Larger Listed Companies on Track for Mandatory Climate Reporting in FY 2025 – Study by ACRA and NUS

Singapore, 8 July 2024 – A study by the Accounting and Corporate Regulatory Authority (ACRA) and the Sustainable and Green Finance Institute (SGFIN) at the National University of Singapore found that larger listed companies, 78% of which are from the carbon-intensive sectors¹, are making good progress in climate reporting. The study also recommends strategies to strengthen climate-related disclosures to meet investors’ expectations and mandatory reporting requirements.

2        As announced by Second Minister for Finance, Mr Chee Hong Tat at the Ministry of Finance Committee of Supply in February 2024, Singapore will introduce mandatory climate reporting to help companies ride the green transition, in line with Singapore’s national agenda on sustainable development. The mandatory climate reporting, to be implemented in a phased approach, will start from financial year 2025, with listed issuers reporting using International Sustainability Standards Board (ISSB)-aligned requirements. Larger non-listed companies will start to report from the financial year 2027, with some exceptions. Companies that exhibit strong alignment with Task Force on Climate-related Financial Disclosures (TCFD) Framework will be well-positioned to fulfil ISSB-aligned reporting requirements.

3        The study, undertaken by ACRA, together with Dr Sean Shin, Research Affiliate at SGFIN, examined the climate-related disclosures² of 51 larger listed issuers³ for the financial year 2022 based on the Task Force on Climate-related Financial Disclosures (TCFD) framework. The key findings include:

• Governance: Almost all companies studied [94%] have assigned roles or formed committees to deal with climate risks and opportunities, demonstrating a strong commitment to these matters. Notably, around three-quarters [75%] have fully described their process of reporting to and involving the Board in climate matters. However, the study noted the need to strengthen the disclosure on how the Board was involved in shaping performance objectives as this would allow investors to assess the Board’s involvement and strategic alignment with climate goals.

• Strategy: Most companies studied [88%] have disclosed the physical and transitional risks related to climate, but only close to two-thirds [61%] have disclosed the related opportunities. While three-quarters [75%] have carried out scenario analyses to assess how well their operations and financial positions or performance could withstand the effects of climate change, they should explain why they chose certain scenarios, clarify the assumptions they relied on, and most importantly, describe how resilient and effective their strategy is. Only a few companies studied [16%] have fully disclosed how they incorporated climate risks in their financial planning.

• Risk Management: Over two-thirds [71%] have fully disclosed how they identified, assessed, and managed climate-related risks. However, only 24% of companies made full disclosures on the significance of climate-related risks compared to other risks and only 10% explained their potential magnitude. This suggests room for improvement, as such information is necessary for investors to evaluate the company's readiness in facing the upcoming economic and regulatory changes, including the transition to a lower-carbon economy.

• Metrics and Targets: Companies studied did well in this aspect, with commendable disclosures for Scope 1 and 2 GHG emissions [at 96% and 100%, respectively] and notable progress for Scope 3 emissions [59%]. Most companies studied [80%] have set targets and the timeframes to reduce emissions, indicating a strong commitment to becoming more environmentally friendly. However, more could be done in terms of setting interim milestones to track tangible and timely progress. Transparency could also be enhanced in disclosures for opportunity metrics and how executive pay was tied to climate performance as less than 10% companies studied have done so. 

4        The study shows how some local and overseas companies disclose climate-related information, which can serve as a guide for best practices. The study also recommends strategies on how companies can enhance their climate reporting, such as prioritising progress over perfection, making meaningful links to financial reporting, and working towards future-proofing the strategy and business model.

5         Several initiatives have been launched to assist companies in meeting the upcoming reporting requirements:

        a. In view of the increasing demand for companies to publish climate-related disclosures, including upcoming regulations to mandate climate-related disclosures for some Singapore-incorporated companies, Singapore Economic Development Board and Enterprise Singapore will launch a Sustainability Reporting Grant⁴ to provide funding support for companies who may be impacted by mandatory reporting requirements (i.e. large companies annual revenue of $100 million and above⁵), to produce their first sustainability report in Singapore, before mandatory reporting takes effect. This will help companies kickstart their sustainability strategy and sustainability performance reporting journey. The disclosures are to be consistent with the ISSB standards;

          b. The Ministry of Trade and Industry and SkillsFuture Singapore, in collaboration with the private sector, have established the Green Skills Committee to develop skills and training programs for the low-carbon economy. With Sustainability Reporting and Assurance as one of its focus areas, the initiative aims to upskill workers within companies and assurance providers in sustainable reporting capabilities to keep pace with the demand to transit into a sustainable, lower-carbon economy;

           c. The Infocomm Media Development Authority (IMDA) has curated a list of digital sustainability solutions, under the Advanced Digital Solutions (ADS) scheme, to help eligible enterprises kickstart their sustainability journey by measuring, monitoring and managing their emissions, enabling them to stay competitive with customers and improve the oversight and reporting of Scope 3 emissions within their supply chain. Beyond the ADS scheme, IMDA is also supporting enterprises who are keen to collaborate with value chain partners to drive sustainability through digitalisation; and

            d. Singapore Business Federation, in collaboration with Agency for Science, Technology and Research, PwC Singapore, and Singtel, are creating a Singapore Emission Factors Registry. This registry will provide conversion factors that translate different business activities into corresponding greenhouse gas emissions, thus supporting the existing reporting solutions in our ecosystem.

6          "ACRA is dedicated to supporting companies throughout their climate reporting journey. Our aim is to inspire and guide companies in adopting both local and global best practices through this study. Together, we can empower companies to make transparent disclosures, enhance their access to green financing, and facilitate their transition to a greener business model," said ACRA Assistant Chief Executive, Ms Kuldip Gill.

7         “Our study has unveiled some of the best business practices and climate-related disclosure by our listed companies. This underscored their adept management of climate-related challenges and commitment to ride the green transition. This will also place them in a good position to report using the ISSB standards,” said Dr Sean Shin, Research Affiliate at SGFIN.

8        The full report, "Unveiling Climate-related Disclosures in Singapore: Getting ready for the ISSB Standards" is available here: www.go.gov.sg/acra-nus-study.

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[1] The TCFD framework has identified the (i) financial, (ii) agriculture, food and forest products, (iii) energy, (iv) materials and buildings, and (v) transportation as sectors most affected by climate change and the transition to a lower carbon economy.

[2] These disclosures were prepared using the TCFD framework, which is intended to provide investors, lenders, insurers, and other stakeholders with better information to understand the potential financial impact of climate change.

[3] Each company had a market capitalisation exceeding $1 billion as of 4 July 2023.

[4] The grant defrays up to 30% of qualifying costs, capped at the lower of S$150,000 per company or 30% of the qualifying costs, in the preparation of their first ISSB-aligned sustainability reports.

[5] Companies which are exempted from Singapore's mandatory sustainability reporting requirements will be ineligible to apply for the SR. This includes large non-listcos whose parent company reports CRD using ISSB-aligned local reporting standards or equivalent standards.