Singapore’s proposed sustainability disclosure standards: A strong foundation, with room for clarity

Singapore is moving closer to a new era of mandatory climate-related disclosures.

The Interim Sustainability Standards Committee (Interim SSC), established by Accounting and Corporate Regulatory Authority (ACRA), has released an Exposure Draft of the proposed Singapore Sustainability Disclosure Standards (SSDS), built on International Financial Reporting Standards (IFRS) S1 and IFRS S2.

At the centre of the proposal is a climate-first approach, where SFRS S2 would become the primary reporting requirement while SFRS S1 would remain voluntary. The requirements would apply first to listed companies and later to large non-listed companies.

What we’re seeing

Having supported sustainability reporting, climate-related assessments and disclosures across multiple sectors for more than a decade, SLR broadly supports the targeted amendments proposed in the draft SSDS.

In particular, several aspects of the proposal help improve clarity and implementation.

A clearer climate-first framework

The draft incorporates climate-relevant elements of SFRS S1 into SFRS S2 through an appendix while keeping SFRS S1 voluntary.

Why it matters: Companies need clarity on what is required under mandatory climate reporting, and integrating the climate-relevant components of SFRS S1 directly into SFRS S2 helps reduce ambiguity, supporting greater consistency and comparability across disclosures.

Practical transition relief

The proposed transition relief amendments include aligning the timing of climate-related disclosures with financial statements and removing climate-first relief.

These changes support a more practical implementation pathway while helping organisations align reporting processes.

Continued reference to (Sustainability Accounting Standards Board) Standards

The proposal also retains voluntary application of and references to the SASB Standards, an approach that SLR supports.

Where additional guidance could help

While we broadly support the proposed approach, we believe companies would benefit from greater clarity on expectations and additional practical guidance to support implementation.

1. Translating climate risks into financial effects

One of the most challenging aspects of IFRS S2 implementation is disclosing the anticipated financial effects of climate-related risks and opportunities.
In practice, companies currently disclose very different levels of quantitative information.

What's needed: More practical guidance worked examples and illustrative approaches to help organisations understand how climate-related risks and opportunities can be translated into financial effects and disclosed at an appropriate level of detail.

2. Providing an implementation roadmap

Companies are starting from different levels of maturity with some conducting their first climate risk assessments whilst others are already moving towards quantification and transition planning.

An implementation roadmap could help organisations navigate this journey, while illustrative disclosures could clarify the difference between foundational disclosures and best-practice disclosures across the four pillars.

3. Building assurance readiness

Assurance requirements are expected to remain an important consideration for reporting entities.

What this means for business: Guidance on the documentation needed to support sustainability disclosures would help companies, as well as the consultants supporting them prepare for future assurance expectations beyond the current limited assurance requirements for Scope 1 and Scope 2 emissions. We also support retaining limited assurance, as it strikes an appropriate balance between enhancing the credibility of disclosures and allowing companies sufficient time to build mature reporting systems and internal controls.

4. Creating greater certainty on Scope 3 reporting

The current draft provides ongoing Scope 3 relief for all listed and large non-listed companies other than constituents of the Straits Times Index (STI).
Scope 3 emissions frequently account for the largest share of a company's carbon footprint. While the challenges associated with collecting and reporting Scope 3 data are well understood, companies also need visibility on future requirements.

A more definitive timeline for the phased introduction of Scope 3 disclosures would provide clearer expectations and help organisations plan resources and budgets more effectively.

To read the response submitted by our team, view the full response document.