Over the last few years, we have kept our US multinational company readers current on the progress and timing of Singapore corporate climate reporting. Singapore’s climate reporting requirements capture many larger US-based multinationals operating in the country. Mandatory reporting by these companies was scheduled to start with fiscal year 2027. As discussed in this post, that timeline has now been extended.
Large non-listed companies (Large NLCos) are subject to Singapore’s climate disclosure requirements. Large NLCos are companies with annual revenue of at least $1 billion Singapore dollars (approximately US$780 million) and total assets of at least S$500 million (approximately US$390 million). These companies generally will be required to provide International Sustainability Standards Board-aligned climate-related disclosures, including Scope 1 and 2 greenhouse gas emissions. The reporting requirements for Large NLCos are discussed in more detail in this Ropes & Gray post.
(Note that Singapore-listed issuers also have to make climate-related disclosures, starting with fiscal year 2025. The listed issuer requirements – many of which also have been modified – are not discussed in this post.)
On Monday, the Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation announced that they have extended timelines for implementing climate reporting requirements, to support subject companies in developing their reporting capabilities.
For Large NLCos, the reporting timelines have been modified as follows:
- ISSB-based climate-related disclosures, including Scope 1 and 2 GHG emissions, have been postponed by three years, from fiscal year 2027 to fiscal year 2030.
- Scope 3 GHG emissions reporting remains voluntary until further notice. Previously, ACRA had indicated that Large NLCos would not be required to report Scope 3 GHG emissions earlier than fiscal year 2029 and that it would provide at least two years’ notice for these companies to prepare for Scope 3 reporting.
- External limited assurance for Scope 1 and 2 GHG emissions also has been extended by three years. Assurance now commences with fiscal year 2032 rather than fiscal year 2029.
