Mandatory Climate Reporting for Large Non-Listed Companies: The 2026 Compliance Roadmap

Singapore has moved past the era of voluntary ESG. Sustainability reporting is now a strict statutory requirement, not a marketing exercise. Following the Sustainability Reporting Advisory Committee (SRAC) recommendations—a joint effort by ACRA and SGX RegCo—the government has laid out a clear timeline for compliance [9]. While listed issuers hit the starting blocks in FY2025, the net widens to include large non-listed companies (NLCos) from FY2027.

Determining Who Falls Within the Scope

The mandate targets Singapore-incorporated companies hitting two specific financial triggers. According to ACRA, a large NLCo is defined as an entity with annual revenue of at least SGD 1 billion and total assets of at least SGD 500 million [1]. The Ministry of Finance expects this to pull roughly 300 companies into the regulatory fold.

It is worth noting that the mandate follows the place of incorporation, not the location of operations [10]. If a multinational uses Singapore as a regional holding hub, they must assess the consolidated data of that Singapore entity against these thresholds.

New Liabilities for the Board

We are seeing the complete phase-out of the 'comply or explain' leniency. For listed firms, this ends by FY2025 [14], and NLCos are next. This is a fundamental shift in corporate governance. Climate reporting will be baked directly into the Singapore Companies Act 1967.

Legal experts at Allen & Gledhill have pointed out that directors will carry the same legal weight for climate reports as they do for financial statements [12]. By elevating climate data to this level, directors face real liability for material misstatements or omissions.

For the C-suite, FY2027 isn't as far off as it looks. Setting up the data pipelines and board oversight needed to sign off on these disclosures takes time. The preparation window is already open.

To keep Singapore competitive as a green finance hub, the data has to be comparable on a global stage. The Ministry of Finance is requiring these reports to align with the International Sustainability Standards Board (ISSB) framework [3], specifically IFRS S1 and IFRS S2.

The ISSB Framework

Moving to ISSB means looking at the business through a climate lens. IFRS S2 requires disclosures across four specific areas [16]:

• Governance: How the board actually monitors climate risks.
• Strategy: The impact of these risks on the business model and financial planning.
• Risk Management: The nuts and bolts of identifying and assessing climate threats.
• Metrics and Targets: The hard numbers used to track performance against regulatory or internal goals.

PwC Singapore’s Fang Eu-Lin notes that this move creates a global baseline, ensuring local firms remain attractive to international investors who now demand standardised ESG data [20].

Measuring Emissions

On the quantitative side, the math has to be consistent. Companies must use the Greenhouse Gas (GHG) Protocol Corporate Standard to calculate their inventory [8]. This ensures that Scope 1 (direct) and Scope 2 (indirect electricity-related) emissions are measured the same way across the board.

Digital Filing and Public Scrutiny

The filing process is equally rigid. Under the ACRA (Climate-related Disclosures) Regulations 2024, climate reports must be part of the Annual Return [7]. ACRA also requires these filings in XBRL (eXtensible Business Reporting Language) [11]. This isn't just about digitisation; it allows regulators and investors to run automated data analysis. Once filed, these reports sit on ACRA's public record alongside financial statements. Any greenwashing or data gaps will be visible to everyone—from competitors to the public.

Singapore is taking a staggered approach to give the private sector room to breathe. While Scope 1 and 2 reporting starts in FY2027 for large NLCos, the more complex requirements come later.

The Scope 3 Timeline

Scope 3 emissions—those coming from your suppliers or the end-use of your products—are notoriously difficult to track. Listed firms start reporting these in FY2026 [2]. For large NLCos, the government is being more pragmatic. Scope 3 won't be mandatory before FY2029. ACRA plans a review in 2027 to fix the final timeline [6]. Even so, NLCos shouldn't ignore this; listed partners will likely ask for this data much sooner to satisfy their own reporting needs.

External Verification

To ensure the data is reliable, independent audits are being phased in. Mandatory external limited assurance for Scope 1 and 2 emissions starts for large NLCos in FY2029—two years after they start reporting [4]. This audit can't be done by just any consultant. It must be a registered audit firm or a Testing, Inspection and Certification (TIC) provider accredited by the Singapore Accreditation Council [13].

The Tax Angle

Climate reporting isn't just about compliance; it's about the bottom line. Singapore’s carbon tax is rising. According to IRAS, the rate jumps from SGD 25/tCO2e to SGD 45/tCO2e in 2026 and 2027 [17].

When you combine mandatory public data with a rising carbon tax, poor carbon management becomes a direct financial risk. The GHG inventory is now a tool for protecting margins.

NLCos Climate Reporting Implementation Roadmap

For MNCs, the Singapore mandate could lead to double reporting. ACRA has introduced specific exemptions to help, provided certain criteria are met.

The 'Equivalent Reporting' Out

If a Singapore subsidiary’s parent company already reports climate data using ISSB-aligned or equivalent standards, the local entity may be exempt from filing a separate report [5]. For instance, if a European parent consolidates the Singapore entity's data under the EU’s Corporate Sustainability Reporting Directive (CSRD), the local firm might not need a separate ISSB filing. It is vital to check with legal counsel if your parent company’s framework meets ACRA’s definition of 'equivalence'.

Tapping into Support

If you are starting from zero, the government provides financial help. Enterprise Singapore’s Enterprise Sustainability Programme (ESP) helps firms build these reporting capabilities [15]. Eligible SMEs in the supply chains of large NLCos can also get grants covering up to 70% of costs for training and projects. Encouraging your local suppliers to use these grants will make your future Scope 3 data much more accurate.

Don't Wait for 2027

While the first filings aren't due until 2028 (for FY2027), waiting is a mistake. Deloitte Singapore suggests using this transition period to test internal controls and perhaps even trial a voluntary report [18]. Roughly 65% of listed firms are already doing this voluntarily, so they have a massive head start.

Also, smaller firms should keep an eye on the horizon. The government will review the SGD 1 billion revenue threshold in 2027 [19]. They may decide to lower it to include smaller companies once the first group has settled in.

Immediate Steps for the C-Suite:

• Run a Gap Analysis: Check your current data against IFRS S1 and S2 requirements.
• Check for Exemptions: Confirm if your parent company's reporting satisfies ACRA's equivalence rules.
• Formalise Oversight: Get climate risks on the board agenda now to manage future Companies Act liabilities.
• Review Digital Systems: Ensure your internal software can export the structured XBRL data ACRA requires.