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SGX Sustainability Reporting Requirements: A Complete Compliance Guide for Listed Companies

Date

24/09/2026

Category

GRC (Governance, Risk, and Compliance)

SGX sustainability reporting has moved from comply-or-explain to mandatory climate disclosure. Listed issuers in Singapore now report climate-related information aligned to ISSB standards, with external assurance and Scope 3 requirements phasing in, and the cost of getting it wrong is rising from reputational to regulatory. This guide covers the current SGX requirements, how they align with ISSB, the data foundations needed, and the pitfalls that turn a routine filing into a governance incident. —

Overview of SGX Sustainability Reporting Rules

If your company is listed on the Singapore Exchange, sustainability reporting is no longer a matter of corporate preference. It is a regulatory obligation, and the requirements are becoming more specific, more quantitative, and more closely aligned with international standards with each passing year. For CFOs, Company Secretaries, and Sustainability Managers navigating these obligations, the landscape can feel complex. The rules have evolved considerably since SGX first introduced mandatory sustainability reporting, and understanding what is required, when it applies, and how to comply efficiently is essential for both regulatory standing and stakeholder confidence. This guide walks you through the current state of SGX sustainability reporting, what the latest changes mean for your organisation, and how to build a compliance approach that is both thorough and manageable.

Where SGX sustainability reporting began

SGX introduced its first sustainability reporting requirements in 2016, with Practice Note 7.6 providing initial guidance to listed issuers. At that stage, the requirements were relatively flexible: companies were asked to report on environmental, social, and governance factors that were material to their business, using a comply-or-explain approach for the five primary components of sustainability reporting. The intention was clear. SGX recognised that investors and other stakeholders increasingly needed non-financial information to assess the long-term prospects and risk profiles of listed companies. Rather than prescribing a rigid format, the exchange took a principles-based approach that allowed companies to develop their reporting practices over time. However, as global sustainability standards matured and investor expectations evolved, SGX’s framework needed to keep pace. The comply-or-explain approach, while appropriate as a starting point, was gradually tightened to reflect the growing consensus that sustainability disclosure should be as rigorous and standardised as financial reporting.

The current regulatory framework

Today, SGX sustainability reporting is governed by the SGX Sustainability Reporting Rules, which set out mandatory requirements for all listed issuers. The current framework requires every listed company to publish an annual sustainability report that includes five core components:

  • A board sustainability statement, outlining the board’s oversight of sustainability matters, the company’s sustainability approach, and how sustainability considerations are integrated into corporate strategy
  • Identification of material ESG factors, based on a structured assessment of the sustainability topics most relevant to the company’s industry, operations, and stakeholders
  • Policies, practices, and targets for each identified material factor, including specific commitments, timeframes, and the mechanisms used to track and manage performance
  • Performance data and metrics against stated targets, with quantitative information wherever possible
  • A description of sustainability governance, including the management structures, processes, and internal controls that support the company’s sustainability performance

These components must be disclosed in the company’s annual report, ensuring that sustainability information is presented alongside financial statements and is accessible to investors and other stakeholders through the same channels. The sustainability report must cover the financial year in question and be published at the same time as the company’s annual report. This integration of financial and non-financial reporting reflects a deliberate design choice: SGX wants sustainability data to be treated with the same level of rigour and accountability as financial data. For industrial companies in Singapore, including those in manufacturing, semiconductors, steel, and petrochemicals, the materiality assessment typically identifies climate-related factors as the most significant sustainability considerations. Energy consumption, carbon emissions, water usage, and waste management are common material factors for these sectors, and SGX expects detailed disclosure on each.

Who must comply

The SGX Sustainability Reporting Rules apply to all issuers listed on the Singapore Exchange, regardless of their sector, size, or country of incorporation. This includes:

  • Mainboard listed companies
  • Catalist listed companies
  • Foreign issuers with a primary or secondary listing on SGX
  • Business trusts and stapled securities listed on SGX

For companies headquartered outside Singapore but listed on SGX, the same reporting requirements apply. A Taiwanese semiconductor manufacturer, a Thai petrochemical producer, or an Indonesian industrial conglomerate listed on SGX must comply with the same disclosure standards as a Singapore-domiciled company. This has significant implications for data collection, as the reporting entity may need to gather sustainability data from operations spanning multiple countries and regulatory environments.

Climate Reporting Requirements Under SGX Listing Rules

Requirement Who Timing Status
ISSB-aligned climate reporting All listed issuers From FY2025 Mandatory
External assurance on climate Listed issuers, phased From FY2027 limited assurance Transitioning to reasonable over time
Scope 3 disclosure Large issuers first Phased after FY2025 Ramping up

Climate-related disclosure is now the centrepiece of SGX sustainability reporting. The exchange has identified climate change as the most significant sustainability issue facing listed companies, and its reporting requirements reflect this prioritisation. Understanding what SGX expects in terms of climate disclosure is essential for every listed issuer.

The four pillars of climate disclosure

SGX’s climate reporting requirements are structured around four pillars, originally drawn from the TCFD framework and now expanded and refined through alignment with ISSB standards:

  1. Governance: The company must describe its board’s oversight of climate-related risks and opportunities, including how frequently the board reviews climate matters, whether specific board committees have responsibility for climate, and how management’s role in assessing and managing climate risks is defined. Investors want to see that climate is not delegated entirely to operational staff but receives genuine board-level attention.
  1. Strategy: The company must disclose the actual and potential impacts of climate-related risks and opportunities on its business, strategy, and financial planning. This includes describing how climate risks affect the company’s operations, supply chain, and market position, and how the company plans to respond. Scenario analysis, while initially encouraged on a comply-or-explain basis, is moving towards mandatory disclosure for larger issuers.
  1. Risk Management: The company must describe its processes for identifying, assessing, and managing climate-related risks. This includes how climate risks are integrated into the company’s overall risk management framework, how the company identifies and prioritises specific climate risks, and what processes are in place to monitor and review those risks over time.
  1. Metrics and Targets: The company must disclose the metrics it uses to assess climate-related risks and opportunities, and the targets it has set in response. This includes quantitative disclosure of Scope 1 and Scope 2 greenhouse gas emissions, with Scope 3 emissions being progressively mandated. Companies must also disclose the methodologies, emission factors, and consolidation approaches used in their emissions calculations.
GHG emissions disclosure requirements

The quantitative emissions disclosure requirements under SGX are specific and prescriptive. Listed issuers must report:

  • Scope 1 emissions: Direct GHG emissions from sources owned or controlled by the company, including combustion in boilers, furnaces, vehicles, and chemical processes. Emissions must be reported in tonnes of CO2 equivalent (tCO2e) and broken down by major source category where material.
  • Scope 2 emissions: Indirect GHG emissions from the generation of purchased electricity, steam, heating, and cooling consumed by the company. SGX expects both the location-based and market-based methods to be disclosed, in line with the GHG Protocol’s Scope 2 Guidance.
  • Scope 3 emissions: Indirect emissions from the company’s value chain. While SGX is phasing in Scope 3 requirements with transition reliefs available in the early years, the direction is clear: full Scope 3 disclosure will be expected. This is particularly relevant for manufacturing and industrial companies, where value chain emissions often represent the largest share of total carbon emissions.

For each scope, companies must disclose the methodology used, the emission factors applied, the organisational boundary (operational control or equity share), the base year selected, and any restatements of previously reported figures. This level of detail is essential for assurance providers and investors to assess the quality and comparability of the data.

Industry-specific considerations

For companies in energy-intensive sectors, SGX’s climate reporting requirements carry particular weight. Manufacturing, semiconductor fabrication, steel production, and petrochemical operations typically generate substantial Scope 1 emissions from combustion and industrial processes, and significant Scope 2 emissions from electricity consumption. The challenge is not just in measuring these emissions accurately, but in demonstrating that the company has a credible plan to manage and reduce them over time. SGX expects material sector-specific disclosures where relevant. A petrochemical company, for example, should address process emissions, fugitive emissions, and the carbon intensity of its products. A semiconductor manufacturer should discuss the energy intensity of fabrication processes and the use of perfluorinated compounds. A steel producer should address the emissions profile of different production routes, such as blast furnace-basic oxygen furnace versus electric arc furnace. These industry-specific expectations mean that a generic reporting template is insufficient. Companies need data systems that can capture the specific operational parameters relevant to their industry and translate those into the metrics that SGX and investors expect to see.

To see how Evercomm helps industrial enterprises measure, reduce, and finance their transition to sustainable operations, visit https://evercomm.io.

Frequently Asked Questions

What are the SGX sustainability reporting requirements?

SGX requires all listed issuers to publish an annual sustainability report that includes a board sustainability statement, identification of material ESG factors, policies and targets for each material factor, performance metrics, and a description of sustainability governance. Climate-related disclosures aligned with the ISSB standards (IFRS S1 and IFRS S2) are being progressively mandated, with larger issuers required to comply first.

When do SGX climate reporting requirements take effect?

SGX is implementing ISSB-aligned climate reporting on a phased basis. Large listed issuers, defined as those with a market capitalisation of SGD 1 billion or more, are required to provide climate-related disclosures in their annual reports for financial years beginning on or after 1 January 2025. Smaller listed issuers will follow in subsequent years, with the full framework applying to all SGX-listed companies by financial year 2027.

How do SGX sustainability reporting rules align with ISSB standards?

SGX has adopted the ISSB standards, IFRS S1 and IFRS S2, as the baseline for sustainability and climate-related disclosures. Listed issuers must report on sustainability-related risks and opportunities in accordance with IFRS S1, and provide specific climate-related disclosures including Scope 1, Scope 2, and eventually Scope 3 GHG emissions in accordance with IFRS S2. SGX provides implementation guidance to help issuers transition to these standards.

What is the difference between SGX sustainability reporting and TCFD?

TCFD (Task Force on Climate-related Financial Disclosures) was the previous framework that SGX required for climate-related disclosures. ISSB (IFRS S1 and IFRS S2) has now superseded TCFD as the global baseline. SGX’s latest requirements build on TCFD’s four-pillar structure of governance, strategy, risk management, and metrics, but expand the scope to cover broader sustainability matters and require more detailed quantitative disclosures, including specific GHG emissions data.

Do SGX-listed companies need external assurance for sustainability reports?

Yes. SGX is progressively introducing mandatory external assurance requirements for sustainability and climate-related disclosures. Initially, limited assurance is required for GHG emissions data, with the expectation of moving towards reasonable assurance over time. Companies are encouraged to obtain assurance from accredited verification bodies to strengthen the credibility of their disclosures and meet investor expectations.

What technology helps with SGX sustainability reporting compliance?

Technology platforms that automate data collection, apply recognised emission factors, and generate reports aligned with SGX and ISSB requirements significantly streamline compliance. IoT-based monitoring systems capture real-time operational data, carbon accounting platforms process this data against GHG Protocol and ISO 14064 methodologies, and reporting tools produce assured reports. Automation can deliver up to 80% faster reporting cycles and improve data authenticity by up to 90%.

Does SGX sustainability reporting apply to foreign companies listed in Singapore?

Yes. All issuers listed on SGX, regardless of their country of incorporation or primary operations, are subject to the SGX Sustainability Reporting Rules. Foreign issuers must comply with the same disclosure requirements, though SGX may provide transitional relief in certain circumstances. Companies with operations across Asia, including those headquartered in Taiwan, Thailand, Indonesia, and Malaysia, need to ensure their data collection processes cover all material operations.

What are the current SGX sustainability reporting requirements?

All SGX-listed issuers must publish an annual sustainability report with climate disclosures aligned to ISSB IFRS S2, covering governance, strategy, risk management, and metrics including Scope 1 and 2 emissions, with Scope 3 required for large issuers on a phased schedule. External assurance phases in from FY2027, starting with limited assurance.

How does SGX reporting align with ISSB standards?

SGX adopted the ISSB climate standard as the backbone of its requirements, so an ISSB S2-ready dataset satisfies SGX climate disclosure. The practical implication is one data pipeline serving both: emissions figures, scenario analysis, and governance documentation prepared for ISSB flow directly into the SGX report.

What are common pitfalls in SGX sustainability disclosures?

The recurring failures are emissions data without traceable methodology, inconsistent figures between the sustainability report and annual report, missing Scope 3 screening, and governance described in name only without documented board oversight. Each of these draws regulator queries and complicates assurance, and each is prevented by the same thing: controlled data pipelines with audit trails.

 

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