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TSRS S2 · SET50 · First mandatory climate disclosure
FY2026 is running now
Home/ESG Advisory/SET50 Climate Disclosure
IFRS S2 / TSRS S2 · SET50 first period

Your first mandatory climate disclosure is being written right now.

SET50 companies must file their first mandatory TSRS S2 climate disclosure for financial year 2026 — inside the 56-1 One Report, due roughly end of March 2027. The catch: the emissions and climate-risk data it reports on has to be captured during 2026. This year is the disclosure.

until ~31 March 2027 — the first-report filing window for a December year-end. The FY2026 data window closes sooner, on 31 Dec 2026.
The phase-in

Who’s up first.

FY2026
SET50
First disclosure ~Mar 2027
FY2027
SET100
Disclosure 2028 · gap-analyse in 2026
FY2028
Remaining SET
Disclosure ~2029
FY2029
mai & trusts
Disclosure ~2030

Direction confirmed across sources; the exact middle-phase split is being finalised by the SEC — SET50 FY2026 and SET100 FY2027 are firm. Verify the final notification on sec.or.th before treating later dates as fixed.

Year-one is lighter than you fear

The reliefs that buy you room.

Climate-first, 5 years. IFRS S2 climate information plus only the climate-relevant parts of S1 — not the full S1 suite yet.
Scope 1 & 2 focus. Scope 3 value-chain emissions are deferred in the early years.
No year-one comparatives. First-year relief from restating prior-period figures.
GHG method flexibility. Multiple GHG accounting standards accepted for 5 years, then the GHG Protocol Corporate Standard.

The relief is real — but it is relief on scope, not on timing. Limited assurance on Scope 1 & 2 still applies, and you cannot assure data you did not capture. The work that has to happen this year is the GHG inventory and the disclosure structure.

How Othello gets you there

Inventory, disclosure, both languages.

We build the FY2026 GHG inventory (TGO CFO-grade, ISO 14064-1), draft the TSRS S2 climate disclosure to the standard’s structure, ready it for limited assurance, and produce the English edition that FTSE Russell scores in lockstep with your Thai filing. One accountable in-house bench — carbon, disclosure, and certified bilingual language — so nothing is lost in the handoffs.

Straight answers

SET50, answered.

When is SET50’s first mandatory climate disclosure due?
For SET50 companies the first mandatory period is financial year 2026 — which is running now. The disclosure is made inside the 56-1 One Report, filed within about three months of the fiscal year-end. For a December year-end that means roughly end of March 2027. The data it reports on must be captured during 2026; it cannot be reconstructed later.
What exactly must be disclosed in year one?
Thailand’s TSRS S2 (aligned to IFRS S2) climate disclosure, with a “climate-first” relief for the first five years — you disclose IFRS S2 climate information plus only the climate-relevant parts of S1. Scope 3 emissions are deferred; the early years focus on Scope 1 and Scope 2. There is also a first-year relief from comparative figures.
Do we need assurance on the emissions data?
Yes — limited assurance on Scope 1 and Scope 2, provided by TGO-registered verifiers or internationally recognised standards, moving toward reasonable assurance over time. A TGO Carbon Footprint for Organization (CFO) inventory is a natural underlying data layer, with ISO 14064-3 / AA1000AS as the assurance path.
We are SET100 but not SET50 — when do we start?
Your first mandatory period is FY2027 (disclosed in 2028) — but the right time to run your IFRS S2 gap analysis and stand up your GHG data collection is during 2026, so your first report is built on a full year of good data rather than a scramble.
Why does the English edition matter for a climate disclosure?
Because the same disclosure is scored by FTSE Russell from your public English-language reporting. A climate disclosure that is complete in Thai but thin or loosely translated in English satisfies the SEC yet under-serves the score. We build both editions to reconcile — clause for clause, figure for figure.
Don’t lose the year

Start the FY2026 inventory while the year is still open.

Book a scoping call or send your current reporting — a fixed quote back within one business hour, under NDA from the first email.

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