The Global Push Towards ISSB Aligned Disclosure

Sustainability disclosure requirements are tightening across major economies, with regulators moving from voluntary ESG reporting towards mandatory standardized frameworks. Climate related disclosure is at the center of this shift, driven largely by the International Sustainability Standards Board (ISSB) and its IFRS S1 and IFRS S2 Standards. Over 30 jurisdictions have now signaled adoption of ISSB Standards, reflecting a push for comparable, decision useful sustainability data across global capital markets. Understanding Singapore’s regulatory ecosystem will help businesses see how this global push translates into local requirements.

Singapore is part of this trend. It is moving towards a structured, mandatory sustainability disclosure regime. The Accounting and Corporate Regulatory Authority (ACRA) leads the development of Singapore’s sustainability disclosure framework and the phased rollout of ISSB aligned climate disclosures. Singapore Exchange Regulation (SGX RegCo) implements sustainability reporting requirements for listed companies through the SGX Listing Rules, including progressive ISSB aligned climate and greenhouse gas (GHG) disclosures.

The Monetary Authority of Singapore (MAS) sets sustainable finance regulations and climate risk expectations for banks, insurers and asset managers. The National Climate Change Secretariat (NCCS) coordinates national climate policy and decarbonization strategy, while the Ministry of Sustainability and the Environment (MSE) and the National Environment Agency (NEA) oversee environmental compliance, carbon pricing and emissions reporting. Together, these agencies are moving Singapore towards a transparent, internationally aligned sustainability reporting system.

From Voluntary Reporting to Mandatory ISSB Aligned Disclosure

Singapore’s ESG reporting framework has shifted from voluntary sustainability reporting to a mandatory, climate focused regime. The regime is aligned with International Sustainability Standards Board (ISSB) Standards, specifically IFRS S1 (general sustainability related disclosures) and IFRS S2 (climate related disclosures).

Until 2025, SGX RegCo required listed companies to publish annual sustainability reports covering material ESG factors, strategy, targets and performance. From financial year 2025, this shifted to a firmer requirement. All SGX listed companies must report Scope 1 and Scope 2 GHG emissions, with climate disclosures progressively aligned to ISSB Standards.

In August 2025, ACRA and SGX RegCo revised this original roadmap. The regulators extended most climate reporting and external assurance timelines, citing an uncertain global economic environment and industry feedback on varying levels of reporting readiness. The Scope 1 and Scope 2 reporting start date for all listed companies did not change. The main changes affect Scope 3 timing for non-STI companies, the pace for large non-listed companies, and assurance deadlines. The current, revised timeline is set out below.

The Revised ISSB Aligned Climate Reporting Roadmap

What Companies Must Disclose

Singapore gives IFRS S1 and IFRS S2 legal effect through locally issued standards known as SFRS(I) S1 and SFRS(I) S2, issued by the Accounting Standards Committee (ASC) and mirroring the ISSB Standards. These standards have been finalised and are already in effect and is forming the basis of climate related disclosures from FY2025. What remains phased is their mandatory application across different categories of companies, following the ACRA and SGX RegCo roadmap set out below.

Under the ISSB framework, companies disclose climate related information across four areas.

Revised Timeline for Listed Companies

For non-STI listed companies, Scope 3 GHG emissions reporting is now voluntary until further notice. It was previously scheduled for FY2026 alongside STI constituents.

Revised Timeline for Large Non-Listed Companies

Large non-listed companies (Large NLCos) are defined by ACRA as companies with annual revenue of at least SGD 1 billion and total assets of at least SGD 500 million.

Revised Assurance Requirements

The Sustainability Reporting Advisory Committee (SRAC) supports ACRA and SGX RegCo by recommending reporting and assurance requirements. MAS separately oversees climate risk management and sustainability related requirements for financial institutions.

Business Implications: Building Readiness for ISSB Aligned Reporting

The revised roadmap gives companies more time, but it does not reduce the depth of change required. For ESG and sustainability functions, ISSB aligned reporting is not an extension of existing sustainability reporting. It is a shift towards financial grade disclosure, with the same rigour, controls and accountability expected of financial statements. Seven areas warrant particular attention.

1. Governance and Board Accountability

SFRS(I) S2 requires disclosure of specific board oversight mechanisms, not general governance statements. Boards will need documented processes showing how climate related risks and opportunities are considered in major decisions, capital allocation and strategy approval. Many boards will need a formal climate or sustainability skills assessment while some companies are beginning to link executive remuneration to emissions and transition targets. Sustainability and finance functions should prepare board level reporting packs that clearly evidence oversight, rather than relying on narrative descriptions alone.

2. Data Foundations and GHG Accounting Complexity

Scope 1 and Scope 2 accounting is relatively mature for most companies, but Scope 3 remains the primary technical challenge, particularly for STI constituents already needed to report it from FY2026. Companies will need to work through the GHG Protocol’s fifteen Scope 3 categories, apply spend based, activity based and hybrid calculation methods as appropriate, and progressively shift away from generic emission factors towards supplier specific and primary data. For financial institutions and portfolio companies, this extends to financed emissions calculated under PCAF methodology. Data quality grading, documented calculation methodologies and version-controlled emission factor libraries will increasingly be expected, not optional.

3. Climate Risk Integration and Scenario Analysis

SFRS (I) S2 requires climate resilience assessment using scenario analysis, typically referencing pathways such as those from the NGFS or IPCC. This is a technical and cross functional exercise, requiring collaboration between sustainability, finance, treasury and risk teams to translate physical and transition risk scenarios into financial impact ranges. Companies will need to move beyond qualitative risk narratives towards quantified exposure, linked explicitly to enterprise risk management frameworks and where relevant to impairment testing and going concern assessments under financial reporting standards.

4. Assurance and Controls Readiness

With external limited assurance mandated from FY2029 for listed companies and FY2032 for large non-listed companies, businesses should begin building assurance ready processes well in advance. This includes designing internal controls over sustainability data comparable to internal controls over financial reporting, maintaining audit trails from source data to disclosure, and documenting judgements and estimates. Companies should also monitor the development of assurance standards relevant to Singapore, including alignment with ISSA 5000 and existing ISAE 3410 practice, and engage assurance providers early to understand evidentiary expectations.

5. Technology and Systems Architecture

Spreadsheet based carbon accounting will not scale to ISSB aligned reporting, particularly once Scope 3 and assurance requirements apply. Companies should evaluate dedicated carbon and ESG data management platforms with integration into ERP, procurement and financial systems, ensuring emissions data can be reconciled to underlying transactional data. System architecture should support materiality assessments, restatement of prior period data, and multi entity consolidation for group reporting.

6. Talent and Cross Functional Capability

ISSB aligned reporting sits at the intersection of sustainability, finance, risk and internal audit. Many organisations currently lack in house capability in GHG accounting, climate scenario modelling and sustainability assurance. Companies will need a deliberate capability building plan, whether through hiring, training existing finance and sustainability teams, or engaging external advisers during the transition period, with a clear plan to build internal capability over time rather than permanent reliance on outsourcing.

7. Financial and Strategic Implications

Beyond compliance ISSB aligned disclosure is increasingly linked to cost of capital, access to sustainability linked financing, and investor and lender due diligence. Companies with credible, assured climate data will be better positioned in green and sustainability linked loan negotiations, in responses to investor ESG questionnaires, and in tenders where large listed customers are extending Scope 3 data requests down the supply chain. Conversely, companies that delay readiness risk being drawn into last minute, high-cost compliance exercises, and may face increasing pressure from customers and financiers before their own regulatory deadline arrives.

Conclusion

The August 2025 revision does not change Singapore’s regulatory direction. It changes the pace. ISSB aligned climate reporting remains a firm requirement for listed companies now and for large non-listed companies in due course. What has shifted is the time available to build the governance, data and assurance capabilities that this regime demands.

That extra time should not be mistaken for room to delay. Scope 1 and Scope 2 reporting is already mandatory, and Scope 3 requirements, climate risk integration, and external assurance will follow on clearly dated timelines. Companies that treat this period as a preparation window, rather than a deferral, will be better positioned when each deadline arrives. Businesses that build genuine reporting capability now, rather than responding closer to their deadline, will be better placed to meet regulatory requirements and stay competitive as sustainability data becomes a standard part of doing business in Singapore and the wider region.