Jurisdictions · Singapore

Singapore is the market that moved its own deadlines, and it moved most of them.

On 25 August 2025, ACRA and SGX RegCo extended the timelines for almost every climate reporting requirement they had set eighteen months earlier. Large non-listed companies went from FY2026 to FY2030. Assurance for those companies went from FY2027 to FY2032. The stated reason was the uncertain global economic environment and feedback about differing levels of readiness.

That makes Singapore the most useful jurisdiction to study if you are trying to decide how much weight to put on a published timetable, and the most dangerous to plan from second-hand material. A great deal of what is written about Singapore still carries the original dates.

Before and after

What changed in August 2025.

Two requirements survived untouched: Scope 1 and Scope 2 emissions for all listed issuers, and the wider climate disclosures for Straits Times Index constituents, both from FY2025. Everything else moved, and the further down the size ladder an obligation sat, the further it moved.

Scroll sideways →

Requirement	Who	Was	Now
Scope 1 and 2 emissions	All listed issuers	FY2025	FY2025
Wider climate disclosures	STI constituents	FY2025	FY2025
Scope 3 emissions	STI constituents	FY2025	FY2026
Wider climate disclosures	Listed, non-STI, market cap S$1bn+	FY2026	FY2028
Wider climate disclosures	Listed, non-STI, under S$1bn	FY2027	FY2030
Limited assurance, Scope 1 and 2	Listed issuers	FY2026	FY2029
Climate disclosures incl. Scope 1 and 2	Large non-listed companies	FY2026	FY2030
Limited assurance, Scope 1 and 2	Large non-listed companies	FY2027	FY2032

Both columns from ACRA's announcement of the extended timelines and its current requirements timeline. Large non-listed companies are those meeting both tests: annual revenue of S$1 billion or more and total assets of S$500 million or more, unless an exemption applies.

Scoping

Singapore sorts by index membership, not by size tests.

Australia and Malaysia both scope by characteristics of the entity: two of three size tests, or an emissions registration, or a revenue threshold. Singapore's listed regime sorts by where you sit in the market. The top tier is membership of the Straits Times Index. The second is market capitalisation of S$1 billion or more. The third is everyone else on the exchange.

This has a consequence worth planning around. Index membership and market capitalisation are not stable, and they are not within your control. ACRA fixed the measurement for the middle tier at 30 June 2025, which removes the uncertainty for that cohort, but the underlying design ties obligations to market position rather than to the scale of the business.

The non-listed test is more familiar: revenue of S$1 billion or more and total assets of S$500 million or more, and unusually both must be met rather than two of three. That is a narrow gate, and it is one reason the non-listed population caught by this regime is far smaller than Malaysia's or Australia's.

Tier 1

STI constituents. The full set, earliest, and the only ones with mandatory Scope 3.

Tier 2

Listed, not in the STI, market capitalisation S$1bn or more measured at 30 June 2025.

Tier 3

Every other listed issuer, regardless of size.

Large NLCo

Revenue S$1bn or more and total assets S$500m or more. Both tests, not two of three.

The planning problem

A deferral is not the same as a reprieve, and treating it as one is how companies lose four years.

When a regulator moves a date out by four years, the rational response looks obvious and is usually wrong. The obligation did not go away. It was restated, by the same two bodies, with a new date attached and a reason given that was about capability rather than about doubt over the destination.

There is also a quieter asymmetry in the revised schedule. Reporting moved, and assurance moved further. A listed issuer now reports Scope 1 and 2 from FY2025 but is not assured on them until FY2029, which is four unassured cycles. Those four years produce the comparatives and the methodology history that the first assurance engagement will examine. Nothing about the deferral makes those years less consequential; it just removes the person who would have told you they were going wrong.

The practical read is that the deferral changed when you are marked, not when the work counts. The data you generate in an unassured year is the data an assurer will trace back to, and a methodology chosen casually in FY2026 is a methodology you will be explaining in FY2029.

One thing that did not move

Scope 1 and Scope 2 for all listed issuers has been in force since FY2025 throughout, and STI constituents have had the wider climate disclosures from FY2025 as well. If you are an SGX-listed issuer, the earliest obligations were never deferred, and the extensions apply to what comes next rather than to what is already due.

Divergences

Three ways Singapore asks for less than the standard does.

Singapore describes its requirements as ISSB-based rather than as an adoption of the standards. That wording is doing real work: the requirements are built into the SGX Listing Rules and, for non-listed companies, into a separate obligation, rather than IFRS S1 and IFRS S2 being given legal force as written.

against a full ISSB adoptionwhat differs

Climate only No general sustainability reporting requirement The obligation is climate-related disclosure. There is no equivalent of the wider IFRS S1 requirement applying across other sustainability topics, so this is a climate-first regime with no announced second step

Scope 3 Mandatory for STI constituents only Voluntary for every other listed issuer and for large non-listed companies, with no mandatory date set. Under IFRS S2 as written, Scope 3 is required of everyone after the first-year relief the single biggest divergence

Assurance Limited only, and not only from auditors Limited assurance over Scope 1 and 2, with no announced move to reasonable assurance. Providers may be ACRA-registered audit firms or testing, inspection and certification firms accredited by the Singapore Accreditation Council

Compare with Australia, which legislated the standard and mandates reasonable assurance across the whole report from 2030, and Malaysia, which adopts IFRS S1 and S2 in full on a staged basis. Three neighbours, three quite different answers.

If STI

You are already reporting the full set including Scope 3 from FY2026, and assured from FY2029. You are the deepest reporter in the region outside Australia.

If listed,
S$1bn+

Scope 1 and 2 now. Wider disclosures FY2028. Two years to build what the STI cohort is already doing, with their published reports to learn from.

If listed,
smaller

Scope 1 and 2 now, wider disclosures FY2030. The longest runway of any listed cohort in the region.

If large
non-listed

FY2030, assurance FY2032, and Scope 3 voluntary. Check the exemption conditions before assuming you are in scope at all.

Where to start

Use the deferral rather than spending it.

Singapore has handed most of its reporting population something the other markets in the region did not get: several unassured cycles with a known end date. The companies that come out of this well will be the ones that treat FY2026 to FY2028 as the period in which the emissions boundary gets fixed, the methodology gets written down and the review trail starts existing, rather than the period before the work starts.

The cheapest thing to do now is also the most valuable later: make each figure traceable to a source document and record who approved it. That is what the FY2029 engagement will ask for, and it cannot be reconstructed afterwards.

Score your evidence position →

Six minutes, no signup. Or check your cohort and first period, read what IFRS S2 requires, or see how every other market is sequencing this.