Governance Briefing — Singapore mandatory climate reporting for listed issuers
ISSB-aligned climate reporting playbook for SGX issuers beginning FY2025, detailing governance upgrades, universal opt-out architecture, value-chain controls, and assurance evidence.
Executive briefing: From financial years starting on or after 1 January 2025, every Singapore Exchange (SGX) listed issuer must produce climate disclosures aligned with the International Sustainability Standards Board’s IFRS S2, pursuant to the joint ACRA–SGX sustainability reporting roadmap and Listing Rule 711B. Limited assurance begins with FY2027 reports. Boards must design governance systems that integrate climate oversight with enterprise risk management, orchestrate universal opt-out mechanisms for stakeholder data used in climate metrics, and maintain evidence repositories capable of supporting assurance engagements and Monetary Authority of Singapore (MAS) supervisory dialogues.
Regulatory context and timelines
The 2023 roadmap requires all SGX-listed issuers to adopt ISSB-aligned climate reporting for FY2025, banks and insurers to extend climate reporting to MAS expectations, and large non-listed companies to follow from FY2027. Listed issuers must file climate disclosures within five months of fiscal year-end alongside annual reports. Limited assurance over greenhouse gas metrics and selected disclosures becomes mandatory for FY2027, escalating to reasonable assurance over time. SGX expects issuers to explain how they align with Singapore’s Green Plan 2030, regional taxonomies, and cross-border regulatory requirements, such as the EU’s Corporate Sustainability Reporting Directive when dual-listed.
Issuers should maintain a regulatory tracker capturing SGX circulars, MAS guidelines, and international developments (for example, ISSB updates or ASEAN taxonomy revisions). Governance teams must brief boards quarterly on readiness, including universal opt-out performance metrics, evidence completion status, and assurance planning milestones.
Board governance and oversight
Listing Rule 711B and the SGX Practice Guidance require boards to assume responsibility for sustainability governance, including climate risk strategy, performance targets, and data quality. Boards must identify committees responsible for climate oversight, define skill requirements, and conduct annual effectiveness assessments. Documented board calendars should show when climate topics are reviewed, how scenario analysis and transition plans influence strategy, and how universal opt-out considerations are integrated when stakeholder data underpins disclosures.
Boards should approve a climate governance charter detailing decision rights, escalation paths, and reporting protocols. The charter must align with the company’s risk appetite framework and include responsibilities for monitoring climate-linked incentives, capital expenditure decisions, and supply-chain engagement. Directors require continuous education on IFRS S2, MAS supervisory expectations, and regional climate policies. Training logs and competency matrices belong in the evidence repository to demonstrate oversight diligence during assurance reviews.
Management operating model
Management must establish a climate disclosure steering committee chaired by the CFO, CRO, or Chief Sustainability Officer, comprising leaders from finance, risk, strategy, sustainability, legal, procurement, HR, and IT. The committee should meet monthly in 2024 to address data quality, universal opt-out orchestration, and evidence collection, then quarterly post go-live. Minutes should capture decisions, action owners, and due dates. Integrate the committee with existing disclosure committees to ensure climate narratives align with financial reporting and investor communications.
Operational teams must align data collection processes with IFRS S2 disclosure topics: governance, strategy, risk management, and metrics & targets. Establish data owners for each metric, document data lineage, and define controls for validation, reconciliation, and approval. Universal opt-out controls should be embedded in emissions data pipelines, scenario modelling platforms, and supplier portals. For example, when using employee commute surveys or customer usage data, opt-out requests should be processed via a central preference centre, trigger anonymisation or aggregation workflows, and update downstream systems before reporting. Document the impact of opt-outs on data completeness and describe substitute data sources or estimation techniques.
Scenario analysis and risk management
IFRS S2 requires issuers to disclose climate-related risks and opportunities, their impact on strategy and financial planning, and the resilience of the business under different scenarios. SGX expects robust scenario analysis across multiple time horizons, including at least a 1.5 °C pathway and a disorderly transition or high-physical-risk scenario. Governance teams should document scenario selection criteria, data sources, modelling tools, and board challenge sessions. Maintain evidence of management responses to scenario outcomes, such as capital reallocation, supply-chain diversification, or operational resilience upgrades.
Integrate climate risk into enterprise risk management frameworks by assigning risk owners, defining key risk indicators, and linking climate risks to existing risk categories (strategic, operational, financial, compliance). Risk registers should include universal opt-out considerations when personal data supports risk assessments. Conduct control testing to ensure opt-out events trigger updates to risk dashboards and escalate when data quality thresholds are breached. Store test results, remediation plans, and approvals in the evidence repository.
Metrics, targets, and assurance readiness
SGX mandates disclosure of Scope 1, Scope 2 (market- and location-based), and material Scope 3 emissions, intensity metrics, and climate targets. Issuers must explain methodologies, emission factors, and data sources. With limited assurance beginning in FY2027, companies should implement internal control frameworks analogous to financial reporting: segregation of duties, change control for calculation models, automated reconciliations, and management review checkpoints. Engage assurance providers early to define scope, data requirements, and testing schedules.
Universal opt-out logs must be linked to metrics documentation to demonstrate compliance with regional data protection obligations, including Singapore’s Personal Data Protection Act (PDPA) and cross-border transfer rules. When opt-outs reduce data granularity, disclose the effect on metrics, describe estimation techniques used, and document approvals from management and assurance providers. Maintain evidence packs containing raw data extracts, calculation workbooks, control narratives, exception reports, and assurance communications.
Supply chain and value chain governance
Many Scope 3 categories depend on supplier and customer data. Issuers should update supplier codes of conduct and contracts to include climate data requirements, universal opt-out clauses, and evidence expectations. Provide suppliers with training on data submission, privacy obligations, and assurance readiness. Implement supplier portals or APIs that collect data, propagate opt-out flags, and capture supporting documentation. Conduct periodic supplier audits or attestations to validate data integrity.
For financed emissions (where applicable) and product use-phase data, coordinate with customers to clarify data usage, opt-out rights, and confidentiality protections. Maintain communication logs, consent records, and dispute resolution notes to demonstrate responsible engagement.
Evidence management and reporting integration
Construct a central evidence repository—such as a secure document management system—with role-based access, retention policies, and metadata tagging aligned to IFRS S2 disclosure requirements. Each disclosure topic should have a checklist of required documents: board minutes, policies, training records, data extracts, opt-out logs, scenario models, and assurance reports. Schedule quarterly evidence reviews to verify completeness and accuracy. Integrate the repository with disclosure management software to streamline drafting and approvals.
Align climate disclosures with annual report narratives, sustainability reports, and investor presentations. Establish a disclosure committee workflow that coordinates finance, legal, sustainability, and investor relations teams. Capture sign-offs, challenge logs, and reconciliation records to support assurance and regulatory reviews. Monitor cross-jurisdiction reporting obligations to ensure consistency with EU CSRD, UK TPT, or other frameworks if the issuer operates globally.
Immediate priorities for FY2024-2025
- Run a comprehensive gap assessment. Compare current TCFD or SGX disclosures with IFRS S2 requirements, identify governance, data, and evidence gaps, and assign remediation owners.
- Build universal opt-out infrastructure. Integrate preference centres with climate data systems, establish suppression tests, and document the impact of opt-outs on metrics and scenarios.
- Establish evidence and assurance programmes. Implement a controlled repository, engage assurance providers, and conduct mock walkthroughs covering data lineage, opt-out handling, and control testing.
- Strengthen value chain engagement. Update supplier contracts, launch training, and test data submission portals that enforce opt-out preferences and evidence capture.
- Educate boards and executives. Deliver targeted training on IFRS S2, MAS expectations, universal opt-out implications, and assurance requirements, with attendance logs stored for audit.
Zeph Tech supports SGX issuers by engineering IFRS S2 governance, automating universal opt-out compliance across climate data, and assembling evidence suites ready for limited assurance and regulatory scrutiny.
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