The SGX Climate Reporting Timeline: What Singapore Listed and Non-Listed Companies Must Do Now

Why SGX Issued New Requirements

The SGX climate reporting requirements didn't emerge from nowhere — they're the Singapore implementation of a global regulatory shift. When the ISSB published IFRS S1 and S2 in June 2023, it handed regulators around the world a common baseline they could adopt. Singapore moved quickly: SGX RegCo and ACRA announced the adoption of IFRS S2 as the mandatory standard for listed companies, embedding it into the SGX Listing Rules.

The strategic backdrop is Singapore's Green Plan 2030 — the national sustainability roadmap targeting net zero GHG emissions by 2050. Climate reporting is one lever in that plan; it forces capital markets to price climate risk, channels investment toward lower-carbon business models, and gives the government data to track national emissions trajectories. Singapore also needs its listed companies to meet the disclosure standards expected by global institutional investors, who increasingly screen for TCFD and IFRS S2 alignment before taking positions.

MAS has reinforced this from the financial sector side, requiring banks and insurers to integrate climate considerations into risk frameworks. The result is a regulatory environment where climate disclosure is no longer voluntary, optional, or peripheral — it's a core governance and financial reporting obligation.

The Timeline Mapped Out Clearly

Here is the full SGX climate reporting schedule, milestone by milestone:

FY2025 — Scope 1+2 mandatory for all listed companies. All companies listed on SGX Main Board and Catalist must disclose gross Scope 1 and gross Scope 2 GHG emissions in their sustainability reports for financial years ending in 2025. Both location-based and market-based Scope 2 figures are required. A methodology note documenting emission factors, organisational boundary, and data sources is expected alongside the numbers.

FY2026 — Scope 3, best efforts.Companies are expected to begin measuring and disclosing Scope 3 emissions across relevant value chain categories — upstream supply chain, business travel, employee commuting, product use, and end-of-life disposal, among others. The "best efforts" framing means incomplete or estimated data is acceptable, but the expectation is active engagement with Scope 3 measurement, not absence of disclosure.

FY2029 — Limited external assurance on Scope 1+2. A qualified, independent third party must review and provide limited assurance on Scope 1 and Scope 2 disclosures. This is the most consequential milestone — it transforms self-reported numbers into verified claims. The assurer will review your methodology, data collection process, internal controls, and underlying source documents.

FY2030 and beyond — Extended Scope 3 and reasonable assurance.SGX has signalled aspirational goals for broader Scope 3 assurance and a potential step up to "reasonable assurance" (the level applied to financial statement audits) over the longer term. These timelines are subject to review, but the direction is clear: climate disclosures are on a path toward the same rigour as financial reporting.

What "Financial Year 2025" Actually Means

There is consistent confusion about what "FY2025" means in the context of SGX requirements — and getting this wrong can lead to either unnecessary panic or dangerous complacency.

FY2025 refers to financial years that end in calendar year 2025. The most common case: a company whose financial year runs from 1 January 2025 to 31 December 2025 has a FY2025 financial year. Their annual report — including their sustainability report with Scope 1+2 disclosures — will be published in early 2026, but it covers FY2025.

If your financial year ends on a different date — say, 31 March 2026 — then the financial year running from 1 April 2025 to 31 March 2026 is your FY2026, not FY2025. The Scope 1+2 mandatory requirement applies to you from FY2026, with your report published in mid-2026.

Check your company's financial year end date and count forward. Whatever year your financial year ends in, that's when each timeline milestone applies to you. Don't assume the calendar year — know your year-end date.

What Listed Companies Must Produce in Their Sustainability Report

A compliant SGX sustainability report under IFRS S2 is more than a page of GHG numbers. It's a structured four-pillar disclosure that requires input from the board, the finance team, the risk function, and whoever owns your operations data. Here's what each pillar requires:

Governance disclosure. The report must identify which board member or committee has oversight of climate risk, describe how climate issues are raised at board level, and explain the management structures responsible for assessing and managing climate risks day-to-day. This is a governance disclosure, not an aspirational statement — it needs to reflect actual board processes.

Strategy disclosure. Companies must describe the climate-related risks and opportunities they have identified, explain how these affect business strategy and financial planning, and disclose the results of scenario analysis testing the business under at least a 1.5°C transition pathway and a higher-warming physical risk scenario.

Risk management disclosure.The report must explain how climate risks are identified, assessed, and prioritised, and how this process connects to the company's enterprise risk management framework. Climate risk must be integrated into the overall risk register, not treated as a standalone sustainability exercise.

Metrics & Targets. The quantitative core: gross Scope 1 GHG emissions, gross Scope 2 GHG emissions (location-based and market-based), climate-related targets and progress, and cross-industry metrics required under IFRS S2 paragraph 29. All figures must be accompanied by a methodology note and linked to underlying source data.

The Non-Listed Company Angle

If you're not listed on SGX, you are not directly subject to these requirements. But the indirect pressure is real and growing.

Supply chain data requests.Every listed company's Scope 3 emissions include the Scope 1+2 emissions of their significant suppliers. As listed companies build their Scope 3 measurement capability — which SGX requires them to do from FY2026 — they need their suppliers to provide auditable Scope 1+2 data. If you supply goods or services to a listed company and can't provide this data, they will estimate it using industry averages (which typically produces a worse figure than your actual footprint) or flag you as a supply chain risk in their sustainability report. Neither outcome is good for the relationship.

Green procurement and financing.Beyond listed-company supply chains, sustainability disclosure is becoming a standard part of B2B procurement in Singapore. Banks are embedding carbon data requests into SME loan applications. Large enterprise clients are adding GHG disclosure requirements to supplier questionnaires. Tender processes for government contracts increasingly include sustainability criteria. Voluntary disclosure isn't optional if your customers are making it a condition of doing business.

Grant eligibility.EnterpriseSG's SME Sustainability Reporting Programme (effective 1 April 2026) provides up to 50% co-funding for SMEs engaging appointed providers to build sustainability reporting capability. The Sustainability Reporting Grant (SRG) provides up to 30% (cap S$150k) for larger companies. The economics of voluntary disclosure have never been better.

The Assurance Cliff in FY2029

Of all the SGX timeline milestones, FY2029 is the one that requires the longest lead time — which is why it deserves attention now, in 2026.

What limited assurance means operationally.In a limited assurance engagement, the assurer performs procedures agreed in advance — reviewing your measurement methodology, checking that your emission factor sources are appropriate and current, testing a sample of underlying bills and invoices against your reported figures, evaluating your internal controls for data collection and calculation, and assessing whether your methodology has been applied consistently year-on-year. They then issue a written opinion, typically in negative form: "Nothing has come to our attention that suggests the Scope 1 and Scope 2 disclosures are materially misstated."

What "limited" versus "reasonable" assurance means. Limited assurance is less comprehensive than the reasonable assurance applied to financial statement audits — the assurer performs fewer and less detailed procedures and provides lower confidence. But limited assurance is still substantive. It will expose methodology errors, missing source documents, inconsistent emission factors, and calculation mistakes. It is not a rubber stamp.

Why the evidence chain must be built now. Assurers assess consistency across years. If you start data collection in 2028, you arrive at your FY2029 assurance engagement with one year of data, no baseline, and no demonstrated consistency. Assurers want to see that your methodology has been applied the same way each year, that your internal controls have been operating continuously, and that any methodology changes were documented and justified. You cannot build that track record in twelve months. Start now.

Action Checklist by Company Type

The right action depends on your situation. Here is a checklist for each major company type:

SGX Main Board listed company: (1) Confirm your financial year end date and which FY your first Scope 1+2 disclosure covers. (2) Map all Scope 1 and Scope 2 emission sources. (3) Establish data collection processes — digital or manual — for each source. (4) Select GHG Protocol methodology and document it. (5) Build or procure a system to store source documents in an auditable trail. (6) Draft your four-pillar IFRS S2 narrative. (7) Begin Scope 3 measurement for FY2026 readiness. (8) Plan your assurance readiness programme for FY2029.

SGX Catalist listed company: Same requirements as Main Board — the SGX requirements apply equally to Catalist companies. Catalist companies may have smaller teams and fewer resources, making external support (and co-funded programmes like the SRG) especially relevant.

SME supplier to listed companies:(1) Identify which of your customers are listed and what they've asked or are likely to ask for. (2) Map your Scope 1 and Scope 2 sources. (3) Calculate your emissions for the current financial year. (4) Investigate EnterpriseSG's SME Sustainability Reporting Programme for co-funding. (5) Build a simple but auditable evidence trail. (6) Be ready to respond to supplier questionnaires with documented, consistent figures — not estimates.

Independent SME with no immediate listed-company pressure:(1) Monitor your customer base — even if today's clients aren't asking, they may be in 12–18 months. (2) Review bank and financing relationships — green lending criteria are evolving. (3) Consider voluntary disclosure as a competitive differentiator. (4) Begin data collection for your own baseline understanding of your carbon footprint. The cost of starting is low; the cost of being caught flat-footed when a key customer starts asking is high.