Introduction

Singapore Exchange (SGX) has moved decisively from voluntary to mandatory climate reporting, positioning the city-state as one of Asia’s most rigorous sustainability disclosure regimes. Effective from financial year 2025, all SGX-listed companies must disclose Scope 1 and Scope 2 greenhouse gas (GHG) emissions aligned with the International Sustainability Standards Board (ISSB) framework. For professionals operating in or investing across Asian markets, understanding this phased regime is now essential — not least because Singapore’s approach is being closely watched as a model by other exchanges across ASEAN.

The Framework

Singapore’s approach is built on recommendations jointly developed by SGX RegCo and the Accounting and Corporate Regulatory Authority (ACRA). Rather than directly adopting IFRS S1 and IFRS S2 verbatim, Singapore has embedded key elements of IFRS S2 into SGX Listing Rules through a tiered, phased roadmap. Companies are grouped into three categories based on market capitalisation, with obligations escalating accordingly. The Straits Times Index (STI) constituents — the top 30 listed companies — face the earliest and most demanding requirements, including mandatory Scope 3 reporting from FY2026.

SGX Climate Reporting Phased Timeline

Category	Scope 1 & 2	Scope 3	Assurance
STI constituents (top 30)	FY2025	FY2026 (mandatory)	FY2027 (limited)
Listed, market cap ≥ S$1bn	FY2025	Voluntary	FY2027 (limited)
Listed, market cap < S$1bn	FY2025	Voluntary	FY2027 (limited)
Large non-listed (rev ≥ S$1bn, assets ≥ S$500m)	FY2030	FY2030 (TBC)	FY2029

Beyond emissions metrics, companies must also produce qualitative disclosures covering governance structures, climate strategy, and risk management — all modelled on IFRS S2 pillars. Full sustainability reports (including non-climate components) become mandatory from FY2026. Companies that complete external assurance have up to five months after year-end to file.

Assurance requirements kick in from FY2027 for listed issuers and FY2029 for large non-listed companies. The threshold for non-listed companies — at least S$1 billion in revenue and S$500 million in assets — will bring a significant cohort of private firms into scope from FY2030.

Methodology and Implications

The shift to mandatory ISSB-aligned disclosure brings significant methodological complexity. Scope 3 emissions — covering upstream and downstream value chain activities — require companies to engage suppliers, customers, and logistics providers for data they often do not directly control. For STI constituents with complex, cross-border supply chains in Southeast Asia, this is a substantial operational undertaking, and the quality of early Scope 3 reporting will vary widely.

Singapore’s escalating carbon tax adds further commercial urgency. The carbon price rises from S$25 per tonne in 2025 to S$45 in 2026–2027, targeting S$50–S$80 per tonne by 2030. Accurate GHG accounting is no longer purely a compliance exercise — it directly affects tax liabilities and informs strategic decisions on operations, procurement, and capital investment.

For investors, the new regime creates a growing body of comparable, standardised disclosure across Singapore’s most significant companies — a meaningful step up from the patchwork of voluntary reports that preceded it. Firms that delay building robust measurement infrastructure risk regulatory action, reputational damage, and constrained access to sustainability-linked financing.

Summary

SGX’s sustainability reporting regime is among the most structured in Asia. The phased, tiered approach balances ambition with practicality, giving smaller listed companies time to build data systems while holding the largest firms to higher immediate standards. Non-listed companies above the revenue and asset thresholds should begin preparing now. For investors, the standardised disclosures will increasingly serve as a lens for assessing climate risk exposure and long-term capital allocation.