Listed issuers will be subject to additional emissions disclosure requirements as the Singapore Exchange Regulation announces enhancements to its sustainability reporting regime.
By Paul A. Davies, Farhana Sharmeen, Michael D. Green, James Bee, and Kevin Mak
On 23 September 2024, the Singapore Exchange Regulation (SGX RegCo) announced that it will begin incorporating the IFRS Sustainability Disclosure Standards (IFRS Standards) issued by the International Sustainability Standards Board (ISSB) into its sustainability reporting regime.
The announcement comes after the SGX RegCo and the Accounting and Corporate Regulatory Authority introduced regulations in February 2024 for mandatory climate-related disclosures (CRD) for listed issuers and large non-listed companies. For more information on the implementation of CRD, see this Latham blog post.
Reporting CRD for Listed Issuers From FY 2025
From FY 2025, all listed issuers will be required to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions in accordance with the requirements under IFRS S2. In addition, disclosures of other primary components of a sustainability report (other than CRD) will only be mandated from FY 2026. Such primary components (other than CRD) include:
- material ESG factors;
- policies, practices, and performance;
- targets;
- sustainability reporting framework; and
- board statement and associated governance structure for sustainability practices.
The sustainability report should identify the material ESG factors, and describe both the reasons for and the process of selection, taking into consideration their relevance or impact to the business, strategy, financial planning, business model, and key stakeholders. Here material ESG factors refer to the environmental, social, and governance issues that are most significant to the company’s business and stakeholders.
The sustainability report should also set out the issuer’s targets for the forthcoming year in relation to each material ESG factor identified. Targets should be considered for defined short, medium, and long term horizons, and if not consistent with those used for strategic planning and financial reporting, the reasons for the inconsistency should be disclosed.
External Assurance on the Sustainability Report
From FY 2026, a listed issuer must issue a sustainability report together with its annual report for its financial year. However, if a listed issuer has conducted external assurance on its sustainability report, it can issue a sustainability report no later than five months after the end of its financial year.
Summary of Baseline Reporting Practice
| Timeline | Baseline Reporting Practice | Calendar Year in Which Report Is Published |
| FY 2025 | Mandatory climate reporting incorporating the climate-related requirements in the IFRS StandardsThe requirement on Scope 3 GHG emissions is under review and not yet implementedOther primary components of a sustainability report to be disclosed on a comply-or-explain basisExisting timeline to issue sustainability report for its financial year applies:if no external assurance was conducted, no later than four months after the end of the financial yearif external assurance was conducted, no later than five months after the end of the financial year | 2026 |
| FY 2026 | Primary components of a sustainability report to be disclosed on a mandatory basisSustainability report to be issued based on the following timelines:if no external assurance was conducted, together with its annual reportsif external assurance was conducted, no later than five months after the end of the financial yearExpectation that large listed issuers will be required to report on Scope 3 GHG emissions and that their climate reporting will be aligned with the climate-related requirements in the IFRS Standards | 2027 |
Next Steps
From FY 2026, larger listed issuers (based on market capitalisation) will be expected to report Scope 3 GHG emissions.1 However, SGX RegCo will review the experience and readiness of such listed issuers before establishing the implementation roadmap for listed issuers to report Scope 3 GHG emissions. SGX RegCo will provide such listed issuers with ample notice before the effective date of Scope 3 GHG emissions reporting.
Latham & Watkins will continue to monitor developments in this area.
This post was prepared with the assistance of Cheryl Ting.
- SGX RegCo has not specified the exact size threshold for larger listed issuers based on market capitalization that will be expected to report Scope 3 GHG emissions from FY 2026. Rather, the response paper mentions that SGX RegCo will carry out an in-depth review of issuers’ experience and readiness before setting out the implementation roadmap for disclosures of Scope 3 GHG emissions. In the implementation roadmap, larger issuers (e.g., issuers above a certain market capitalisation) will likely be prioritised for reporting. ↩︎