Singapore’s regulators have revised the country’s climate disclosure roadmap to ease the reporting burden on smaller companies. While all listed entities must still begin disclosing Scope 1 and 2 greenhouse gas emissions from financial year 2025, most other mandatory sustainability reporting requirements will be delayed for several years. The move aims to balance near-term capability gaps with long-term climate commitments, particularly as Singapore advances toward its 2050 net-zero goal.

Three-Tier Approach to Climate Disclosure

The revised framework, jointly announced by the Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo), introduces a differentiated reporting system. Companies are now grouped into three tiers: Straits Times Index (STI) constituents, non-STI listed firms with market capitalisation above $1 billion, and smaller non-STI companies with capitalisation below that threshold.

Under the updated rules, STI firms will continue on the original timeline. They must begin reporting Scope 3 emissions from financial year 2026 and provide full ISSB-aligned climate disclosures as scheduled. Larger non-STI companies will now begin these more detailed disclosures in FY2028, while smaller listed firms have until FY2030. Scope 3 emissions reporting for both groups will remain voluntary until these deadlines.

Delayed Reporting for Large Unlisted Companies

The timeline has also shifted for large unlisted firms, defined as companies with at least $1 billion in revenue and $500 million in assets. These entities were originally expected to begin reporting Scope 1 and 2 emissions from FY2027, but the new framework defers this requirement until FY2030. External assurance for their emissions data, initially planned for FY2029, is now expected from FY2032. Scope 3 reporting remains optional for this group.

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Regulators Cite Capability Gaps and Practical Concerns

ACRA Chief Executive Mrs Chia-Tern Huey Min said the revised schedule aims to strike a balance between urgency and feasibility. According to her, sustainability reporting is an essential tool for corporate accountability and climate strategy. However, companies that are less prepared need time to build internal systems and develop capabilities.

She added that while more resourceful firms should lead the way, others will benefit from phased implementation. The tiered approach is intended to provide relief in the near term, while still encouraging long-term readiness.

This decision follows a formal request submitted in June by the Singapore Business Federation (SBF), which represents industry voices. In a recent survey by SBF, only 4 percent of small and mid-cap companies expressed strong confidence in meeting the earlier climate reporting deadlines. Many cited insufficient familiarity with disclosure rules, lack of technical resources, and underdeveloped data infrastructure.

SGX RegCo Emphasizes Quality over Speed

SGX RegCo CEO Mr Tan Boon Gin underscored the complexity of producing high-quality, comparable climate disclosures. According to him, companies in the STI index and other large-cap firms are generally better positioned to meet these requirements on time. For smaller businesses, more time is necessary to address technical gaps and ensure robust implementation.

Despite the extensions, one key requirement remains unchanged. All listed firms, regardless of size, must begin reporting Scope 1 and 2 emissions from FY2025. Mr Tan noted that these disclosures are more specific and narrowly defined, which makes them a suitable starting point for learning and systems development.

He added that this mandatory step will give companies a chance to gain experience, preparing them for more complex disclosures in the future.

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Supporting Capacity Building While Advancing Climate Goals

Singapore’s updated framework attempts to preserve momentum on climate transparency while recognizing the practical limitations faced by smaller firms. With 84 percent of SGX-listed companies falling into the small- and mid-cap category, the regulators’ decision reflects a pragmatic approach to inclusivity in climate regulation.

By maintaining the Scope 1 and 2 baseline while extending more complex requirements, the authorities are sending a clear signal. Climate accountability is not optional, but the pace of compliance must be aligned with real-world capacity.

The new approach provides regulatory breathing room without abandoning ambition. As Singapore positions itself as a green finance and sustainability hub, this recalibrated reporting path could offer a replicable model for other markets facing similar challenges.

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