The ISSB built four transition reliefs into IFRS S1 and IFRS S2 to ease a first cycle. Malaysia's National Sustainability Reporting Framework does not simply adopt them. It extends two, removes one entirely, and adds a fourth that exists nowhere in the global baseline at all, with the duration differing by reporting group.
The ISSB baseline, before Malaysia touches it
Before any jurisdiction extends them, IFRS S1's Appendix E gives an entity applying the standards for the first time three reliefs, plus a fourth relief inside IFRS S2 itself:
| Relief | Paragraph | What it permits | Default duration |
|---|---|---|---|
| Climate-first approach | IFRS S1.E5 | Disclose only climate-related information (per IFRS S2) in the first year of applying IFRS S1 | 1 year |
| Comparative information | IFRS S1.E3 (replicated IFRS S2.C3) | Omit comparative (prior-period) information | 1 year |
| Publication timing | IFRS S1.E4 | Publish sustainability disclosures after the related financial statements | 1 year |
| Scope 3 GHG emissions | IFRS S2, paragraph number not separately verified this cycle | Omit Scope 3 emissions | 1 year |
Paragraph references and the E3-versus-E5 pairing above are the resolved reading from `company/market/regulatory/transition-reliefs.md`: E5 is the climate-first relief, E3 (replicated at IFRS S2.C3) is the comparative-information relief. The full baseline, including how it applies before any jurisdiction touches it, is in IFRS S2 transition reliefs, and is not repeated in full here.
What Malaysia changes
Against that baseline, the NSRF makes four changes. Two reliefs run longer than the ISSB default. One is removed with no exception. One does not exist in IFRS S1 or IFRS S2 at all and is a Malaysian addition on top of the baseline.
| Relief | ISSB baseline | Malaysia's version |
|---|---|---|
| Climate-first (E5) | 1 year | Extended, one additional annual reporting period |
| Scope 3 GHG emissions | 1 year | Extended, one additional annual reporting period |
| Publication timing (E4) | 1 year, permitted | Removed entirely. Disclosures must publish alongside the financial statements, every group, every year |
| Principal business segments | Not in IFRS S1/S2 | Added. A Malaysia-only relief, not present in the ISSB baseline |
| Comparative information (E3) | 1 year | Not extended. Stays at the one-year ISSB default |
The comparative-information row is worth reading twice. It is the one relief Malaysia's own list of extensions does not mention. Three reliefs get more time or get added outright; this one does not, and a reporter who assumes every relief on this page runs on the same clock will misjudge it.
How long each relief runs, by group
Where Malaysia extends or adds a relief, the duration is not the same for every group. It follows the same three-group structure as the phase-in dates themselves.
| Relief | Groups 1 and 2 | Group 3 |
|---|---|---|
| Climate-first (E5) | 2 annual reporting periods | 3 annual reporting periods |
| Scope 3 GHG emissions | 2 annual reporting periods | 3 annual reporting periods |
| Principal business segments | 2 annual reporting periods | 3 annual reporting periods |
| Publication timing (E4) | Not available, any group, any year | |
| Comparative information (E3) | 1 year, the ISSB default, unchanged for every group | |
Duration figures quoted directly from the IFRS Foundation's jurisdictional profile for Malaysia, updated 12 June 2025, read 2026-09-17, cross-referencing Securities Commission Malaysia's Frequently Asked Questions on the NSRF. Group definitions and their own phase-in dates are in IFRS S2 adoption by jurisdiction. What this means specifically for Group 1, including when each relief runs out against that group's own dates, is worked through in Bursa NSRF Group 1: what changes before 1 January 2027; the equivalent for Group 2 is in Bursa NSRF Group 2: what FY2026 reporters need in place.
The principal-business-segments relief, in detail
This is the one relief on this page that is not a longer version of something the ISSB already permits. It lets an entity focus its climate disclosures on its principal business segments, rather than the full reporting entity, for the durations in the table above.
What it narrows is the scope of what is disclosed about: which segments of the business the climate-related information covers. What it does not change is the reporting entity used for whatever an entity does disclose. On the source's own reading, that stays the same reporting entity used for the financial statements. It is a relief on breadth of coverage, not a different consolidation boundary for the figures that are published.
Because it is Malaysia-only, it will not appear in a global checklist built from the ISSB standards alone. A reporter working from an international template, rather than the NSRF's own text, could easily miss that it is available at all.
Why the removed relief matters more than it looks
The publication-timing relief (IFRS S1.E4) looks minor next to the other three. In the ISSB baseline, it lets a first-time reporter publish sustainability disclosures after the related financial statements, buying preparation time in year one. Malaysia's jurisdictional profile states plainly that this relief "has been removed." Not narrowed, not shortened: removed, for every group, in every year, including the first.
The practical effect is that the sustainability statement is on the same clock as the financial statements from day one. There is no separate, later filing deadline to fall back on if the climate figures are not ready when the annual report is. That is a scheduling constraint on the preparation process itself, independent of which other reliefs an entity is using.
Dual reporting and the compliance statement
Malaysia permits dual reporting: an entity may assert compliance with both the ISSB Standards as issued and with Malaysia's own NSRF requirements at the same time. Where an entity does assert compliance, the source is explicit that it must be an explicit, unreserved statement of compliance with the IFRS Sustainability Disclosure Standards as issued by the ISSB. It is a separate fact from the reliefs above, not a conclusion drawn from them: this page does not state, and the source read for it does not say, whether using a particular Malaysia-specific relief in a given year affects whether an unreserved compliance statement can be made for that year. Where that question matters for a specific cycle, it is one to put to the entity's own advisers, not one this page answers.
What this means in practice
Read as a set, the four changes push in one direction: Malaysia gives more time on what gets disclosed, climate-only scope, no Scope 3, a narrower segment boundary, but no time at all on when it gets disclosed. The extensions ease the content of a first cycle. Nothing eases the calendar.
For a reporter planning around these reliefs, the useful question is not "which reliefs can we use" but "on the date each one runs out, what has to already exist." A relief that ends is not a cliff if the underlying data collection started during the relief period rather than after it.
- Do not assume a relief because the ISSB permits it. Malaysia's own list of extensions does not include the comparative-information relief. Working from a global checklist rather than the NSRF's own text is how that gets missed.
- Record which relief was used, for which figures, and for which reporting period. That is the question an assurance provider, or a reader comparing this year's disclosure to next year's, will ask first. A relief used without a record of it having been used is indistinguishable from an omission.
- Treat the segment relief and the reporting entity as two separate decisions. The relief narrows which segments the climate disclosure covers. It does not change which entity the disclosure is prepared for.
- Build toward the state each relief leaves behind, ahead of the state it permits now. The Scope 3 boundary, the full-entity segment coverage, and the same-day publication timetable are all requirements from the point a given relief ends, whether or not that end date has arrived yet.
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Common questions
Does Malaysia extend the comparative-information relief?
No. 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. It stays at the ISSB default: no comparative information required in an entity's first year of applying IFRS S1, for every group.
What is the principal-business-segments relief?
A Malaysia-only addition, not present in IFRS S1 or IFRS S2 at all. It lets an entity focus its climate disclosures on its principal business segments rather than the full reporting entity, for two annual reporting periods for Groups 1 and 2, three for Group 3, while still using the same reporting entity as the financial statements for whatever it does disclose.
Can a Malaysian entity publish its sustainability statement after its financial statements?
No. The ISSB baseline permits this for one year under IFRS S1 paragraph E4. Malaysia removed that relief entirely: the sustainability statement must publish at the same time as the financial statements, for every group, in every year, including the first.
How long do Malaysia's extended reliefs last for Group 3?
Three annual reporting periods, one longer than Groups 1 and 2 get. That applies to the climate-first relief, the Scope 3 omission, and the principal-business-segments relief. Group 3 also has the latest full-application date of the three groups, 1 January 2030.