SGX Mandatory Climate Reporting: What Singapore Companies Must Know

Why SGX Mandatory Climate Reporting Matters for Your Business

Singapore’s regulatory landscape for sustainability disclosure has shifted decisively. The Singapore Exchange (SGX) has progressively tightened its climate reporting requirements, moving from voluntary best-practice guidance to a structured mandatory framework. For listed issuers and, increasingly, large non-listed companies, understanding what is required — and when — is no longer optional.

The framework draws on the Task Force on Climate-related Financial Disclosures (TCFD) recommendations and aligns with the International Sustainability Standards Board (ISSB) standards, specifically IFRS S2 Climate-related Disclosures. Singapore’s Accounting and Corporate Regulatory Authority (ACRA) and SGX RegCo have jointly signalled that ISSB-aligned reporting will become the baseline for large listed entities, with phased timelines extending requirements to additional company categories.

For safety and risk management professionals, this is not solely a finance or investor-relations matter. Climate reporting requires organisations to identify, assess, and disclose physical and transition risks — work that sits squarely within the risk management disciplines governed by the Workplace Safety and Health Act (Cap. 354A) and the WSH (Risk Management) Regulations. Integrating climate risk into your enterprise risk management framework is both a regulatory expectation and sound business practice.

Understanding the SGX Climate Reporting Framework

SGX introduced mandatory climate-related disclosures in a phased approach. The key milestones are:

• Large-cap listed issuers (STI constituents): Mandatory TCFD-aligned climate disclosures have applied from financial year 2023 onwards, covering governance, strategy, risk management, and metrics and targets.
• All listed issuers: Mandatory climate reporting requirements extend to all SGX-listed companies on a phased basis, with the expectation that ISSB S2 alignment replaces TCFD as the primary standard progressively from FY2025/2026.
• Large non-listed companies: ACRA’s sustainability reporting roadmap targets large non-listed companies with annual revenue of S$1 billion or more, with mandatory requirements anticipated from FY2027, subject to final legislative updates.
• Scope 3 emissions: Disclosure of Scope 3 greenhouse gas emissions is required for large listed issuers, with a phased relief period acknowledging data collection complexity.

The four TCFD pillars — Governance, Strategy, Risk Management, and Metrics & Targets — remain the structural backbone of what must be disclosed. Under ISSB S2, companies must also conduct climate scenario analysis to assess resilience under different warming pathways, a requirement that demands cross-functional input from operations, facilities, and risk teams.

From a workplace safety and health perspective, physical climate risks such as extreme heat, flooding, and air quality degradation have direct implications for worker safety. The Ministry of Manpower (MOM) and the Workplace Safety and Health Council (WSHC) have both issued guidance on heat stress management and outdoor work protocols — data points that are directly relevant to your climate risk disclosures under the physical risk category.

Practical Steps to Achieve SGX Climate Reporting Compliance

Meeting SGX mandatory climate reporting requirements is a multi-disciplinary exercise. The following checklist provides a structured starting point:

• Establish governance accountability: Assign board-level oversight for climate risk. Document how the board monitors climate-related risks and opportunities, and ensure management-level roles are clearly defined. This mirrors the accountability structures required under the WSH Act for workplace risk governance.
• Conduct a climate risk and opportunity assessment: Identify physical risks (acute and chronic) and transition risks (policy, legal, technology, market, reputational) relevant to your operations and value chain. Use the risk assessment methodology consistent with the WSH (Risk Management) Regulations — hazard identification, risk evaluation, and control measures — adapted for climate parameters.
• Perform climate scenario analysis: Model your business resilience under at least two scenarios, typically a below-2°C pathway and a higher-warming scenario. Engage operations and facilities teams to assess site-level vulnerabilities.
• Measure and verify greenhouse gas emissions: Quantify Scope 1, 2, and 3 emissions using the GHG Protocol Corporate Standard. Consider third-party verification aligned with ISO 14064-3 to strengthen disclosure credibility.
• Set targets and track metrics: Establish measurable climate targets, including emissions reduction goals and, where applicable, internal carbon pricing. Align metrics with industry benchmarks and ISSB S2 requirements.
• Integrate climate risk into enterprise risk management: Embed climate risks within your existing risk register. Companies holding bizSAFE certification or pursuing ISO 45001 occupational health and safety management systems should ensure climate-related physical risks to workers are captured within their risk management documentation.
• Prepare and review your sustainability report: Draft disclosures against the TCFD/ISSB S2 framework. Engage internal audit or an external assurance provider to review material climate disclosures before publication.
• Monitor regulatory updates: Track SGX RegCo and ACRA circulars for timeline adjustments, sector-specific guidance, and updates to assurance requirements as the framework matures through 2026 and beyond.

Common Questions on SGX Mandatory Climate Reporting

Q: Our company is listed on SGX Catalist, not the Mainboard. Do mandatory climate reporting requirements apply to us?

Yes. SGX’s mandatory climate reporting requirements apply to both Mainboard and Catalist issuers, though the timelines and specific requirements may differ based on company size and market capitalisation. Catalist issuers should review the SGX RegCo sustainability reporting guide and the accompanying practice notes to confirm their applicable reporting year and scope of disclosure. Smaller issuers may benefit from a phased approach to building internal capability, but early preparation avoids last-minute compliance gaps.

Q: How does climate risk reporting connect to our existing workplace safety and health obligations?

The connection is more direct than many organisations realise. Under the WSH (Risk Management) Regulations, employers are required to identify hazards and assess risks to workers. Climate-related physical hazards — such as heat stress from rising ambient temperatures, flooding that affects site access, or deteriorating air quality from transboundary haze — are legitimate workplace hazards that must be assessed and controlled. MOM and the WSHC have published specific advisories on outdoor heat work and haze management. Documenting these assessments not only fulfils WSH obligations but also provides substantive evidence for the physical risk section of your climate disclosure. Organisations with a mature WSH risk management system, including those with bizSAFE Level 3 or above, are well-positioned to extend that methodology into climate risk assessment.

Take the Next Step Towards Climate Reporting Readiness

Navigating SGX mandatory climate reporting requires coordinated effort across risk management, operations, finance, and governance. At Sage Shield Safety Consultants, we help Singapore businesses build the risk assessment frameworks, documentation systems, and internal capabilities needed to meet both WSH regulatory requirements and emerging sustainability disclosure obligations. Whether you are beginning your climate risk assessment or preparing for third-party assurance, our consultants bring practical, Singapore-specific expertise to every engagement. Book a free consultation with our team today to discuss how we can support your climate reporting and risk management compliance journey.