm which SGX, ACRA and MAS requirements apply to your category and year, and produce a gap analysis and reporting plan the board can approve.
Disclosure review
We review draft reports, targets, transition plans and forward-looking statements for accuracy, consistency with financial reporting and appropriate qualification.
Board and governance support
We prepare board briefing packs and terms of reference, and work with our corporate governance team so oversight is documented properly.
Claims and contracts
We review marketing and tender claims, and align green finance and sustainability-linked loan terms with what the report actually discloses.
For listed issuers, we also coordinate with our securities and capital markets team on continuing disclosure, and with our carbon markets team where targets or claims rely on carbon credits. Where reported figures feed into supplier or customer obligations, our climate-risk contracting practice aligns the contract terms. See our practices or contact us to discuss your next reporting cycle.
Checklist for decision-makers
- Have we checked our category against the 25 August 2025 SGX and ACRA announcement this year?
- Are Scope 1 and Scope 2 emissions captured for every site, with documented methods?
- Is our materiality assessment current and documented, with reasons for each factor?
- Does every target have an evidence base, a pathway and disclosed dependencies?
- Has the internal review been completed and its findings closed?
- Did the board see a full briefing pack, and do the minutes record its consideration?
- Do marketing, investor and tender claims match the report and its evidence?
- Are we preparing data controls now for assurance before it becomes mandatory for us?
Issuers that can answer yes to each question are well placed to meet the evolving requirements for sustainability reporting in Singapore without restatements or reputational surprises.
Frequently asked questions
01Is sustainability reporting mandatory for all Singapore companies?
No. It is mandatory for SGX-listed issuers under Listing Rules 711A and 711B. Large non-listed companies were brought into a climate reporting roadmap in 2024, defined by annual revenue of at least S$1 billion and total assets of at least S$500 million, but their timeline was extended in August 2025. Other companies have no general statutory duty, although lenders, investors, multinational customers and tender processes increasingly ask for comparable information.
02What changed in the 25 August 2025 announcement?
SGX and ACRA revised the climate reporting timetable. All listed issuers must still report Scope 1 and Scope 2 emissions for financial years beginning in 2025. Start dates for fuller ISSB-aligned climate disclosures and Scope 3 emissions were staged according to the issuer's category, including STI constituency and market capitalisation tier, external limited assurance was deferred to FY2029 for all listed issuers, and the timeline for large non-listed companies was extended. Check your category against the announcement rather than earlier roadmaps.
03Which reporting framework should we use?
For climate disclosures, Singapore has aligned its requirements with the ISSB standards, so climate reporting should be built around IFRS S2 as applied in Singapore. For wider ESG topics, many issuers use GRI or sector-specific frameworks. SGX requires issuers to state the framework used. Whatever you choose, explain how frameworks fit together and avoid selectively applying parts without saying so, because reviewers and investors compare reports across peers.
04Do we need external assurance on our sustainability report?
Under the revised timetable, external limited assurance on Scope 1 and Scope 2 emissions is deferred to FY2029 for all listed issuers and FY2032 for large non-listed companies, so it is not yet mandatory. Practice Note 7.6 also expects an internal review of the reporting process. Many issuers obtain voluntary assurance before it is mandatory, which tests data controls early and reduces the risk of restatement once assurance becomes compulsory.
05What should the board statement say?
The board statement confirms that the board has considered sustainability issues as part of its strategic formulation, determined the material ESG factors and overseen their management and monitoring. It should be supported by real engagement: a briefing pack on materiality, data controls, estimates and open issues, and minutes recording discussion and challenge. A statement approved without that evidence is difficult to defend if the report is later questioned.
06Can we be liable for inaccurate sustainability disclosures?
Potentially. For listed issuers, sustainability reports are public disclosures, so material inaccuracies can raise Listing Rule and securities law concerns. Consumer-facing claims are assessed under the Consumer Protection (Fair Trading) Act 2003. Lenders may also have contractual remedies where sustainability-linked terms rely on reported figures. The best protection is a documented evidence file, legal review of claims and forward-looking statements, and transparent correction of errors.
07We are a subsidiary of a foreign group. Can we rely on the parent's report?
You can use group data, systems and methodologies, but a Singapore-listed issuer must meet its own SGX obligations for its own reporting perimeter and its own board must issue the statement. Check that the parent's boundaries, reporting period and metrics match what your Singapore report needs, and document how Singapore figures are extracted and checked from group data.
Sources and official materials
- SGX Practice Note 7.6: Sustainability Reporting Guide — Primary components, board statement and internal review
- Code of Corporate Governance 2018 — Board responsibilities and governance principles
- MAS Guidelines on Environmental Risk Management — Expectations for banks, insurers and asset managers
- MAS: Guidelines on transition planning (2026) — Transition planning expectations for financial institutions
- MAS: Singapore-Asia Taxonomy — Classification of green and transition activities
- CCS: Guide on clear and accurate product claims — Consumer-facing claims and greenwashing risk
General information only, current as at 20 October 2026. It is not legal advice and does not create a lawyer–client relationship. Singapore law and regulatory practice change; check current official sources and take advice on the facts of your matter.
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