Singapore Climate-Related Disclosures
Step-by-step method for preparing a compliant Singapore climate disclosure: how to identify which of the four reporting cohorts captures you across the SGX listed-issuer and ACRA company-level tracks, assemble the four-pillar ISSB-aligned disclosure, build the Scope 1, 2, and 3 GHG metric for a gas-dominated grid, run scenario analysis, navigate the limited-assurance roadmap, and treat the carbon tax as a financial-materiality input. Singapore’s regime is built on IFRS S2 — this page is the Singapore application layer over the global IFRS S2 disclosure methodology.
A methodology page is the execution layer. It takes the disclosure architecture from IFRS S2, the Singapore scoping and timeline rules layered on by SGX RegCo and ACRA, and the measurement rules from the GHG Protocol Corporate Standard, and tells you how to assemble a lodgement-ready climate statement. If you already know your cohort, jump to the four-pillar architecture or the GHG metric build. Australian readers comparing regimes should also see the sibling AASB S2 methodology and the AASB S2 group calculator.
Singapore runs two tracks — and the listed track is sub-tiered
Unlike Australia’s single Chapter 2M test, Singapore captures entities through two separate instruments. Which one applies decides your first reporting year, your assurance date, and whether Scope 3 is mandatory or voluntary. The roadmap for both is shaped by the Sustainability Reporting Advisory Committee (SRAC).
Listed issuers (SGX-ST Listing Rules)
All SGX-listed issuers report Scope 1+2 from FY2025. The track is sub-tiered: STI constituents with market capitalisation of S$1 billion or more carry the heaviest near-term obligations (including mandatory Scope 3 from FY2026); other listed issuers follow a later schedule. Administered by SGX RegCo.
Large non-listed companies (Companies Act)
Large non-listed companies (NLCos) are brought in separately from FY2030, on a narrow size gate. Administered by ACRA. This track is the Singapore analogue of Australia’s company-level mandate, but with a much tighter net — see Step 1.
When to Use This Methodology
- You are an SGX-listed issuer determining your cohort and first reporting year
- You are a large non-listed company assessing the ACRA company-level mandate
- You need to reconcile group IFRS S2 reporting to Singapore’s adopted requirements
- You are building the Scope 1, 2, and (where required) Scope 3 metric for a Singapore reporting entity
- You are integrating the carbon tax as a financial-materiality input to your Strategy pillar
- You report only under the EU regime — use the CSRD ESRS E1 methodology
- You report only to the US SEC — use the SEC climate disclosure methodology
- You report under Australia’s regime — use the AASB S2 methodology
- You are computing facility-level carbon-tax liability rather than disclosing emissions — that is a separate obligation under the Carbon Pricing Act, though the data feeds your Scope 1 figure
Provider directory
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Step 1 — Which Cohort Captures You
Four cohorts, two instruments. Your cohort sets your first reporting year, whether Scope 3 is mandatory, when limited assurance begins, and when the full ISSB-aligned climate-related disclosures (CRD) apply. Misreading the cohort is the highest-leverage error on this page.
| Cohort | First reporting FY | Scope 1+2 GHG | Scope 3 | Full ISSB-aligned CRD | Limited assurance (S1+2) |
|---|---|---|---|---|---|
| STI constituents, market cap ≥ S$1bn | FY2025 | FY2025 | FY2026 | FY2028 | FY2029 |
| Non-STI listed, market cap < S$1bn | FY2025 | FY2025 | Voluntary | FY2030 | FY2029 |
| Large non-listed companies (NLCos) | FY2030 | FY2030 | Voluntary | FY2030 | FY2032 |
Source: ACRA Sustainability reporting requirements & timeline; SGX-ST Listing Rules; roadmap shaped by the Sustainability Reporting Advisory Committee (SRAC). NLCo timeline extended from FY2027 to FY2030 — see the callout below.
First: the large non-listed company start date was extended from FY2027 to FY2030, with their limited assurance from FY2032. Plans built on the earlier FY2027 date are out of date. Second: only STI constituents have mandatory Scope 3 (from FY2026). For every other listed issuer and for NLCos, Scope 3 is voluntary until further notice — not deferred to a known later year. Do not build the disclosure as though Scope 3 is universally mandatory in Singapore; it is not.
The SGX listed-issuer track
All SGX-listed issuers report Scope 1+2 GHG from FY2025. The split that matters is the STI-constituent test, fixed by market capitalisation: an issuer’s market cap is assessed at the close of market on 30 June 2025, and the resulting obligation persists even if the cap later falls below the threshold. STI constituents at S$1 billion or more take on mandatory Scope 3 from FY2026 and the full ISSB-aligned CRD from FY2028; non-STI issuers below that line reach full CRD in FY2030.
The ACRA company-level track and the AND test
The large non-listed company gate is the single biggest structural difference from Australia. It is an AND test, not a two-of-three test:
A company is a large NLCo only if it has annual revenue of S$1 billion or more and total assets of S$500 million or more. Both are required. This is materially narrower than Australia’s AASB S2 gate, where meeting any two of three criteria captures the entity. A Singapore company with S$1.2 billion revenue but S$300 million in assets is out; the equivalent entity would likely be in under AASB S2. The AND test is why Singapore’s non-listed perimeter is small and concentrated in the largest private groups.
One relief narrows the NLCo perimeter further. A large NLCo whose parent already reports climate-related disclosures using ISSB-aligned local standards or an equivalent such as the EU’s ESRS is exempt from reporting and filing separately with ACRA, provided the subsidiary’s activities are covered in the parent’s report and that report is public. NLCos whose parent reports under other international frameworks (for example GRI or the legacy TCFD recommendations) receive the same exemption for a transitional period. The effect is that a Singapore subsidiary inside a group already disclosing at parent level generally does not file a second, standalone Singapore climate statement.
Cohort decision logic
Step 2 — The Four-Pillar Disclosure Architecture
Singapore’s regime is climate-first and ISSB-aligned: IFRS S2 is the backbone, while IFRS S1 (broader sustainability) is encouraged rather than mandatory. The disclosure is organised around the same four pillars that the TCFD recommendations established before that framework sunset in October 2024 and the ISSB took over. The clause references below are the IFRS S2 paragraphs the Singapore requirements track.
How Singapore’s regime relates to IFRS S2
Singapore adopts ISSB-aligned climate-related disclosure requirements built on IFRS S2, with the climate-first relief pattern that lets entities focus on climate before broader sustainability topics. The single largest practical consequence for Pillar 4 — and the cleanest contrast with Australia — is that Singapore takes IFRS S2 on a full-alignment basis, so the industry-based metric package is retained:
Singapore incorporates IFRS S1 and S2 into the SGX Listing Rules on a full-alignment basis: listed issuers report climate-related disclosures in accordance with all applicable requirements of IFRS S2. That means the SASB-derived industry-based metrics required by IFRS S2 — industry-specific disclosures spanning 11 sectors — are in. This is the headline contrast with Australia’s AASB S2, which explicitly dropped those industry metrics. A group preparing both an Australian and a Singapore disclosure cannot reuse a single Pillar 4 metric set: Singapore expects the full IFRS S2 industry-metric package, Australia does not.
Singapore requires GHG measurement in line with IFRS S2, which routes to the GHG Protocol, but neither the SGX Listing Rules, the ACRA roadmap, nor the IFRS Foundation Singapore jurisdictional profile states which IPCC Assessment Report supplies the global warming potentials verify. Do not default to AR6. Confirm the GWP basis against the adopted requirements and NEA guidance before printing any GWP multiplier, and state the basis explicitly. This is left as a confirm-before-publish marker because it could not be located in any primary source.
Step 3 — Building the GHG Metric (Scope 1, 2, 3)
The quantitative core is the absolute gross emissions figure, measured on the GHG Protocol Corporate Standard basis and broken out by scope. Scope 1+2 is the universal listed-issuer obligation from FY2025; Scope 3 is mandatory only for STI constituents (from FY2026) and voluntary for everyone else.
Measurement basis and GWP
Activity data becomes a CO2e figure by applying emission factors and global warming potentials. The GWP basis to apply verify must be confirmed against the adopted Singapore requirements and NEA guidance rather than defaulted to AR6 — the same GWP trap that produces inconsistent disclosures in other jurisdictions. State the basis you used explicitly and apply it consistently across all scopes and years.
Scope 2 in a gas-dominated grid: location vs market-based
Scope 2 method choice is unusually consequential in Singapore because the grid is overwhelmingly natural-gas-fired, so the location-based grid-average factor is both high and relatively uniform. Under the GHG Protocol, the location-based method uses that grid-average factor, while the market-based method reflects contractual instruments such as renewable energy certificates. The extent to which a Singapore entity can lower its market-based figure depends on the domestic instrument market verify — confirm the available REC/EAC instrument rules before asserting how constrained that market is. Whichever method you adopt, apply it consistently and disclose the contractual instruments behind any market-based claim.
Worked example — Scope 1 + Scope 2 for a listed issuer
A single physical inventory shown under both Scope 2 methods, to make the location-vs-market gap concrete. Figures are illustrative and computed for this example; they are an audit-trail snapshot, not a live factor lookup. The Scope 2 factors used are placeholders pending the verified Singapore grid factor and GWP basis.
Scope 1 — onsite gas combustion: 18,000 tCO2e
Scope 2 — purchased electricity: 30,000 MWh
Grid factor (location-based, illustrative): 0.40 tCO2e/MWh Scope 2 factors are placeholders. The location-based grid factor and the GWP basis must be replaced with the verified Singapore values before publication. Market-based column assumes 8,000 MWh covered by instruments at a 0.05 tCO2e/MWh contractual factor, illustrative only.
Step 4 — Scope 3 and the Transition Relief
Scope 3 — the value-chain emissions covered by the GHG Protocol Scope 3 Standard — is the cohort-dependent obligation, and the distinction is sharper than in most regimes:
STI constituents at S$1 billion or more must disclose Scope 3 from FY2026. For all other listed issuers and for large NLCos, Scope 3 is voluntary until further notice — a standing position, not a deferral to a known later year. Where Scope 3 applies, the measurement methodology is in line with IFRS S2, which permits the use of reasonable and supportable information available without undue cost or effort, including reasonable estimates (IFRS S2 Scope 3 measurement provisions). For financial institutions, Category 15 financed emissions follow the PCAF financed-emissions standard.
Even where Scope 3 is voluntary, screening all fifteen categories for materiality is worthwhile: it builds the data pipeline ahead of any future mandate and supports the Strategy-pillar narrative. The market-based Scope 2 methodology and the broader SBTi target methodology are the natural companions for an entity moving from disclosure to reduction.
Step 5 — Climate Scenario Analysis
Scenario analysis sits in the Strategy pillar and is part of the ISSB-aligned climate-resilience assessment: the entity considers how its strategy and business model hold under different climate-related scenarios across short, medium, and long-term horizons. The construction mechanics — building physical-risk and transition-risk scenarios on a two-axis structure — are covered in the TCFD scenario analysis methodology, which the ISSB approach inherits. For a Singapore entity, the carbon-tax trajectory is a concrete transition-risk driver to feed into the analysis (see Step 7), and the heavy exposure of the gas-fired grid makes energy-price and decarbonisation pathways especially material.
Step 6 — The Assurance Roadmap
External limited assurance over Scope 1+2 GHG phases in by cohort. Assurance is provided by ACRA-registered audit firms or SAC-accredited providers, and the GHG figures can be verified against the ISO 14064-3 verification principles your provider applies. The roadmap escalates by cohort rather than by a single national date:
Confirm the exact assurance-scope progression and any subsequent move toward reasonable assurance against the current ACRA requirements before committing assurance dates in your plan — the roadmap is set by regulator instrument and has been refined since first publication.
Step 7 — The Carbon Tax Interaction
Singapore’s carbon tax, set under the Carbon Pricing Act 2018 (as amended), is the local analogue of Australia’s Safeguard Mechanism interaction — and a clean, quantifiable transition-risk input to the Strategy pillar. It applies to facilities emitting 25,000 tonnes of CO2e a year or more, covering roughly 50 facilities and about 70% of national emissions across power, manufacturing, waste, and water. The rate is on a steep upward path:
For a covered facility, the tax converts a tonne of Scope 1 emissions into a direct, escalating cash cost — the kind of quantified transition exposure the Strategy pillar exists to surface. An entity disclosing under this methodology should reconcile the Scope 1 inventory it reports against the emissions it reports for carbon-tax purposes; a divergence between the two is an obvious assurance and regulatory flag.
Moving from disclosure to a reduction target against this rising cost? The SBTi Absolute Contraction Approach methodology covers the target-trajectory maths.
Singapore vs IFRS S2 vs AASB S2 vs the Other Regimes
Singapore sits in the converging family of ISSB-based mandatory climate-disclosure regimes. The differences below drive what a multi-jurisdiction group can share and what it must prepare separately.
| Regime | Basis | Non-listed capture test | Scope 3 | Distinctive feature |
|---|---|---|---|---|
| Singapore (this page) | IFRS S2 on a full-alignment basis, climate-first | AND test: revenue ≥ S$1bn and assets ≥ S$500m | Mandatory only for STI constituents; voluntary otherwise | Full-alignment: SASB industry metrics retained; two-track (SGX + ACRA); carbon tax to S$50–80 by 2030 |
| Australia AASB S2 | Modified adoption of IFRS S2 | Two-of-three size test (much wider net) | Mandatory from year 2 for all in-scope entities | Three-year modified-liability period; SASB metrics dropped |
| IFRS S2 | ISSB baseline | Jurisdiction-dependent | Mandatory, with transition reliefs | The global baseline; requires SASB §32 industry metrics |
| EU CSRD / ESRS E1 | EU Sustainability Reporting Standards | Size-based, broad | Mandatory under double materiality | Double materiality — impact and financial |
| US SEC rules | SEC final rule | Registrant-based | Excluded from the final rule | Filer-tier phase-in; subject to legal challenge |
Implementation Workflow
An ordered readiness sequence for a Singapore reporting entity. The voluntary Scope 3 status for most cohorts and the FY2030 NLCo start mean the early steps are about cohort confirmation and Scope 1+2 quality, not full-inventory completeness.
Error Traps — With Consequence Magnitudes
| Error | What happens | Consequence | How to avoid |
|---|---|---|---|
| Plan to the superseded FY2027 NLCo start | Large-company readiness built around the original FY2027 date before the extension to FY2030. | Resources committed years early, or a plan calendar anchored to a date that no longer applies. | Large NLCos start FY2030, limited assurance FY2032. Source the date from ACRA’s current timeline. |
| Treat the NLCo gate as a two-of-three test | An entity meeting one threshold (e.g. revenue) is assumed captured, as it would be under AASB S2. | Mis-scoping in either direction — needless reporting, or a missed obligation if both thresholds are in fact met. | It is an AND test: revenue ≥ S$1bn and assets ≥ S$500m. Both required. |
| Assume Scope 3 is mandatory for all listed issuers | A non-STI listed issuer builds a mandatory Scope 3 inventory it does not yet owe. | Disproportionate first-year effort; possible mis-statement of the basis of preparation. | Only STI constituents have mandatory Scope 3 (FY2026). For others it is voluntary until further notice. |
| Default the GWP basis to AR6 without checking | GWP multipliers applied from AR6 when the adopted requirements may specify a different report. | A non-compliant or inconsistent CO2e figure that fails assurance. | Confirm the GWP basis against the adopted requirements and NEA before computing; state it explicitly. |
| Overstate market-based Scope 2 reductions | Market-based claims made beyond what the domestic instrument market actually supports. | Unsupportable Scope 2 figure; greenwashing and assurance risk in a gas-dominated grid. | Confirm the available REC/EAC instrument rules; disclose every instrument behind a market-based claim; always report location-based alongside. |
| Diverge from carbon-tax reported emissions | The disclosed Scope 1 number does not reconcile to the facility’s carbon-tax filing. | An obvious assurance and regulatory flag; raises which number is correct. | Reconcile the AASB-style Scope 1 inventory to the carbon-tax report using the same activity data. |
Reporting and Documentation Metadata
For your climate statement’s basis-of-preparation note. Confirm the bracketed and flagged lines against the adopted Singapore requirements before finalising.
Does this regime apply to you? Scoping is a separate question from reporting, and the six regimes use six different size tests. For the thresholds side by side — revenue, public float, turnover, balance sheet and headcount — with first reporting years and assurance phase-ins, see Regulatory Thresholds.
Frequently Asked Questions
Singapore runs two tracks. On the SGX track, all listed issuers report Scope 1+2 from FY2025; STI constituents with market capitalisation of S$1 billion or more (assessed at close on 30 June 2025) add mandatory Scope 3 from FY2026 and full ISSB-aligned disclosures from FY2028, while other listed issuers reach full disclosures in FY2030. On the ACRA track, large non-listed companies are captured from FY2030, but only if they have annual revenue of S$1 billion or more and total assets of S$500 million or more — both thresholds are required. Limited assurance over Scope 1+2 begins FY2029 for listed issuers and FY2032 for large NLCos.
Only for STI constituents, from FY2026. For all other listed issuers and for large non-listed companies, Scope 3 is voluntary until further notice — a standing position rather than a deferral to a known later year. Where it applies, value-chain emissions follow the GHG Protocol Scope 3 Standard, and financed emissions follow PCAF. Even where voluntary, screening all fifteen categories for materiality builds the data pipeline ahead of any future mandate. The precise first-year estimate-relief wording for STI constituents should be confirmed against the SGX Listing Rules.
Singapore uses an AND test: a large non-listed company must have annual revenue of S$1 billion or more and total assets of S$500 million or more. Both are required, so a single sub-threshold metric removes the obligation. Australia’s AASB S2 uses a two-of-three size test, where meeting any two of three criteria captures the entity. The practical effect is that Singapore’s non-listed reporting net is much narrower and concentrated in the largest private groups, while Australia’s is far broader.
The GHG metric is measured on the GHG Protocol Corporate Standard basis, with Scope 2 reported location-based and, where contractual instruments are held, market-based as well. The specific GWP basis — which IPCC Assessment Report supplies the global warming potentials — should be confirmed against the adopted Singapore requirements and NEA guidance rather than defaulted to AR6, and stated explicitly in the basis of preparation. In a gas-dominated grid the location-based Scope 2 figure is the high, comparable baseline, so the location-versus-market choice is unusually consequential.
Singapore’s carbon tax, under the Carbon Pricing Act 2018 (as amended), applies to facilities emitting 25,000 tonnes of CO2e a year or more — about 50 facilities and roughly 70% of national emissions. The rate is S$25/tCO2e in 2024–25, rises to S$45 in 2026–27, and targets S$50–80 by 2030 (a range, not a fixed figure). For a covered facility this converts Scope 1 emissions into a direct, escalating cash cost, making it a clean transition-risk input to the Strategy pillar. Reconcile your disclosed Scope 1 inventory to the emissions you report for carbon-tax purposes — a divergence is an assurance and regulatory flag.
Singapore adopts ISSB-aligned climate-related disclosure requirements built on IFRS S2, applied climate-first — IFRS S2 is mandatory while the broader IFRS S1 is encouraged rather than required. Crucially, the climate-related disclosures are incorporated into the SGX Listing Rules on a full-alignment basis, so listed issuers report against all applicable requirements of IFRS S2 — including the SASB-derived industry-based metrics. That is the key difference from Australia’s AASB S2, which dropped those industry metrics. The one detail still to confirm against the adopted requirements is the GWP basis (which IPCC Assessment Report supplies the global warming potentials), which is not specified in the published primary sources.
External limited assurance over Scope 1+2 GHG begins FY2029 for listed issuers and FY2032 for large non-listed companies, tracking their later FY2030 reporting start. Assurance must be provided by ACRA-registered audit firms or SAC-accredited providers, and the GHG figures can be verified against ISO 14064-3 principles. Confirm the exact assurance-scope progression and any later move toward reasonable assurance against ACRA’s current requirements before committing assurance dates.