Singapore & Australia Mandatory Climate Disclosure

The Asia-Pacific Climate Disclosure Revolution: Singapore and Australia Lead the Global Charge

The sustainability reporting landscape is shifting at unprecedented speed—and Asia-Pacific is leading the way.

In the past year, two major economies have made climate disclosure mandatory, signaling a fundamental transformation in how businesses report environmental impact. This isn't a distant future scenario. For thousands of companies, these requirements are already in effect.

Singapore: All Listed Companies Now Reporting

As of FY2025, every company listed on the Singapore Exchange must report Scope 1 and Scope 2 emissions—no exceptions, no delays.

Here's what Singapore's phased approach looks like:

✓ FY2025 (Now): All listed companies must disclose Scope 1 & 2 emissions aligned with ISSB Standards

✓ FY2026: Straits Times Index (STI) constituents must add Scope 3 emissions and full ISSB-based climate disclosures

✓ FY2029: External limited assurance required for all Scope 1 & 2 emissions

✓ FY2030: Large non-listed companies (>$1B revenue, >$500M assets) must begin reporting

The Singapore Exchange Regulation and Accounting and Corporate Regulatory Authority have built these requirements on the International Sustainability Standards Board (ISSB) framework—specifically IFRS S2 Climate-related Disclosures.

What makes this particularly significant: Singapore updated its timeline in August 2025 to provide smaller companies more preparation time, but the core requirements remain unchanged. The message is clear—climate disclosure is no longer optional.

Australia: Mandatory Reporting Begins January 2025

Australia's Treasury Laws Amendment Act received Royal Assent in September 2024, introducing one of the world's most comprehensive mandatory climate reporting regimes.

The phased implementation:

Group 1 (January 2025): Large entities with 500+ employees, $500M+ revenue, or $1B+ assets

• First reports due in 2026 for FY2025

• Includes both listed and unlisted companies

Group 2 (July 2026): Medium entities with 250+ employees, $200M+ revenue, or $500M+ assets

Group 3 (July 2027): Smaller qualifying entities

What Australian Companies Must Disclose:

→ Governance: Board oversight and management processes for climate matters

→ Strategy: How climate risks and opportunities affect business model, including scenario analysis using at least two climate scenarios (one consistent with Paris Agreement, one exceeding 2°C warming)

→ Risk Management: Processes for identifying and managing climate risks

→ Metrics and Targets:

• Scope 1, 2, and 3 GHG emissions (Scope 3 with one-year grace period)

• Climate-related targets and progress

• Industry-specific metrics

→ Assurance: Phased approach ending with reasonable assurance by 2030

Critically, Australia has built in a modified liability regime for the first three years (2025-2027) to allow companies to develop expertise—but this protection is limited to Scope 3 emissions, scenario analysis, and transition plans only. Core disclosures are subject to full liability from day one.

The Global Context: 36+ Countries Adopting ISSB Standards

Singapore and Australia aren't outliers—they're part of a global wave.

As of September 2025, 36 jurisdictions have adopted or are actively incorporating ISSB Standards, representing:

• ~60% of global GDP

• 40%+ of global market capitalization

• ~60% of global greenhouse gas emissions

Countries already implementing or scheduled to implement ISSB-aligned mandatory reporting include:

• Brazil (mandatory from January 2026)

• Hong Kong (mandatory from 2026)

• Japan (SSBJ standards effective 2025)

• Nigeria (already mandatory)

• UK (expected January 2026)

• Canada (standards finalized)

• Chile (mandatory from January 2026)

• Mexico (formally adopted 2025)

• Pakistan (phasing in from July 2025)

• Malaysia, Sri Lanka, Tanzania, Costa Rica (mandatory reporting underway)

• 
  

Even in the United States, where federal requirements remain uncertain, California's climate disclosure law requires large companies to report Scope 1 & 2 emissions starting in 2026, with Scope 3 following in 2027—and California has explicitly indicated companies can use IFRS S2 as their framework.

Why This Matters for Indian Businesses

"We operate in India. Why should we care about Singapore and Australia?"

Here's why this is directly relevant:

1. Investor Expectations Are Borderless

Global institutional investors don't think in jurisdictions—they think in portfolios. If you're seeking international capital, investors are increasingly benchmarking all companies against ISSB standards, regardless of where those companies are based.

Indian companies accessing Singapore or Australian capital markets face these requirements directly. But even for purely domestic fundraising, Indian institutional investors are adopting global best practices shaped by these standards.

2. Supply Chain Implications

If you supply to companies in Singapore or Australia, you're part of their Scope 3 emissions. Companies facing mandatory disclosure are cascading data requirements to their suppliers.

This means Indian exporters and suppliers to MNCs based in these jurisdictions need to be ready to provide:

• Carbon footprint data for products/services

• Climate risk assessments for operations

• Decarbonization targets and progress

3. Competitive Positioning

As regional peers adopt ISSB-aligned reporting, Indian companies with comparable disclosure gain competitive advantage:

• Differentiation in export markets

• Preferred vendor status with sustainability-focused buyers

• Access to green finance and ESG-linked capital

• Enhanced reputation with environmentally conscious stakeholders

4. Regulatory Trajectory in India

SEBI's evolution of BRSR requirements shows clear movement toward alignment with global standards. The regulator has already referenced TCFD (which forms the foundation of IFRS S2).

Singapore and Australia's implementation provides a roadmap for what India's regulatory framework may evolve toward. Companies preparing now will be ahead when Indian requirements formally converge with global standards.

The Technical Challenge: What ISSB-Aligned Reporting Actually Requires

Understanding what Singapore and Australia mandate reveals the implementation challenge:

Scope 1 & 2 Emissions: Most Indian companies can calculate direct (Scope 1) and energy-related (Scope 2) emissions with reasonable effort. This requires:

• Energy consumption data (electricity, fuel, heating)

• Application of emission factors

• Alignment with GHG Protocol

Scope 3 Emissions: This is where complexity explodes. Scope 3 represents all other indirect emissions in the value chain—upstream and downstream. For most companies, Scope 3 is 70-90% of total carbon footprint.

Scope 3 includes 15 categories:

• Purchased goods and services

• Capital goods

• Upstream transportation

• Business travel

• Employee commuting

• Downstream transportation

• Product use

• End-of-life treatment ...and more

Getting Scope 3 data requires:

• Supplier engagement and data collection

• Product lifecycle assessment

• Customer usage patterns

• Complex calculation methodologies

Climate Scenario Analysis: Both Singapore (for STI constituents) and Australia (for all Group 1-3 entities) require scenario analysis. This means modeling how your business performs under different climate futures:

• Paris-aligned scenario (1.5°C or well below 2°C warming)

• High-warming scenario (exceeding 2°C, anticipating severe climate impacts)

This requires:

• Understanding physical risks (extreme weather, sea level rise, temperature changes)

• Understanding transition risks (carbon pricing, technology shifts, policy changes)

• Quantifying financial impacts across scenarios

• Assessing strategy resilience

Governance and Strategy Integration: Disclosure must show:

• Board-level oversight of climate matters

• Management processes and accountability

• Integration into business strategy and financial planning

• How climate considerations affect capital allocation

Assurance Requirements: Both jurisdictions require external assurance—initially limited assurance, progressing to reasonable assurance. This means sustainability data must meet the same rigor as financial data:

• Documented processes and controls

• Audit trails for data sources

• Methodology documentation

• Quality management systems

The Implementation Challenge

For companies new to comprehensive climate reporting, the journey is substantial:

Phase 1: Foundation (Months 1-6)

• Establish carbon accounting capability

• Calculate Scope 1 & 2 baseline

• Develop Scope 3 measurement strategy

• Assess governance structures

• Identify data gaps

Phase 2: Advanced Disclosure (Months 6-12)

• Implement Scope 3 measurement

• Develop scenario analysis capability

• Quantify financial impacts

• Set science-based targets

• Build data systems and controls

Phase 3: Assurance Readiness (Months 12-18)

• Implement quality controls

• Document methodologies

• Prepare for external assurance

• Integrate with financial reporting

• Establish annual update processes

This timeline assumes dedicated resources and expert support. Companies attempting to build this capability solely with existing teams often underestimate the required investment by 3-5x.

The Opportunity: Turning Compliance into Competitive Advantage

Smart companies view mandatory climate disclosure not as compliance burden but as strategic opportunity.

Enhanced Risk Management: Rigorous climate disclosure forces systematic identification and quantification of risks that informal processes miss—both physical risks (how climate change affects operations) and transition risks (how decarbonization affects business models).

Better Capital Allocation: Scenario analysis and climate-integrated financial planning improve investment decision-making by forcing consideration of multiple futures rather than single-point forecasts.

Investor Appeal: Companies with ISSB-aligned disclosure signal sophistication, transparency, and investor-orientation—translating into better access to capital and lower cost of capital.

Market Differentiation: In sectors where most competitors provide minimal sustainability data, comprehensive climate disclosure creates meaningful differentiation, particularly in B2B contexts where customers face their own Scope 3 reporting requirements.

Organizational Capability: Building robust climate reporting infrastructure creates cross-functional collaboration between finance, operations, strategy, and sustainability teams—capability that drives broader organizational effectiveness.

What Indian Companies Should Do Now

Whether ISSB standards become mandatory in India or remain investor expectations, preparation follows similar steps:

Immediate Actions:

1. Assess Current State

• Review existing sustainability disclosures (BRSR, sustainability reports)

• Identify gaps versus ISSB requirements

• Evaluate data availability and quality

2. Establish Emissions Baseline

• Comprehensive carbon assessment (Scopes 1, 2, 3)

• Document methodology aligned with GHG Protocol

• Identify Scope 3 hotspots and data gaps

3. Build Governance

• Establish board-level oversight of climate

• Define management accountability

• Integrate climate into risk management

4. Develop Data Infrastructure

• Implement sustainability data systems

• Establish controls and audit trails

• Integrate with financial reporting processes

Medium-Term Actions:

5. Advanced Measurement

• Progressively improve Scope 3 data quality

• Engage suppliers for primary data

• Implement activity-based calculation where possible

6. Scenario Analysis

• Develop climate scenario capability

• Assess physical and transition risks

• Quantify potential financial impacts

• Integrate into strategic planning

7. Target Setting

• Establish science-based emissions reduction targets

• Consider SBTi validation

• Develop decarbonization roadmap

• Set interim milestones

8. Assurance Preparation

• Implement data quality controls

• Document assumptions and methodologies

• Prepare for external verification

• Build internal audit capability

• 
  

The Bottom Line

Singapore and Australia's mandatory climate disclosure represents more than regulatory change in two countries—it signals the global direction of travel.

Key Takeaways:

→ Climate disclosure is moving from voluntary best practice to mandatory requirement across major economies

→ 36+ jurisdictions representing ~60% of global GDP are adopting ISSB standards

→ Requirements extend beyond listed companies to large private entities

→ Full value chain emissions (including Scope 3) are becoming standard expectation

→ Assurance requirements mean sustainability data must match financial reporting rigor

→ Indian companies with international operations, investors, or customers are affected now

→ Early preparation creates competitive advantage

For Indian Businesses:

The question isn't "Will India mandate ISSB-aligned climate disclosure?"

The question is "Are we ready when investors, customers, and eventually regulators expect it?"

Singapore and Australia have shown the roadmap. Smart Indian companies won't wait for Indian mandates they'll build the capability now to turn climate disclosure from compliance burden into strategic asset.

The global sustainability reporting landscape has shifted. The question is whether your organization will lead or follow.

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