Singapore — ISSB climate reporting, the carbon tax and CBAM

Singapore requires ISSB-based climate reporting from listed companies and, later, from large non-listed companies, under rules set by SGX RegCo and ACRA. It taxes carbon at large industrial facilities under the Carbon Pricing Act, administered by NEA. The EU Carbon Border Adjustment Mechanism (CBAM) reaches Singapore exporters of covered goods.

What is in force

Mainboard Rule 711B, as amended on 1 January 2026, requires the sustainability report to cover material ESG factors, climate-related disclosures, policies and performance, targets, the reporting framework and a Board statement, with the climate component complying with Practice Note 7.6.¹ Rule 711A requires it to be issued with the annual report or, where externally assured, no later than 5 months after the end of the financial year.²

The Practice Note amendments effective 25 August 2025 require an issuer to disclose Scope 1 and Scope 2 GHG emissions as set out in paragraph 29(a) of IFRS S2 from its financial year commencing on or after 1 January 2025 (FYC 2025).³ The Guide requires climate-related disclosures applying all the requirements in IFRS S2 other than Scope 3. Those apply from FYC 2025 for an issuer that was an STI constituent on 30 June 2025, from FYC 2028 for an issuer with a market capitalisation of S$1 billion or more, and from FYC 2030 for all other issuers. An STI constituent on 30 June 2025 must disclose Scope 3 from FYC 2026.³ The joint ACRA and SGX RegCo release of 25 August 2025 records that these tiers were fixed on 30 June 2025 and hold even if status later changes.⁴

The carbon tax has applied since 1 January 2019 under the Carbon Pricing Act, with amendments in effect from 1 January 2024.⁵ NEA states that it applies to industrial facilities with annual direct emissions of at least 25,000 tCO2e. The rate was $5 per tonne for 2019 to 2023, is $25 per tonne in 2024 and 2025 and $45 per tonne in 2026 and 2027, with a view to $50 to $80 per tonne by 2030.⁵ From 1 January 2024 taxable facilities may use eligible international carbon credits to offset up to 5% of taxable emissions, and EDB administers a transition framework of allowances for existing emissions-intensive trade-exposed companies from 2024.⁵

Regulation (EU) 2023/956 lists cement, electricity, fertilisers, iron and steel, aluminium and hydrogen in Annex I, and Singapore is not among the Annex III countries excluded from scope.⁶ Its transitional period ran from 1 October 2023 to 31 December 2025 with reporting only. Applications for authorised CBAM declarant status opened on 31 December 2024, and from 1 January 2026 goods may be imported into the customs territory of the Union only by an authorised CBAM declarant, with the annual declaration, verification, carbon-price deduction, certificate-surrender and penalty articles applying from that date. The quarterly certificate-holding requirement in Article 22(2) applies from 1 January 2027.⁷ Regulation (EU) 2025/2083, in force from 20 October 2025, adds a de minimis exemption of 50 tonnes cumulative net mass per importer per calendar year across iron and steel, aluminium, fertilisers and cement (electricity and hydrogen excluded). It moves the annual declaration and surrender to 30 September of the year following importation, so the first is due 30 September 2027.⁸

What is coming

For listed companies the next steps are Scope 3 for STI constituents from FY2026, ISSB-based disclosures for non-STI companies from FY2028 (S$1 billion and above) and FY2030 (below), and external limited assurance for Scope 1 and 2 from FY2029, deferred from FY2027.⁴ For large non-listed companies — annual revenue of S$1 billion and above with total assets of S$500 million and above — ISSB-based climate disclosures including Scope 1 and 2 are deferred to FY2030 from FY2027. Scope 3 remains voluntary until further notice, and external limited assurance is deferred to FY2032 from FY2029.⁴ ACRA states that it is developing local sustainability disclosure standards based on the ISSB Standards and has consulted on drafts.⁹

Unutilised international-credit offset quota from emissions year 2025 may be rolled over to emissions year 2026 with a credit conversion factor of 25/45.⁵

Who it binds

The SGX rules bind all issuers listed on the Singapore Exchange, in the three tiers above; the instruments cited here are the Mainboard Rules and Mainboard Practice Note 7.6.⁴ ACRA states that listed and large non-listed companies comply from FY2025 and FY2030 respectively, with an exemption where the parent reports on ISSB-based local or equivalent standards and includes the company in its public report.⁹

The Carbon Pricing Act applies to business facilities in manufacturing and manufacturing-related services; supply of electricity, gas, steam, compressed air and chilled water; and water supply, sewage and waste management, covering direct emissions of CO2, CH4, N2O, SF6, NF3, HFCs and PFCs.⁵ A facility attaining a threshold must register by 30 June of the year following the trigger year: 2,000 tCO2e makes it a reportable facility, 25,000 tCO2e a taxable facility.⁵

Annex I goods may be imported into the Union only by an authorised CBAM declarant, who applies for that status, files the annual declaration and surrenders the certificates. CBAM therefore binds the EU importer rather than the Singapore producer, whose exposure is indirect through the importer’s need for verified embedded-emissions data.⁶ That need falls away only where the importer stays under the de minimis threshold.⁸ Under Article 9 as adopted, the declarant may claim a reduction in certificates for a carbon price (a tax, levy, fee or allowance cost) effectively paid in the country of origin, net of any rebate. The claim must be supported by records certified by a person independent of the declarant and of that country’s authorities.⁶

Verification requirements

Rule 711B requires the issuer’s sustainability reporting process to be subject to internal review and states that the issuer may additionally commission independent external assurance.¹ Practice Note 7.6 requires the issuer to apply the climate-relevant provisions in IFRS S1, and requires Scope 3 emissions to be measured under the Greenhouse Gas Protocol Corporate Standard, subject to the reliefs specified. No explicit and unreserved statement of compliance with the ISSB standards is required.³ For the mandatory limited assurance on Scope 1 and 2, ACRA states that the company must engage a registered climate assurance provider: an audit firm registered with ACRA or a testing, inspection and certification firm accredited by the Singapore Accreditation Council.⁹

Under the Carbon Pricing Act, a registered corporation must engage an NEA-accredited third-party verifier to verify each taxable facility’s Emissions Report annually, before submitting it to NEA by 30 June of the year following the reporting period; only reckonable emissions are verified. Any company offering CPA verification must be accredited by NEA, which lists accredited external auditors for complex sectors (oil and gas refining and large-scale chemicals, other chemicals, semiconductors) and non-complex sectors.¹⁰

Under CBAM, declared embedded emissions must be verified by a verifier accredited under Article 18 on the Annex VI principles, and an operator of a Singapore installation may request registration in the CBAM registry, valid for five years.⁶

What an organisation on ESGOS can do

An organisation in Singapore can find its listing in the directory and claim it from its profile page, or get listed and submit evidence: a sustainability report with Scope 1 and 2 disclosures, a verified Emissions Report for a taxable facility, or embedded-emissions data for CBAM goods. Where CBAM applies, a compliance profile shows an EU importer which Annex I goods an exporter supplies, what verified emissions data exists, and whether a domestic carbon price was paid. The verifiers directory lists accredited verification bodies drawn from national accreditation registers; verifiers accredited for CBAM are not yet published by the Commission, so the directory does not hold them. The exposure check shows which regimes reach a given product and market.

Footnotes

1. Mainboard Rule 711B, Sustainability Report, Singapore Exchange. ↩ ↩²

2. Mainboard Rule 711A, Sustainability Report, Singapore Exchange. ↩

3. Updated Climate Reporting Requirements — Amendments to Mainboard Rules, Practice Note 7.6 Sustainability Reporting Guide, Singapore Exchange Regulation. ↩ ↩² ↩³

4. Extended Timelines for Most Climate Reporting Requirements to Support Companies, Accounting and Corporate Regulatory Authority and Singapore Exchange Regulation. ↩ ↩² ↩³ ↩⁴

5. Carbon Tax (Carbon Pricing Act — rates, thresholds, regulated facilities), National Environment Agency. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

6. Regulation establishing a carbon border adjustment mechanism, EUR-Lex, Official Journal of the European Union. ↩ ↩² ↩³ ↩⁴

7. Regulation (EU) 2023/956 — consolidated text 02023R0956-20251020, EUR-Lex. ↩

8. Regulation simplifying and strengthening the carbon border adjustment mechanism, EUR-Lex, Official Journal of the European Union. ↩ ↩²

9. Sustainability reporting and assurance requirements, Accounting and Corporate Regulatory Authority. ↩ ↩² ↩³

10. Verification and Accreditation Requirements (Carbon Pricing Act), National Environment Agency. ↩