What changed in 2025
In August 2025, ACRA and SGX RegCo announced extended timelines for most of Singapore's climate reporting requirements. The stated reason was to give companies more time to build capability — a reasonable response to a genuinely difficult first reporting cycle.
What survived unchanged is the part that matters most: Scope 1 and Scope 2 greenhouse gas reporting remains mandatory for all listed companies from FY2025. That obligation is live now. Several of the requirements layered on top of it were pushed out:
| Requirement | Applies to | From |
|---|---|---|
| Scope 1 & 2 GHG emissions | All listed companies | FY2025 |
| Other ISSB-based climate disclosures | STI constituents | FY2025 |
| Scope 3 GHG emissions | STI constituents | FY2026 |
| Other ISSB-based climate disclosures | Non-STI, market cap ≥ S$1bn | FY2028 |
| Other ISSB-based climate disclosures | Non-STI, market cap < S$1bn | FY2030 |
| Scope 1 & 2 GHG emissions | Large non-listed companies | FY2030 |
| External limited assurance, Scope 1 & 2 | Phased | FY2032 |
The two shifts most likely to change your planning: large non-listed companies moved from an earlier start to FY2030, and external limited assurance on Scope 1 and 2 was deferred to FY2032.
A framing point that trips people up: Singapore has not adopted IFRS S1 and IFRS S2 wholesale into law. The approach is ISSB-informed and climate-first — key elements of IFRS S2 are embedded in the SGX Listing Rules. If a vendor tells you their tool makes you "IFRS S1 compliant" in Singapore, ask them which rule they are actually mapping to.
Why the extra time is not a reprieve
The instinct after a deadline extension is to reallocate the budget. That is usually a mistake here, for a reason that has nothing to do with regulatory virtue.
The work in climate reporting is not the calculation. Emission factors are published; multiplication is not hard. The work is collecting defensible activity data — litres of diesel, kilowatt-hours by site and tariff, refrigerant top-ups, business travel, supplier fuel use — and being able to show, months later, exactly which invoice produced which number.
That is an operational data problem, and operational data problems take between one and three reporting cycles to get right. Companies that started when the earlier deadline applied are now on their second or third cycle, and their reports take days rather than months to produce. Companies that stopped will start again in FY2029 with the same first-cycle chaos, except with assurance looming.
What assurance actually demands
Limited assurance being deferred to FY2032 sounds distant. It is worth understanding what it will require, because it constrains how you should be recording data now.
An assurance provider does not check your arithmetic. They sample your figures and ask where each one came from. For a sampled number to survive, you need:
- The source document attached to the figure — the actual utility bill, not a transcription of it.
- A record of which emission factor version was applied, and why that one.
- Change history: who altered the input, when, and what it was before.
- A locked period, so the number in the report is provably the number that was signed off.
Spreadsheets fail every one of these tests. Not because spreadsheets are bad, but because they were designed to calculate, not to preserve provenance. This is the single strongest argument for moving off them well before assurance arrives — retrofitting provenance onto three years of historical spreadsheets is considerably worse than capturing it as you go.
Scope 3, and the honest version of it
Scope 3 is where most reporting programmes lose credibility, because the temptation is to report all fifteen categories badly rather than four categories well and document why the rest are immaterial.
The defensible approach is narrower than people expect: identify which categories are material to your business, build a real data collection process for those, and state your reasoning for excluding the others. A supplier engagement workflow — requests, reminders, a completeness view — will do more for your Scope 3 quality than any calculation engine.
If you are an STI constituent, this is already live from FY2026. If you are not, you have time, and the right use of it is building the supplier relationships rather than waiting for a mandate.
What to do in the next quarter
Regardless of which row of that table you sit in:
- Confirm which row you are in. Market capitalisation and index membership change; the obligation follows them.
- Inventory your activity data sources. Not the numbers — the systems and people that produce them. Most companies find between eight and twenty.
- Fix provenance before precision. A slightly rough number with a traceable source beats a precise one nobody can defend.
- Run one full cycle early, even voluntarily. The first cycle teaches you things no gap assessment will.
None of this requires a platform. It is considerably easier with one, which is why we built Karbon0 — but the sequence matters more than the tooling.
