Singapore Exchange Regulation (SGX RegCo) has been phasing in mandatory climate reporting requirements for listed issuers since FY2022. For sustainability leads at Singapore-listed manufacturers, the timeline and scope of these requirements determine what you must produce, in what format, and by when. Voluntary reporting alongside peers who are not yet required is a different situation from mandatory disclosure subject to SGX review.
This article sets out the current state of SGX climate reporting requirements as they applied through FY2025, the framework structure these disclosures follow, and the data implications for mid-market manufacturers working toward compliance.
The SGX climate reporting phasing structure
SGX adopted a phased approach to mandatory climate reporting, structured by issuer market capitalization. Large-cap issuers (by SGX's category definition at the time of adoption) were required to include climate reporting in their sustainability reports beginning with FY2022 annual reports. Mid-cap and smaller issuers were brought into mandatory reporting on a later schedule, with the expectation that all SGX-listed issuers would be within the mandatory framework by FY2025.
The framework SGX aligned to is the Task Force on Climate-related Financial Disclosures (TCFD). TCFD's four-pillar structure, covering governance, strategy, risk management, and metrics and targets, forms the organizational backbone of the required climate disclosures within SGX sustainability reports.
This alignment means that companies already reporting under TCFD, either voluntarily or because institutional investors demanded it, are working within a compatible structure. It also means that the substantive requirement is not just emissions data but a broader narrative about how climate risks and opportunities are integrated into governance and strategy.
What the metrics and targets section requires
Within the TCFD-aligned structure, the metrics and targets section is where quantitative emissions data sits. SGX-listed companies are expected to disclose Scope 1 and Scope 2 greenhouse gas emissions. Scope 3 disclosure was recommended, with the understanding that the data infrastructure for full Scope 3 takes time to build.
The emissions figures need to be presented in a way that enables year-over-year comparison. This means a consistent methodology, consistent boundary definition (which entities and facilities are included), and consistent emission factor selection. Changing any of these without explicit disclosure and restatement breaks comparability and will raise questions in SGX's sustainability reporting review process.
Intensity metrics are also part of the expected disclosure: total emissions divided by a relevant business metric, such as revenue or production volume. The choice of intensity metric should reflect the nature of your operations and remain consistent across reporting years.
The GHG Protocol as measurement foundation
SGX sustainability reporting guidance does not prescribe a specific measurement methodology in every detail, but it references the GHG Protocol as the recognized standard for corporate emissions accounting. This means the activity-based calculation approach (physical activity quantities multiplied by appropriate emission factors) is the expected basis for the figures you disclose.
For Scope 1, this means fuel consumption data from invoices and meter records, matched to IPCC AR6 combustion factors. For Scope 2, electricity consumption from utility bills matched to the EMA grid emission factor for Singapore facilities (with appropriate factors for any overseas facilities). For Scope 3, activity-based or spend-based estimates for the categories your operations make material.
The GHG Protocol boundary concept also applies: you need to define whether you are using an equity share or operational control approach for which entities are in scope. Most manufacturers use operational control, which includes all facilities where you have operational authority over emissions management, regardless of ownership share.
Assurance and third-party review
SGX requires that sustainability reports, including climate disclosures, be reviewed by the board and include a statement of the board's oversight of sustainability matters. For the quantitative data, SGX has progressively encouraged external assurance, and the direction of SGX requirements has been toward limited assurance as a minimum expectation for larger issuers' key metrics.
What this means practically for the emissions numbers: a third-party assurance provider will need to be able to trace your disclosed Scope 1 and Scope 2 figures back to source documents. Invoices, utility bills, meter records. The calculation methodology needs to be documented in enough detail that the assurer can replicate it.
This is a higher standard than maintaining a spreadsheet with a single number per year. The audit trail that supports assurance is a structured ledger, where every emission entry has a source, a calculation, a factor reference, and a result. That structure is not a compliance overhead that comes after you have the numbers; it is the only reliable way to produce numbers that a third-party assurer will sign off on.
What SGX climate reporting does not cover
SGX sustainability reporting requirements cover listed issuers. Companies that are not listed on SGX are not directly subject to these requirements. Mid-market manufacturers that supply to listed companies, or that have listed customers who request supply chain data as part of their own Scope 3 reporting, may face data requests that reference these standards without being directly required to produce formal SGX disclosures themselves.
The SGX requirements also do not prescribe the format of the underlying calculation in any detail. They specify the disclosure outputs (Scope 1, Scope 2, intensity, targets), the framework structure (TCFD), and the governance expectations. How you get to the numbers, which tools you use, which databases you reference, is not prescribed beyond the reference to GHG Protocol methodology. There is judgment space in how you implement the standard, which also means there is judgment space that an auditor or SGX reviewer can probe.
Preparing for the next phase of requirements
The trajectory of SGX climate reporting requirements has been consistently toward greater scope, greater specificity, and greater assurance requirements. What started as encouraged disclosure has moved to mandatory disclosure, and what started as narrative disclosure has moved to quantitative data with audit trails.
The alignment of SGX requirements with IFRS S2 is ongoing. As IFRS S2 becomes the global baseline for climate disclosure and is incorporated into local securities frameworks, the expectation is that SGX requirements will converge toward the IFRS S2 standard, including its expectations for data quality, methodology documentation, and assurance coverage.
For a mid-market manufacturer in Singapore, the practical implication is that building the underlying data infrastructure now, rather than at each new compliance deadline, is the less costly approach. Every year you maintain a clean, documented, auditable emissions ledger is a year that the next compliance requirement step is an extension of existing practice rather than a new infrastructure build from scratch.
A data preparation note for SGX reporters
The companies that find SGX sustainability reporting straightforward are the ones whose underlying data was already organized before the reporting cycle opened. They have utility account inventories, fuel consumption records, and purchase data that can be queried by facility and period. The companies that find it difficult are the ones reconciling spreadsheets and hunting for prior-year documents in email.
The SGX requirements, as they stand through FY2025, are achievable for a mid-market manufacturer with adequate data infrastructure. Scope 1 and 2 data is available in your existing utility bills and fuel invoices. The calculation methodology is well-documented in the GHG Protocol. The disclosure format is well-defined by TCFD.
At Zevero, we focus on the data preparation layer: extracting activity data from invoices and meter reads, matching to appropriate emission factors, and producing a documented ledger that supports disclosure across SGX and other frameworks. The reporting layer is a structured output from that underlying data. Getting the data right is where the compliance work actually lives.