The Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo) have launched a public consultation on the recommendations by the Sustainability Reporting Advisory Committee (SRAC) to advance climate reporting in Singapore. The recommendations require Listed Issuers to lead the way and report International Sustainability Standards Board (ISSB)-aligned climate-related disclosures (CRDs) starting from financial year 2025 (FY2025). Large Non-Listed Companies with annual revenue of at least $1 billion will follow suit in FY2027. The public consultation will run from 6 July 2023 to 30 September 2023.
2 The recommendations of SRAC aim to uphold Singapore’s attractiveness as a global business hub while contributing to our national agenda on sustainable development under the Singapore Green Plan 2030. Bolder climate action and transparency in reporting can become a key competitive advantage, and present new business growth and opportunities. These recommendations will prepare companies to meet stakeholder expectations including those of their customers and lenders.
3 The SRAC is an industry-led committee set up by ACRA and SGX RegCo to advise on the roadmap for advancing sustainability reporting by companies in Singapore.
4 Currently, only Listed Issuers in five prioritised industries are required to provide full Task Force on Climate-related Financial Disclosures (TCFD)-aligned CRD progressively from FY2023. All other Listed Issuers are required to apply TCFD on a ‘comply-or-explain’ basis.
5 The SRAC, having consulted over 90 participants, has made the following key recommendations:
a. Mandatory climate reporting from FY2025 for all Listed Issuers – Listed Issuers, including those incorporated overseas, business trusts and real estate investment trusts, should report CRDs from FY2025. This will build on their momentum and progress in climate reporting.
b. Mandatory climate reporting from FY2027 for Large Non-Listed Companies – Non-listed companies with annual revenue of at least $1 billion should make CRDs from FY2027. A review will be conducted in 2027 with the view to mandate climate reporting on Large Non-Listed Companies with revenue of at least $100 million, by around FY2030. The review will consider factors such as international developments, industry capacity and the implementation experience of Large Non-Listed Companies.
c. Prescribed standards aligned with the ISSB requirements for climate reporting –Both Listed Issuers and Large Non-Listed Companies should report CRD using the local prescribed standards that mirror the requirements in the ISSB standards. To allow more time to prepare, these companies could opt to make certain complex CRDs such as Greenhouse gas Scope 3 emissions1 one/two years after reporting requirements kick in.
d. External assurance requirements – Companies subjected to mandatory climate reporting should obtain external assurance on Greenhouse gas Scope 1 and Scope 2 emissions1 from FY2027 for all listed issuers, and FY2029 for Large Non-Listed Companies. The assurance can be provided by ACRA-registered audit firms and Testing, Inspection, Certification firms accredited by the Singapore Accreditation Council2.
e. Reporting and Filing Timelines – CRDs should have the same reporting and filing timelines as financial statements to facilitate timely communication to shareholders and other stakeholders. Legal responsibilities should also be imposed on the company, its directors, and/or officers to ensure accountability for CRDs.
6 Ms Esther An, Chairperson, SRAC, said, “With more countries pledging for net zero and the rising carbon cost globally, climate strategy and reporting can help companies, listed or non-listed, to mitigate and adapt to risks in the transition to a low carbon economy. What gets measured gets managed. There is a strong business case for climate reporting as it has helped many businesses to improve performance and create stronger competitive advantage by capturing growth opportunities.”
7 Ms Kuldip Gill, Assistant Chief Executive, ACRA, said, “Trusted and consistent climate reporting is essential to drive accountability and decisive actions by companies. It will also rally companies towards contributing to Singapore’s net zero emissions commitments, expediting our transition to a green economy. I encourage the public to actively participate in this consultation.”
8 Mr Michael Tang, Head of the Sustainable Development Office, SGX RegCo, said, "SGX-listed companies have been at the forefront of sustainability reporting. That Large Non-Listed Companies should start climate reporting will complement the progress of listed companies. As a whole, these efforts create a virtuous cycle of lifting standards all round and enabling Singapore corporates to make an outsize contribution towards global sustainability."
Public Consultation Details
9 The public can access the public consultation documents on the REACH consultation portal, ACRA and Singapore Exchange websites. Interested parties can submit their comments through FormSG. SGX RegCo expects to consult on any amendment to the Listing Rules on sustainability reporting by the end of the year. ACRA and SGX RegCo will consider the feedback received from this public consultation before finalising the recommendations by 2024.
[1] Greenhouse gases:
- Scope 1 emissions are direct emissions from owned or controlled sources.
- Scope 2 emissions are indirect emissions from the generation of purchased energy.
- Scope 3 emissions are all indirect emissions (not included in Scope 2) that occur in the value chain of the reporting company, including both upstream and downstream emissions.
[2] In Singapore, the Singapore Accreditation Council (SAC) is the national accreditation body that manages and promotes accreditation schemes and registration programmes.
