SGX listing rules on sustainability reporting (Rules 711A and 711B, and Practice Note 7.6)

The three instruments, and what each one does

Rule 711A - when you must publish. An issuer must issue a sustainability report to shareholders and to the Exchange for its financial year at the same time as it issues its annual report. If the issuer has obtained external assurance on the sustainability report, the deadline extends to no later than 5 months after the end of the financial year.

Rule 711B - what must be in it. The rule lists the primary components of a sustainability report:

• (a) material environmental, social and governance factors
• (aa) climate-related disclosures
• (b) policies, practices and performance
• (c) targets
• (d) the sustainability reporting framework used
• (e) a board statement and the associated governance structure

Rule 711B(4) then provides: "The primary component in Rule 711B(1)(aa) must comply with the requirements on climate-related disclosures set out in Practice Note 7.6."

That single sentence is what converts climate reporting from optional to mandatory. The non-climate components continue to work on a comply-or-explain basis, meaning an issuer may leave one out provided it says so and explains why. The climate component does not work that way.

Practice Note 7.6 - the climate content. PN 7.6 adopts IFRS S1 and IFRS S2, the sustainability and climate standards issued by the International Sustainability Standards Board, as the disclosure baseline from FY2025. Those standards build on the earlier TCFD (Task Force on Climate-related Financial Disclosures) recommendations, so companies that already reported against TCFD are not starting from zero.

PN 7.6 requires, among other things:

• Scope 1 and Scope 2 emissions measured in accordance with the GHG Protocol, the most widely used global carbon accounting standard
• Climate scenario analysis demonstrating the company's resilience to different climate futures
• Cross-industry and industry-specific metrics
• Quantified targets over short, medium and long-term horizons
• An explanation of which reporting framework was used

PN 7.6 also recognises other frameworks alongside the IFRS standards, including the GRI Standards, SASB and the Integrated Reporting Framework, for the wider sustainability components.

Relief for first-time reporters

A company reporting for the first time may:

• omit Scope 3 emissions
• use an alternative greenhouse gas measurement methodology
• omit comparative figures for prior years

These reliefs are exactly that - reliefs for year one. They do not remove the obligation in later years.

Amendment history (the two rules differ - do not merge them)

These histories are commonly confused. They are not the same:

Rule 711A has no 1 January 2025 amendment. Rule 711B does.

Practice Note 7.6 is also versioned. The version effective 25 August 2025 ran only to 31 December 2025 and was replaced by a version effective 1 January 2026. Always check the version date on the rulebook page rather than relying on a saved copy.

Catalist

Catalist, SGX's board for smaller and growing companies, has its own Rules 711A and 711B at separate rulebook addresses. They are generally treated as equivalent to the Mainboard rules, but the Catalist text should be read directly rather than assumed identical.

The board's role

The board must determine which environmental, social and governance factors are material to the company, and oversee how they are managed and monitored. Under Rule 711B(3) the sustainability reporting process must be subject to internal review, and the issuer may additionally commission independent external assurance. External assurance is optional until the assurance dates set out in the ACRA / SGX RegCo timetable (see the phase-in entry).

Penalties

Consequences of non-compliance are not stated here because they were not confirmed against a primary source during research. Do not assume there are none - check with SGX RegCo or your listing adviser.

The three source documents

• Rule 711A: https://rulebook.sgx.com/rulebook/711a
• Rule 711B: https://rulebook.sgx.com/rulebook/711b
• Practice Note 7.6: https://rulebook.sgx.com/rulebook/practice-note-76-sustainability-reporting-guide