Implementing ISSB: Observations on Singapore's Draft Sustainability Disclosure Standards

Anthesis' analysis on how Singapore is adapting the ISSB global baseline to local implementation realities.

Principal Consultant

Philippines

Lara Ferrer

Senior Consultant

Philippines

Key proposed adjustments to ISSB Standards
Three Observations on Singapore’s Draft Sustainability Disclosure Standards
Looking Ahead: The Future of ISSB Alignment in Singapore

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Singapore’s proposed Sustainability Disclosure Standards offer an early indication of how the country intends to balance global consistency with local implementation realities.

With the public consultation on the draft Singapore Sustainability Disclosure Standards (SFRS S1 and SFRS S2) now concluded, Anthesis has submitted its response to the Accounting and Corporate Regulatory Authority (ACRA)’s Interim Sustainability Standards Committee, contributing insights drawn from our global experience supporting organisations on sustainability reporting and disclosure.

The proposals largely reflect Singapore’s climate-first reporting roadmap and build on the phased implementation approach established by ACRA and Singapore Exchange Regulation (SGX RegCo). At the same time, the consultation provides useful insight into how Singapore is adapting the International Sustainability Standards Board (ISSB) global baseline to local implementation realities.

Looking across the proposals, a common theme emerges: balancing alignment with international standards while recognising current levels of reporting maturity and readiness.

Key proposed adjustments to ISSB Standards:

A standalone climate disclosure standard (SFRS S2), incorporating relevant climate-related disclosure requirements from SFRS S1 into Appendix D, while broader sustainability disclosures under SFRS S1 remain voluntary
Climate disclosures being published alongside annual financial statements
Ongoing Scope 3 relief for entities not otherwise subject to mandatory Scope 3 requirements
Voluntary consideration of SASB guidance
An explicit statement of compliance with applicable SFRS S2 requirements

Taken together, these proposals reflect a pragmatic approach to implementation, seeking to maintain comparability with the ISSB baseline while providing flexibility in areas where reporting capabilities continue to develop.

Comparing the proposals with developments across Asia-Pacific is particularly interesting. Among the jurisdictions reviewed, Singapore’s proposed structure is most comparable to Australia’s ASRS standalone climate reporting approach. By contrast, jurisdictions such as Malaysia, the Philippines, Hong Kong, and the UK have largely retained the two-standard S1/S2 structure. The proposed ongoing Scope 3 relief is also more flexible than many of the time-limited transitional approaches currently being adopted elsewhere in the region.

Learn how ‘Global Companies Are Interpreting ISSB Requirements In Practice‘

Three Observations on Singapore’s Draft Sustainability Disclosure Standards

1. Scope 3 Emissions Relief: Balancing Practicality and Long-Term Visibility

The proposed Scope 3 relief recognises the implementation challenges many organisations continue to face around value-chain data collection, methodology and reporting. At the same time, Scope 3 emissions often represent the large majority of an organisation’s overall emissions footprint. According to estimates cited by the World Resources Institute (2022), Scope 3 emissions account for approximately 75% of corporate emissions on average, while the SGX-National University of Singapore (NUS) Climate Reporting Review found that only 37% of Singapore-listed issuers currently disclose Scope 3 emissions.

While the proposed relief may be appropriate at this stage, periodic review points could help provide greater visibility on the longer-term direction of travel as reporting capabilities and market maturity continue to evolve. Greater clarity on future reporting expectations could encourage earlier and more proactive value chain engagement, helping organisations build the data, governance and supplier relationships needed to better understand and manage emissions over time.

Insights: How Australian companies are navigating Scope 3 emissions under ISSB-aligned disclosures

2. The Future Role of SFRS S1 in Singapore Sustainability Reporting

The consultation provides a clear pathway for climate-related disclosures through SFRS S2.

However, broader sustainability-related disclosures under SFRS S1 remain voluntary, and there is currently limited visibility on whether this position is expected to change over time.

Additional clarity on the intended long-term role of SFRS S1 could help organisations make more informed decisions regarding governance structures, reporting systems and capability building. Greater certainty around future reporting expectations may also support longer-term planning as organisations continue to develop their sustainability reporting capabilities.

This may become increasingly relevant as discussions continue around the future development of ISSB standards beyond climate-related disclosures.

3. Practical Guidance for Implementing Singapore Sustainability Disclosure Standards

As organisations move from understanding reporting requirements to implementing them, guidance may become just as important as the standards themselves.

Several areas may benefit from additional implementation guidance, including:

Proportionality and the application of judgement
Quantification of climate-related financial effects
Climate resilience assessments and scenario analysis

These are not uniquely Singaporean challenges. Similar questions have emerged across a number of jurisdictions implementing ISSB-aligned reporting frameworks, particularly as organisations move from understanding the requirements to operationalising them.

As organisations move from understanding reporting requirements to applying them in practice, experiences from other jurisdictions can provide useful lessons. Anthesis recently examined the Australian Securities and Investments Commission (ASIC)’s observations from its review of first-year sustainability reports in Australia and what they may mean for reporting quality going forward in Our 7 Key Takeaways from ASIC’s Review of First-Year Sustainability Reports.

Looking Ahead: The Future of ISSB Alignment in Singapore

While consultation feedback may influence specific reliefs and implementation provisions, the broader direction appears clear. Climate-related reporting is increasingly becoming part of mainstream corporate reporting, with greater emphasis on connected information, governance, financial effects and decision-useful disclosures.

For many organisations, the next challenge is likely to be less about understanding the requirements themselves and more about building the governance structures, data processes and analytical capabilities needed to support them.

Overall, the proposals strike a considered balance between international alignment and practical implementation in Singapore while recognising current implementation realities. As reporting maturity continues to evolve, the focus is likely to shift from interpreting reporting requirements to demonstrating how they can be applied consistently, transparently and effectively in practice.

Need support with climate or sustainability reporting in Singapore?

Navigating ISSB alignment requires a careful balance of global consistency and practical reality. Drawing on our extensive experience supporting organisations across Asia-Pacific and globally, Anthesis helps businesses build the governance and analytical capabilities needed for mainstream climate reporting.

Our team can help you benchmark your approach against regional best practices and ensure your reporting framework is both robust and practical.

We are the world’s leading purpose driven, digitally enabled, science-based activator. And always welcome inquiries and partnerships to drive positive change together.

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