Who must report climate information, and from when: the ACRA / SGX RegCo phase-in (revised 25 August 2025)

Why this entry matters most

Almost every other reporting obligation on this site hangs off this one timetable. If you only read one thing, read this.

Two words are used throughout. Scope 1 means emissions from things your company burns or releases directly, such as fuel in your own boilers, furnaces or vehicles. Scope 2 means emissions produced by the power station that generated the electricity you bought. Scope 3 means everything else in your value chain, such as emissions from suppliers, business travel and the use of the products you sell. Scope 3 is much harder to measure, which is why regulators phase it in last.

ISSB stands for the International Sustainability Standards Board, the global standard-setter whose standards (IFRS S1 and IFRS S2) Singapore has adopted as its climate reporting baseline.

The three tiers for listed companies

"FY2025" means financial years beginning on or after 1 January 2025.

Two details are easy to miss and both cost money if you get them wrong:

• The tiering for STI constituents is fixed by reference to the index as at 30 June 2025, not to whichever companies are in the index today.
• Once a company falls into Tier 2, the obligation stays even if its market capitalisation later drops below S$1 billion.

Large non-listed companies

A company that is not listed on the exchange is caught only if it is a Large Non-Listed Company (Large NLCo), defined as annual revenue of at least S$1 billion AND total assets of at least S$500 million. Both tests must be met; meeting only the revenue test is not enough. That two-limb test is the final rule, and it is stricter than the revenue-only test proposed in 2023.

• ISSB-based climate disclosures, including Scope 1 and Scope 2: from FY2030
• Scope 3: voluntary
• External limited assurance on Scope 1 and 2: from FY2032

An exemption exists where a parent company already prepares equivalent reports covering the subsidiary.

What changed on 25 August 2025, and why

The original roadmap came from the Sustainability Reporting Advisory Committee (SRAC), whose 2023 recommendations were announced on 6 July 2023 and consulted on from 6 July to 30 September 2023. SRAC proposed that large non-listed companies start in FY2027, with assurance from FY2027 for listed issuers and FY2029 for large non-listed companies.

The August 2025 revision moved all of those: large non-listed companies to FY2030, listed-issuer assurance to FY2029, and large-NLCo assurance to FY2032. It also split listed issuers into the three tiers above. The stated reason was that smaller listed companies need more time to build capability, and that the cost of compliance has to be weighed against the benefit.

The practical effect is that the floor stayed (everyone listed reports Scope 1 and 2 from FY2025) while the ceiling moved out by several years for everyone except the largest companies.

Assurance: what "limited assurance" means

Assurance means an independent third party examines your emissions figures and issues a statement about them. Limited assurance is the lighter of the two standard levels: the assurer says nothing has come to their attention suggesting the numbers are materially wrong. It is less work, and less comfort, than reasonable assurance, which is the level applied to audited financial statements.

Only two kinds of firm may provide it: an ACRA-registered audit firm, or a testing, inspection and certification firm accredited by the Singapore Accreditation Council (SAC).

Assurance standards referenced in the Singapore market include a Singapore standard equivalent to ISSA 5000, SSAE 3000 / ISAE 3000, SSAE 3410 / ISAE 3410, and SS ISO 14064-3 (Singapore's national adoption of the international standard for verifying greenhouse gas statements).

Note that ACRA's published timeline sets out limited assurance only. Whether Singapore will later require the stricter reasonable assurance, and on what timetable, has not been announced.

What to do now

1. Work out which tier you are in, using the STI membership position as at 30 June 2025 and your market capitalisation.
2. If you are listed, you are already in scope for Scope 1 and 2 for FY2025 regardless of tier. Start there.
3. Check whether the Sustainability Reporting Grant can co-fund your first report (see the grant entry on this site) - the application deadlines are tied to these same tiers.