SFRS S1 and S2: Singapore’s Sustainability Disclosure Standards Timeline for 2026 and Beyond

Singapore’s sustainability reporting regime has moved firmly from “voluntary best practice” to “regulated obligation with a hard deadline.” Under ACRA’s Singapore Sustainability Disclosure Standards — SFRS S1 (general sustainability disclosures) and SFRS S2 (climate-related disclosures), both based on the ISSB’s IFRS S1 and IFRS S2 — listed companies are already reporting Scope 1 and 2 greenhouse gas emissions, and Large Non-Listed Companies (Large NLCos) now have a confirmed compliance date of financial years starting on or after 1 January 2030.

For business owners running private companies below the Large NLCo thresholds, it is tempting to treat this as someone else’s problem. That would be a mistake. The direction of travel — climate-first, phased, and steadily widening in scope — mirrors exactly how XBRL filing and other ACRA reporting obligations expanded over the past decade: starting with the biggest entities, then working down the size ladder as systems and assurance capacity mature.

This article sets out the mandatory timeline for SFRS S2, the assurance requirements attached to it, the current voluntary status of SFRS S1, and what private companies not yet caught by the rules should be doing to prepare for an extension that is, on the current trajectory, more a matter of “when” than “if.”

What Are SFRS S1 and SFRS S2?

Singapore’s Sustainability Disclosure Standards comprise two standards developed by ACRA’s Interim Sustainability Standards Committee, closely modelled on the International Sustainability Standards Board’s (ISSB) global baseline:

• SFRS S1 — General Requirements for Disclosure of Sustainability-related Financial Information (based on IFRS S1): a broad framework requiring companies to disclose material sustainability-related risks and opportunities across governance, strategy, risk management, and metrics/targets — not limited to climate.
• SFRS S2 — Climate-related Disclosures (based on IFRS S2): a climate-specific standard requiring disclosure of Scope 1, 2, and (for some companies) Scope 3 greenhouse gas emissions, along with governance and strategy information specific to climate risk.

Singapore has deliberately taken a “climate-first” approach: SFRS S2 is being made mandatory on a phased basis, while SFRS S1’s broader ESG disclosures remain voluntary for now, with ACRA continuing public consultation on the wider draft standards (open from 27 July to 25 October 2026) before firming up a mandatory timeline for the fuller framework.

This mirrors the general approach to financial reporting obligations in Singapore — our SFRS basics guide covers how the broader financial reporting standards regime is structured, which is a useful companion to understanding where sustainability reporting now sits alongside it.

Who Must Report, and From When

According to ACRA’s published timeline, mandatory reporting applies to two broad groups: listed companies (all SGX-listed companies, tiered by index membership and market capitalisation) and Large Non-Listed Companies meeting both a revenue and asset-size threshold.

Listed Companies

Large Non-Listed Companies (Large NLCos)

A Large NLCo is a company meeting both of the following thresholds: annual revenue of $1 billion or more, and total assets of $500 million or more. Unless exempted, Large NLCos must report ISSB-based climate-related disclosures, including Scope 1 and 2 GHG emissions, for financial years starting on or after 1 January 2030. Scope 3 reporting remains voluntary for Large NLCos until further notice.

An exemption is available where a company’s immediate, intermediate, or ultimate parent (local or foreign) already prepares ISSB-based or equivalent climate/sustainability reports that cover the subsidiary’s activities and are publicly available. This is a meaningful relief for Singapore subsidiaries of large multinational groups already reporting under equivalent overseas regimes.

Assurance Requirements

Disclosure alone is not the end state — ACRA has also set out a phased external assurance requirement for Scope 1 and 2 GHG emissions:

Assurance must be provided by a registered climate assurance provider — either an audit firm registered with ACRA, or a testing, inspection, and certification (TIC) firm accredited by the Singapore Accreditation Council. This closely parallels how statutory financial audit works, and companies already familiar with when they do or do not need a financial statement audit should read our audit exemption guide for context on how ACRA structures similar size-based thresholds elsewhere in the Companies Act.

Worked Example: A Private Company Assessing Its Exposure

Consider a Singapore-incorporated manufacturing group, wholly locally owned and not listed, with annual revenue of $600 million and total assets of $350 million.

Because the company fails both the revenue and asset thresholds for a Large NLCo, it is not currently caught by mandatory SFRS S2 reporting. However, if the group grows organically or through acquisition and crosses both thresholds simultaneously in a future financial year, it would become a Large NLCo and need to begin ISSB-based climate disclosure from the first financial year starting on or after 1 January 2030 (or a later trigger date if it only crosses the thresholds after that point — the precise mechanics of when growth into Large NLCo status triggers reporting will be clarified as ACRA finalises its rules following the current consultation).

The practical lesson: companies approaching either threshold organically, through group restructuring, or via M&A should build climate data capture into their systems now, rather than trying to reconstruct several years of Scope 1 and 2 emissions data retroactively once the obligation crystallises.

What Private Companies Should Do Now

1. Check your numbers against the Large NLCo thresholds annually. Revenue and total assets can move quickly through organic growth or acquisitions — build this into your annual financial statement close process alongside your existing corporate tax filing review.
2. Start tracking Scope 1 and 2 GHG emissions voluntarily. Even companies years away from mandatory reporting benefit from establishing a clean emissions baseline early, since retrofitting historical data is far harder than capturing it as you go.
3. Watch the group parent-exemption pathway. If you are a subsidiary of a larger group (local or foreign) that already reports under ISSB-aligned or equivalent standards, confirm whether that group reporting already covers your operations — this could remove the need for standalone reporting entirely.
4. Budget for assurance costs ahead of time. Even though assurance dates (FY2029 for listed, FY2032 for Large NLCos) sit years out, sourcing a registered climate assurance provider and building internal data controls that will pass assurance scrutiny takes real lead time — treat this the same way you would treat any other item of sound financial management planning, budgeted years in advance rather than left until the deadline is imminent.
5. Watch the SFRS S1 consultation outcome. The broader ESG disclosure framework (beyond climate) is still in consultation until 25 October 2026. Companies that engage with the consultation process, or at least monitor its outcome closely, will have more lead time to adjust than those caught by surprise when SFRS S1 eventually moves from voluntary to mandatory.
6. Review governance structures now. Sustainability reporting obligations increasingly touch board-level governance and directors’ statements — a good moment to also review your broader compliance posture under the Corporate and Accounting Laws Amendment Act 2025.

Why This Extends Beyond “Big Company” Compliance

Even companies with no direct reporting obligation are increasingly affected indirectly. Banks, private equity investors, and larger corporate customers are starting to request climate and sustainability data from their suppliers and portfolio companies as part of their own SFRS S2 and IFRS S2-aligned reporting chains. A private company that cannot answer a basic Scope 1 and 2 emissions question from a lender or a major customer risks losing financing terms or contracts, regardless of whether ACRA itself requires it to report. Building this capability early is as much a matter of commercial competitiveness as regulatory compliance.

Grant support is also available for companies preparing ahead of mandatory compliance — the Sustainability Reporting Grant, jointly offered by the Economic Development Board and Enterprise Singapore, helps offset the cost of preparing ISSB-based climate-related disclosures before they become compulsory.

Conclusion

SFRS S2 is now a confirmed, dated obligation for listed companies and, from FY2030, for Large NLCos, complete with a phased external assurance regime running through to FY2032. SFRS S1’s broader ESG framework remains voluntary while ACRA finalises the wider standards through its current public consultation — but the direction is unmistakable, and private companies sitting below today’s thresholds should treat the next few years as preparation time, not a free pass.

If your company is approaching the Large NLCo thresholds, sits within a group structure that may qualify for the parent-reporting exemption, or simply wants to understand how sustainability reporting interacts with your existing financial reporting and compliance obligations — including how it connects with your CRS reporting obligations if you also run a fund or family office structure — the team at Raffles Corporate Services can help you get ahead of it.

To speak with the team at Raffles Corporate Services, you can email [email protected] or call, SMS, or WhatsApp +65 8501 7133. We are happy to assist with any queries.

— The Editorial Team, Raffles Corporate Services