Singapore Exchange's mandatory climate-related disclosure rules entered force for issuers in priority sectors for financial year 2025 onwards. The phased rollout — building on years of voluntary disclosure work — makes Singapore one of the world's fastest ISSB adopters and creates immediate practical compliance obligations for hundreds of SGX-listed issuers.
For the priority sectors — financials, agriculture, food and forest products, energy, and materials and buildings — the FY 2025 climate report is the first mandatory ISSB-aligned disclosure they have produced. For non-priority sectors, FY 2026 reporting brings them into scope on a phased basis.
This guide covers scope, sector-specific requirements, the SGX–MAS interaction, and what compliance teams should plan for.
The Priority Sector Architecture
SGX's mandatory climate disclosure rules apply in two phases:
Phase 1 — Priority sectors (FY 2025 onwards)
Mandatory ISSB-aligned climate disclosure for issuers in:
- Financials — banks, insurers, capital markets services holders
- Agriculture, food, and forest products — palm oil, timber, rubber, food production
- Energy — oil & gas, mining, energy utilities
- Materials and buildings — chemicals, cement, construction materials, real estate
These sectors were selected because the Task Force on Climate-related Financial Disclosures (TCFD) identified them as the sectors with the most material climate-related financial risks.
Phase 2 — All other listed issuers (FY 2026 onwards)
All other Mainboard-listed issuers (and selected Catalist issuers subject to size and other criteria) come into mandatory scope from FY 2026 reporting.
The phased approach gives non-priority sectors an additional year to build data infrastructure, develop scenario analysis capability, and establish governance arrangements.
Required Disclosure Content
SGX rules incorporate ISSB IFRS S2 directly. The disclosures follow the four pillars:
Governance
- Board oversight responsibilities for climate-related risks and opportunities
- Management committee structure and reporting lines
- Integration of climate considerations into board agenda, decisions, and director competence
Strategy
- Identification of climate-related risks and opportunities affecting the entity
- Description of business model and strategic implications
- Scenario analysis — including transition and physical risk scenarios
- Transition plan disclosure where one exists
- Financial effects — current and anticipated effects on financial position, performance, and cash flows
Risk Management
- Processes for identifying, assessing, prioritising, and monitoring climate-related risks
- Integration with overall enterprise risk management framework
- Treatment of opportunities alongside risks
Metrics and Targets
- Scope 1 and Scope 2 GHG emissions — required from Year 1
- Scope 3 GHG emissions — Year 1 reliefs apply; required thereafter
- Industry-based metrics — cross-referenced to applicable SASB-derived standards
- Climate-related targets — base year, methodology, milestones
- Internal carbon pricing if applied
- Climate-linked remuneration if applicable
Where SGX Disclosure Lives
The mandatory climate statement is integrated into the issuer's sustainability report, which is itself a mandatory disclosure under SGX listing rules.
The sustainability report is filed separately from but referenced in the annual report. SGX-listed issuers must publish their sustainability report within five months of financial year-end — earlier than the annual report deadline for many issuers.
For priority sector issuers reporting FY 2025 (typically year-ended 31 December 2025 or 30 June 2026), this creates a tight first-year timeline.
How MAS Environmental Risk Management Interacts
Separate to SGX listing rules, the Monetary Authority of Singapore (MAS) supervises environmental risk management at banks, insurers, and asset managers.
The MAS Environmental Risk Management Guidelines apply to:
- Banks (commercial banks, merchant banks, finance companies)
- Insurers (direct general, direct life, reinsurers, captive insurers)
- Asset managers (capital markets services licence holders)
Key requirements under the MAS guidelines:
- Governance of environmental risk at board and senior management level
- Risk assessment integration of environmental factors
- Capacity building including staff training
- Disclosure of environmental risk management approach
For SGX-listed financial institutions, the MAS guidelines and SGX climate disclosure rules apply in parallel — the MAS guidelines focus on internal risk management processes, while SGX rules focus on external disclosure. The two regimes are coordinated but not duplicative.
Sector-Specific Considerations
Financials
Financial issuers face the most complex Scope 3 emissions calculation challenge. Financed emissions (Category 15 under the GHG Protocol) typically represent 95%+ of total emissions for banks and asset managers.
MAS has been actively engaged in financed-emissions methodology development through the NGFS and Singapore Green Finance Industry Taskforce. PCAF (Partnership for Carbon Accounting Financials) methodologies are the de facto standard for Singapore-based financial institutions.
Agriculture and forest products
Palm oil, timber, and rubber operations face particular scrutiny under physical risk scenarios and on biodiversity-related disclosures. Singapore-listed agribusinesses with operations in Indonesia and Malaysia must address deforestation, peatland, and labour considerations.
The MAS-supported Singapore-Asia Taxonomy includes specific guidance on agriculture and land use that interacts with these disclosure requirements.
Energy
Oil & gas issuers face the most extensive transition risk scrutiny. Transition plan disclosure is essentially expected for these issuers, even where IFRS S2 frames it as "if you have one."
Scope 3 Category 11 (use of sold products) for energy companies is typically 80%+ of total emissions and is one of the most-scrutinised disclosures.
Materials and buildings
Construction materials (cement, steel, glass) face significant transition risk from decarbonisation pressure. Real estate issuers face physical risk from sea level rise and heat, particularly relevant to Singapore-based REITs with portfolios across Southeast Asia.
Assurance Requirements
Independent assurance is becoming progressively expected, though SGX has phased the requirements:
- Year 1: assurance not mandatory but encouraged for Scope 1 and Scope 2 emissions
- Subsequent years: phased introduction of limited and then reasonable assurance, with MAS-supervised financial institutions facing earlier and tighter expectations
- Voluntary "limited assurance ready" approaches are common among first reporters wanting to signal data quality
The Institute of Singapore Chartered Accountants (ISCA) has developed local sustainability assurance standards aligned with ISAE 3410 and the new ISSA 5000.
Common Singapore Compliance Mistakes
- Treating it as a TCFD update. SGX rules incorporate IFRS S2, which is meaningfully broader and more prescriptive than TCFD. Scope 3, industry metrics, and quantitative financial effects are major additions.
- Underestimating Scope 3 readiness. Even with Year 1 reliefs, Scope 3 disclosure is required thereafter. Most issuers underestimate the time to build credible Scope 3 data.
- Disconnecting SGX disclosure from MAS supervision. Financial issuers need a coordinated approach across both regimes. SGX disclosure feeds into MAS supervisory dialogue.
- Generic scenario analysis. Boilerplate scenarios attract enforcement attention. Singapore-relevant physical risk scenarios (heat, sea level rise, regional supply chain disruption) require entity-specific work.
- Late assurance engagement. Independent assurance requires evidence and controls. Assurance providers need 6+ months of engagement before reporting — engaging them at report drafting is too late.
What to Watch in the Next 12 Months
- ACRA proposals for sustainability disclosure by non-listed companies
- MAS climate scenario stress testing results and supervisory follow-up
- Singapore-Asia Taxonomy continued development and integration with disclosure
- IFRS S2 application guidance updates from ISSB affecting Singapore-adopted standards
- Phase 2 onset — non-priority sector issuers preparing for FY 2026 reporting
How ESGFlux Helps
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