Solid Progress, but Key Gaps Remain
Singapore's largest listed companies have made strong strides in disclosing greenhouse gas emissions, particularly for Scope 1 and 2. With the SGX’s emissions disclosure requirements taking effect starting 1 January 2025, the focus is shifting from basic compliance to the depth, consistency, and credibility of disclosures. The challenge now is to shift from simply reporting that emissions exist to showing clearly how they are measured, managed, and meaningfully reduced in ways that foster transparency and build trust.
Current State of Emissions Disclosure in Singapore
In a recent joint study by ACRA and NUS, which assessed disclosures by 51 SGX Mainboard-listed companies with market capitalisation above S$1 billion as of 4 July 2023, provides critical insight into current reporting practices.Notably, 78% of the companies sampled operate in sectors considered by the TCFD to be most exposed to climate-related risks.
Scope 1 & 2 Emissions:
- 96% disclosed Scope 1 emissions
- 100% of companies disclosed Scope 2 emissions
- Only 24% disclosed both location-based and market-based Scope 2 emissions, which is the best practice under the GHG Protocol that enhances comparability and transparency
Scope 3 Emissions:
- 64% disclosed Scope 3 emissions to some degree
- Only 41% of these companies categorised emissions based on the GHG Protocol’s category-level guidance — limiting insight into value chain impacts
- 3 companies partially in Scope 3 / 18 companies not disclosing Scope 3 / 30 companies fully disclosing Scope 3 Emissions
Target Setting and Performance Tracking for GHG Emissions
- 80% disclosed long-term GHG targets and timelines
- 92% of companies had GHG targets in place, of which:
- 36 companies committed to net-zero by 2050;
- 10 companies aligned with the Science-Based Targets initiative (SBTi); 7 of them committed to a 1.5°C pathway
- 55% of the sample companies have disclosed their yearly performance against the targets while 53% did not report any interim milestones, resulting in difficulty when evaluating whether these companies are on track.
Challenges in Disclosing Scope 3 Greenhouse Gas Emissions
In terms of disclosing emissions data, Scope 3 may be the most difficult to report out of all the emissions due to the many challenges involved in its measurement and attribution.
Data Availability and Quality
- Many companies, particularly smaller ones that work with many different suppliers, often have difficulty in securing reliable data across their value chain for Scope 3 emissions. Collecting this data requires active collaboration across all stakeholders, which may be challenging if some parties are unwilling or unable to engage in the process.
Complexity of Value Chain Mapping
- Even if a company gets their hands on data, companies may face difficulty in pinpointing and determining the classification of emissions in the organisation’s value chain, particularly due to the complexity and numerous steps required to achieve a well-mapped emission data map.
Lack of Standardised Methodologies
- As mentioned above, Scope 3 reporting is not yet required within sustainability reporting, which has resulted in limited reporting on Scope 3. Many companies are still creating their approach used to collect data. As time goes on, more and more companies will begin to report their Scope 3 emissions.
SGX Requirements – How and Where Must Companies Be Ready?
Under SGX’s mandatory climate reporting rules (effective FYs starting 1 Jan 2025), any listed company must:- Report Scope 1 and 2 emissions aligned with IFRS SDS
- Build readiness for Scope 3 disclosures ahead of sector-specific requirements starting FY2026 (beginning with large issuer companies)
- However, the requirements for Scope 3 are subject to change with the reporting timeline not set in stone currently by the SGX.
- Scope 1 and 2 emissions reporting begin FY2027
- Scope 3 emissions reporting beginning FY2029 (without any change to the timeline)
Where BDO Can Help SG Companies
While many companies have made meaningful progress towards meeting emissions reporting standards, the next phase demands consistency, traceability, and stronger governance. BDO supports clients in:
- Clarifying disclosures on reporting boundaries, methodologies, and performance analysis
- Building internal control frameworks for Scope 1 and 2 reporting to support future assurance
- Preparing for Scope 3 reporting through supply chain mapping and category-level data structuring
- Conducting gap assessments aligned with IFRS S2 to identify practical areas for uplift
Climate disclosure is no longer just about publishing numbers. It is about demonstrating accountability, enabling comparability, and earning credibility. As expectations rise, companies that invest in data integrity and governance today will be the ones best positioned for resilience tomorrow.
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References
- Challenges and solutions in measuring and reporting Scope 3 emissions: https://www.deloitte.com/nl/en/issues/climate/challenges-and-solutions-scope-3-emissions.html
- SGX RegCo to start incorporating IFRS Sustainability Disclosure Standards into climate reporting rules: https://www.sgxgroup.com/media-centre/20240923-sgx-regco-start-incorporating-ifrs-sustainability-disclosure
- Sustainability Reporting in Singapore: An Analysis of Climate-related Disclosures in Line with the TCFD Recommendations: https://www.acra.gov.sg/docs/default-source/news-events-documents/2024/acra-nus-study/report.pdf