Singapore is moving decisively toward mandatory climate-related financial disclosures — and the timeline is closer than most directors of private companies realise. ACRA’s new sustainability disclosure standards, SFRS(I) S1 and SFRS(I) S2, are modelled on the IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB), and their adoption has implications not just for listed companies, but for the broader Singapore business ecosystem.

ACRA’s consultation on the adoption framework closed on 25 October 2026. Whether you are a listed company, a large private company, or a smaller business in the supply chain of either, here is what directors need to understand.

What Are SFRS(I) S1 and SFRS(I) S2?

SFRS(I) S1 — General Requirements for Disclosure of Sustainability-related Financial Information sets out the overall framework. It requires companies to disclose material sustainability-related risks and opportunities that could reasonably be expected to affect the company’s cash flows, access to finance, or cost of capital over the short, medium, and long term.

SFRS(I) S2 — Climate-related Disclosures is more specific. It requires companies to disclose information about their climate-related risks and opportunities, including their governance processes for managing climate risk, their strategy and the resilience of that strategy under different climate scenarios, their risk management approach, and — critically — their greenhouse gas emissions metrics and targets.

S2 incorporates by reference the Greenhouse Gas Protocol, meaning companies will need to measure and report Scope 1 emissions (direct), Scope 2 emissions (purchased energy), and in some cases Scope 3 emissions (value chain).

Who Does This Apply To and When?

ACRA’s proposed phased implementation targets different company types at different points:

Listed companies on SGX are the primary initial target. SGX has already been moving in this direction through its own sustainability reporting requirements. The new SFRS(I) standards will align and elevate those requirements to the ISSB framework.

Large non-listed companies — those meeting prescribed size thresholds (likely revenue, total assets, and employee count criteria similar to those used in other jurisdictions) — are expected to follow in subsequent phases. ACRA’s consultation paper signalled that mandatory reporting for large non-listed companies is on the roadmap.

Smaller private companies are not immediately required to report under SFRS(I) S1/S2. However, they will face indirect pressure through two channels: Scope 3 reporting requirements imposed on their listed and large company customers, and lender and investor due diligence processes that increasingly require sustainability data even from unlisted suppliers and investees.

Why This Matters Now, Even If You Are Not Required to Report

Directors of private Singapore companies who are tempted to set this aside until they are legally required to report are making a strategic mistake. Here is why.

Your customers are already reporting on you. Any Singapore company that supplies goods or services to a listed company, a large company with mandatory disclosure obligations, or a multinational corporation subject to similar frameworks elsewhere (EU CSRD, UK TCFD, US SEC rules) will increasingly be asked to provide emissions data. Scope 3 emissions reporting requires companies to survey their supply chains. If you cannot provide that data, you become a compliance problem for your customer — and they will find suppliers who can.

Financing will increasingly require it. Singapore’s major banks and DFIs are integrating sustainability criteria into their lending and investment processes. MAS’s guidelines on environmental risk management set expectations for financial institutions that will flow through to their borrowers and investees. Companies that cannot demonstrate awareness of their climate-related risks and a credible approach to managing them will face higher financing costs or reduced access to capital.

M&A and investment due diligence is catching up. Any Singapore company that might be acquired, invested in, or listed in the next five to ten years will face sustainability due diligence. Building the systems, governance, and data infrastructure now is far less disruptive than doing it at the moment of a transaction.

The Four Pillars: What SFRS(I) S2 Actually Requires

The ISSB framework — and therefore SFRS(I) S2 — organises climate disclosures around four pillars, which will be familiar to companies that have already engaged with the TCFD (Task Force on Climate-related Financial Disclosures) framework on which they are based.

Governance. Who in the organisation is responsible for oversight of climate-related risks and opportunities? This means specifying the role of the board, board committees, and management in identifying, assessing, and managing climate risk. For most Singapore companies, this will require directors to engage with the topic in a structured way — it can no longer be delegated entirely to a sustainability team or CSR function.

Strategy. How do climate-related risks and opportunities affect the company’s business model, strategy, and financial planning? Companies are required to perform scenario analysis — considering how the business would perform under different climate scenarios, including a scenario aligned with limiting warming to 1.5°C above pre-industrial levels.

Risk Management. How does the company identify, assess, prioritise, and monitor climate-related risks? This includes both physical risks (flooding, extreme weather, supply chain disruption) and transition risks (policy changes, technology shifts, changing market preferences).

Metrics and Targets. What are the company’s greenhouse gas emissions (Scope 1, 2, and where material, Scope 3)? What targets has it set, and what progress has been made against them?

What Directors Should Be Doing Now

Whether your company faces immediate disclosure requirements or not, the following steps are appropriate for most Singapore directors to be taking in the current environment:

Understand your exposure. Map your company’s physical and transition climate risks at a high level. Where are your operations, suppliers, and markets? What regulatory changes are most likely to affect your business model? This does not require a full TCFD report — it requires directors to have a considered view.

Assess your data readiness. Do you know your Scope 1 and Scope 2 emissions? If not, start there. Basic carbon accounting is increasingly a prerequisite for commercial relationships, and the data gathering process takes time to establish.

Check your governance structure. Does your board have a formal mechanism for overseeing sustainability risks? Even for smaller companies, having a defined board-level owner for climate and sustainability risk is good governance — and will be required under SFRS(I) S2 for companies in scope.

Review your supply chain exposure. If your key customers are likely to face Scope 3 reporting requirements, engage with them proactively. Understanding what data they will need from you — and by when — allows you to prepare systematically rather than reactively.

Stay current. ACRA’s consultation is ongoing and the final implementation timeline and thresholds will be confirmed in due course. Directors should ensure they are monitoring the output of ACRA’s and MAS’s sustainability-related regulatory activity.

The Role of Corporate Governance Infrastructure

Sustainability disclosures are ultimately a corporate governance matter. The board is responsible for oversight. The disclosures must be accurate, reviewed by the board, and in many cases subject to external assurance. This requires the same governance infrastructure — board minutes, committee charters, documented risk management processes — that underpins good corporate governance generally.

Companies with strong governance infrastructure will find it considerably easier to implement sustainability disclosure requirements than those where governance has been treated as a compliance afterthought. This is yet another reason why investing in proper corporate governance now — including a professional corporate secretarial function — pays dividends (in every sense) when regulatory requirements evolve.

Our corporate secretarial services support companies in building and maintaining the governance infrastructure they need — both for current compliance and in preparation for evolving requirements like SFRS(I) S1 and S2. You can also read our overview of annual compliance requirements for Singapore companies.

Want to understand how sustainability disclosure requirements affect your company’s governance structure? Singapore Secretary Services is operated by Raffles Corporate Services, a licensed CSP under ACRA. Contact us to discuss your compliance needs.

This article is for general information only. The ACRA consultation on SFRS(I) S1 and S2 adoption is ongoing; directors should monitor ACRA’s website for final guidance. This article does not constitute legal, accounting, or sustainability advisory advice.