ISSB Reporting in Singapore: Climate Disclosure & Sustainability Requirements

Global Baseline

Climate Disclosure

Enhanced Transparency

IFRS S1: General Sustainability Disclosures

IFRS S1 requires companies to disclose information about sustainability-related risks and opportunities that could affect the company financial position, financial performance, or cash flows.

IFRS S2: Climate-Related Disclosures

IFRS S2 requires detailed climate-related disclosures, including governance, strategy, risk management, and metrics. It builds on TCFD recommendations and requires Scope 1, 2, and 3 emissions disclosure.

Singapore-Specific Modifications

Singapore may introduce modifications to address local context and priorities, while maintaining alignment with the global ISSB standards to ensure interoperability with international markets.

Regulatory Coordination

MAS and SGX are coordinating on ISSB implementation, ensuring consistency across financial institutions and listed companies, and aligning with existing disclosure requirements.

IFRS S1 Requirements

IFRS S1 requires companies to disclose sustainability-related risks and opportunities, including governance, strategy, risk management, and metrics. It applies to all sustainability-related matters that are material to the company.

IFRS S2 Requirements

IFRS S2 requires climate-related disclosures following TCFD recommendations, including governance, strategy, risk management, and metrics. It requires disclosure of Scope 1, 2, and 3 emissions and climate-related targets.

Materiality Assessment

Companies must assess materiality of sustainability-related risks and opportunities, considering both financial materiality and impact materiality, and disclose information that is material to users of financial statements.

Reporting Frequency

Sustainability disclosures must be provided at the same time as financial statements, ensuring that sustainability information is integrated with financial reporting and provided to investors on a regular basis.

Governance

Companies must disclose governance processes for climate-related risks and opportunities, including board oversight, management responsibility, and organizational structures for climate risk management.

Strategy

Companies must disclose the actual and potential impacts of climate-related risks and opportunities on their business, strategy, and financial planning, including resilience analysis and scenario analysis.

Risk Management

Companies must disclose how they identify, assess, and manage climate-related risks, including risk identification processes, risk assessment methodologies, and risk management integration.

Metrics and Targets

Companies must disclose climate-related metrics, including Scope 1, 2, and 3 emissions, and climate-related targets, including emissions reduction targets and progress toward targets.

Integrated Reporting

Sustainability disclosures are integrated with financial reporting, ensuring that sustainability information is provided alongside financial statements and considered in investment decisions.

Materiality-Based

The framework is based on materiality, requiring companies to disclose information that is material to users of financial statements, focusing on sustainability-related risks and opportunities that affect financial performance.

Decision-Useful Information

The framework focuses on providing decision-useful information to investors, ensuring that sustainability disclosures are relevant, reliable, comparable, and verifiable.

Progressive Enhancement

The framework allows for progressive enhancement, with companies expected to improve the quality and completeness of disclosures over time as capabilities and data availability improve.

Large Listed Companies (2025)

Large listed companies on SGX must implement ISSB reporting from 2025, providing sustainability and climate-related disclosures following IFRS S1 and S2.

Smaller Listed Companies (2027)

Smaller listed companies have additional time to prepare, with ISSB reporting required from 2027. This phased approach allows companies to build capacity and prepare for compliance.

Financial Institutions (Ongoing)

Financial institutions continue to comply with MAS climate risk disclosure requirements, which are being aligned with ISSB standards to ensure consistency across the financial sector.

Review and Enhancement

Singapore will review the implementation of ISSB standards and enhance requirements over time, including the introduction of assurance requirements and expansion to additional company categories.

Listed Companies

All listed companies on SGX are subject to ISSB reporting requirements, with phased implementation based on company size and market capitalization.

Large Companies

Large listed companies, defined by market capitalization and other criteria, must implement ISSB reporting from 2025, providing comprehensive sustainability and climate-related disclosures.

Smaller Companies

Smaller listed companies have additional time to prepare, with ISSB reporting required from 2027. This allows smaller companies to build capacity and prepare for compliance.

Financial Institutions

Financial institutions are subject to MAS climate risk disclosure requirements, which are being aligned with ISSB standards to ensure consistency across the financial sector.

Annual Sustainability Report

Companies must publish an annual sustainability report containing sustainability and climate-related disclosures following IFRS S1 and S2, provided at the same time as financial statements.

Climate-Related Disclosures

Companies must disclose climate-related information following IFRS S2, including governance, strategy, risk management, and metrics, with specific requirements for Scope 1, 2, and 3 emissions.

Sustainability-Related Disclosures

Companies must disclose sustainability-related risks and opportunities following IFRS S1, including governance, strategy, risk management, and metrics for all material sustainability matters.

Board Responsibility

Boards are responsible for overseeing sustainability disclosures, ensuring that companies provide accurate, complete, and timely sustainability information to investors.

Limited Assurance

Singapore is introducing limited assurance requirements for sustainability disclosures, providing a baseline level of verification to enhance the credibility of sustainability information.

Progression to Reasonable Assurance

Singapore plans to move to reasonable assurance over time, providing a higher level of verification for sustainability disclosures as the market matures and capabilities improve.

Assurance Providers

Sustainability disclosures must be assured by qualified assurance providers, including accounting firms and other professional service providers with expertise in sustainability assurance.

International Alignment

Assurance requirements are aligned with international best practices, ensuring that Singapore assurance standards are consistent with global developments in sustainability assurance.

Operational Impact

Companies must implement sustainability reporting systems, collect and manage sustainability data, and integrate sustainability considerations into business processes.

Governance Impact

Boards must oversee sustainability disclosures, and companies must integrate sustainability into corporate governance structures and decision-making processes.

Capital Access Impact

ISSB reporting enhances access to global capital by providing consistent and comparable sustainability information, meeting investor expectations and regulatory requirements.

Competitive Impact

Companies that implement ISSB reporting effectively gain competitive advantage through enhanced transparency, better risk management, and improved investor confidence.

1. Capital Access Mechanism

ISSB reporting → Investor confidence → Lower cost of capital

2. Risk Management Mechanism

Climate disclosure → Risk identification → Better risk management

3. Compliance Cost Mechanism

Reporting systems → Implementation costs → Operational expenditure

4. Competitive Advantage Mechanism

Transparency → Investor preference → Market differentiation

Operational Impact

Sustainability reporting systems, data management, process integration

Strategic Impact

Climate strategy, risk management, capital allocation, investor relations

Financial Impact

Cost of capital, access to capital, compliance costs, competitive advantage

Governance Impact

Board oversight, corporate governance, accountability, transparency

Singapore vs EU

• • Singapore: ISSB-based, phased implementation, focus on materiality
• • EU: CSRD-based, double materiality, broader scope

Singapore vs UK

Both Singapore and UK are adopting ISSB standards, with similar timelines and approaches. Singapore focuses on listed companies, while UK has broader scope including private companies.

Singapore vs US

Singapore is adopting ISSB standards, while the US SEC has proposed climate disclosure rules that are similar but not identical to ISSB. Both focus on climate-related financial disclosures.

Data Availability

Collecting and managing sustainability data, particularly Scope 3 emissions, can be challenging for companies with limited data systems and supplier engagement.

Capacity Building

Building internal capacity for sustainability reporting requires training, systems, and processes, which can be resource-intensive for smaller companies.

Assurance Readiness

Preparing for assurance requires robust data systems and processes, which can be challenging for companies with limited experience in sustainability assurance.

Evolving Standards

ISSB standards and related guidance are evolving, requiring companies to stay updated on developments and adapt their reporting practices over time.