Bursa NSRF Group 1: what changes before 1 January 2027

Group 1 has been disclosing climate information under Malaysia's National Sustainability Reporting Framework since 2025. The larger change is closer than it looks: full IFRS S1 and IFRS S2 application, and Malaysia's stated aim to require reasonable assurance over Scope 1 and Scope 2 emissions, both land on 1 January 2027, the start of the same reporting period.

Who Group 1 is

Group 1 covers Main Market listed issuers, corporations, REITs and business trusts, with market capitalisation of MYR2 billion or more as at 31 December 2024, or at the date of listing if an issuer listed after that date. It is the largest-capitalisation cohort under the NSRF and the first to reach every phase-in date.

The framework itself was released on 24 September 2024 by the Advisory Committee on Sustainability Reporting, chaired by the Securities Commission Malaysia and including the Audit Oversight Board, Bank Negara Malaysia, Bursa Malaysia, the Companies Commission of Malaysia and the Financial Reporting Foundation. Bursa Malaysia amended its Main Market and ACE Market Listing Requirements on 23 December 2024 to require a sustainability statement prepared in accordance with IFRS S1 and IFRS S2, phased in by group.

Two dates, not one

Every NSRF group carries two dates: a climate-first date, when climate-related disclosure under IFRS S2 begins, and a full-application date, when the full scope of IFRS S1 and IFRS S2 applies. Group 1 reached the first date already. The second is what this page is about.

Group and date structure quoted directly from the IFRS Foundation's jurisdictional profile for Malaysia, updated 12 June 2025, read 2026-09-17. Full detail on all three groups, and on the majors outside Malaysia, is in IFRS S2 adoption by jurisdiction.

For a calendar-year reporter, Group 1 is currently inside its second climate-first year, the period beginning 1 January 2026. The period beginning 1 January 2027, the first year of full application, starts a little over three months after this page was written.

What changes on 1 January 2027

Four things change at once for Group 1, and treating any one of them as the whole of it is the most common way to run out of runway.

The disclosure scope widens. Climate-first lets an entity apply IFRS S1 only insofar as it relates to the climate information required by IFRS S2. From the period beginning 1 January 2027, the full scope of IFRS S1 applies alongside IFRS S2: governance, strategy, risk management and metrics and targets, not narrowed to climate.

Scope 3 becomes part of that scope. The ISSB baseline lets an entity omit Scope 3 GHG emissions in its first year of applying IFRS S2. Malaysia extends that to two annual reporting periods for Group 1. Read together with the dates above, that covers the periods beginning 1 January 2025 and 1 January 2026, meaning Scope 3 becomes part of what Group 1 discloses from the period beginning 1 January 2027, the same period full application begins. That reading is this page working through two separately dated facts, the two-period duration and the full-application date, rather than a single sentence quoted from the source. Treat it as the working assumption, not a separately confirmed deadline.

The principal-business-segments relief narrows to the full entity. Malaysia permits an entity to focus its climate disclosures on its principal business segments, rather than the full reporting entity, for two annual reporting periods for Group 1. By the same arithmetic as above, that relief runs out at the same point: full-entity scope from 1 January 2027. This is a Malaysia-only addition, not present in IFRS S1 or IFRS S2 at all. A full comparison of this and the other Malaysia-specific reliefs is in Malaysia's IFRS S2 transition reliefs.

Comparative information already applies, and did before this date. Malaysia's own list of extensions to the ISSB baseline does not include the comparative-information relief (IFRS S1 paragraph E3, replicated at IFRS S2 paragraph C3). The unextended, one-year ISSB default applied to Group 1's first year of applying IFRS S1, the period beginning 1 January 2025. On that reading, comparative information has applied to Group 1 since the period beginning 1 January 2026, not from 2027. It is the one relief on this list that has already run out.

The reasonable assurance target, and what is still unsettled

Malaysia's stated aim is to mandate reasonable assurance on Scope 1 and Scope 2 GHG emissions for Group 1, from annual reporting periods beginning on or after 1 January 2027, the same date full IFRS S1 and IFRS S2 application begins. Reasonable assurance is the higher of the two engagement types the applicable global baseline standard, the International Standard on Sustainability Assurance 5000, covers; the exact paragraph-level detail of how ISSA 5000 itself distinguishes limited from reasonable assurance was not independently verified in the regulatory research behind this page.

As of the most recent regulatory reading behind this page, 17 September 2026, this remained a stated aim rather than a finalised requirement. The source itself describes the sustainability assurance framework as still subject to consultation. It is not a settled rule, and it is not confirmed to apply from the exact date above rather than a later one.

ISSA 5000 becomes the reference standard for engagements on periods beginning on or after 15 December 2026, with early application permitted in most jurisdictions. If Malaysia's stated aim is finalised as read, Group 1's first fully-applied period would fall inside that window. In Malaysia, auditors of public interest entities are regulated by the Securities Commission's Audit Oversight Board, established 1 April 2010; whether its remit has been or will be extended to sustainability assurance practitioners specifically is not confirmed in the source read for this page.

Nothing in the source read for this page states an assurance date for Group 2 or Group 3. Treat that as an open question rather than an absence of a future requirement.

Malaysia's reliefs, and where they run out for Group 1

Malaysia both extends and removes pieces of the ISSB's own transition-relief package, and adds one relief of its own. For Group 1 specifically, the picture is:

The "Ends" column for the first three rows is this page's own reading of two dated facts held together, not a separately quoted deadline; see the caveats in the section above. The full detail behind every row, including how the durations differ for Group 2 and Group 3, is in Malaysia's IFRS S2 transition reliefs, sourced to the same regulatory baseline.

Publication timing is worth stating plainly on its own: Malaysia removed the relief that lets an entity publish its sustainability statement after its financial statements. That was never available to Group 1, or to any group, in any year. The sustainability statement publishes alongside the financial statements, from the first cycle.

What to have in place before period start

None of the four changes above are exotic. What tends to catch a Group 1 reporter out is treating them as one project rather than four with different runways.

• The consolidation boundary for the full entity. If disclosure has been scoped to principal business segments, the entities and activities outside that scope need to be brought in before the period beginning 1 January 2027, not during it.
• Scope 3 categories and data sources. If Scope 3 has been omitted under the relief, the category boundary, the data sources and the calculation method need to exist before the figure has to be published, not after.
• Comparative-period data. On the reading in this page, comparative information already applies. If the period beginning 1 January 2026 has not been tracked with that in mind, that gap gets harder to close the longer it is left.
• A methodology that survives comparison. Reasonable assurance, when and if it lands, tests consistency year over year: the same emission factor source, the same Scope 2 method, the same boundary. A method chosen and recorded once is easier to defend than one reconstructed after the fact.
• A preparer, reviewer and approver record. Reasonable assurance is a materially higher bar than limited assurance. The evidence an assurance provider tests starts with who entered a figure, who reviewed it, and who approved it, captured as it happens rather than reconstructed from an email thread when the engagement begins.

For how Malaysia's reliefs compare to the ISSB baseline in full, including Group 2 and Group 3, see Malaysia's IFRS S2 transition reliefs. For what an assurance provider actually tests once reasonable assurance applies, see what auditors check in a first-cycle IFRS S2 review. Or have a look at the product.

Common questions