On 25 October 2026, Singapore closed its public consultation on the Singapore Sustainability Disclosure Standards: draft SFRS S1 and draft SFRS S2, its local versions of the ISSB’s IFRS S1 and S2. The drafts were prepared by an Interim Sustainability Standards Committee that the Accounting and Corporate Regulatory Authority (ACRA) set up in May 2025, and the consultation ran from 27 July.
The headline decision is structural. Only the climate standard, SFRS S2, will be mandatory. SFRS S1, which covers sustainability topics beyond climate, will be voluntary. Thailand’s SEC reached a similar climate-first outcome by a different route three days later, when it announced that its ISSB-based rules for listed companies are in force. Put the two side by side and a less obvious point appears: Singapore’s largest companies started reporting earlier, but Thailand’s SET50 is set to have its greenhouse gas numbers externally assured two financial years sooner.
What Singapore put out for consultation
The consultation paper says the drafts follow the ISSB Standards “to the extent practicable”, with targeted amendments only where Singapore’s policy objectives or implementation context justify them. Two features of the structure matter most.
First, the climate-relevant parts of SFRS S1 are copied into an appendix of SFRS S2, so that S2 works as a standalone standard covering every climate disclosure requirement. A company that only has to report climate never needs to apply S1. Second, the drafts are published without an effective date, pending legislation. The paper says the standards are expected to apply to listed companies from financial years beginning on or after 1 January 2028, and to large non-listed companies from 1 January 2030. Until then, listed companies keep reporting under the SGX Listing Rules, which already require them to apply the ISSB Standards.
The Interim SSC also proposes that companies make an explicit and unreserved statement of compliance with SFRS S2 for their mandatory requirements, and that the SASB industry materials move from “shall refer to and consider” to “may”. SASB use becomes optional.
Three reliefs Singapore changed, and why
The ISSB Standards come with a package of transition reliefs. Singapore keeps most of them but changes three:
IFRS S1 lets a first-year reporter publish after its financial statements. Singapore drops this: climate disclosures follow the Companies Act timeline for financial statements, which a large majority of respondents to the earlier advisory-committee consultation supported.
Not needed. With S1 voluntary, no one is required to report beyond climate, so a relief from doing so has nothing to apply to.
IFRS S2 gives one year. Singapore makes it open-ended, so regulators can switch Scope 3 on for more companies through the law or listing rules without amending the standard.
An unreserved compliance statement with SFRS S2, since a company applying only S2 cannot claim the full suite. SGX currently encourages but does not require one.
A one-year relief is therefore insufficient in Singapore’s context.
ACRA Interim SSC, consultation paper on the draft Singapore SDS (2026), on Scope 3One detail is easy to miss. SGX RegCo currently gives listed companies extra time to publish a sustainability report when it is externally assured. The paper says SGX will review that concession when it consults on assurance, with a view to aligning the listing rules with the final standards.
Who in Singapore reports what, and when
The standards only describe how to report. Who must report what is set by the reporting timeline, which ACRA and SGX RegCo revised in a joint release on 25 August 2025. It created three tiers of listed company:
The regulators were explicit about the reasoning. Smaller listed companies, through the Singapore Business Federation, asked for more time; the largest companies, judged to have the most resources, were told to keep leading. Assurance was the item pushed back for everyone.
Singapore and Thailand, side by side
Thailand’s first ISSB cohort is the SET50 list fixed at the December 2026 index review. It reports FY2027 data in the new Form 56-1 One Report-S, filed in 2028. Comparing that cohort with Singapore’s STI constituents:
| Singapore · STI constituents | Thailand · SET50 (Dec 2026 review) | |
|---|---|---|
| First ISSB-based climate year | FY2025, under SGX Listing Rules | FY2027, filed 2028 |
| Standards beyond climate | SFRS S1 voluntary | Climate-first relief for 5 years; other topics comply-or-explain |
| Scope 3 | Mandatory from FY2026 | Relief for 5 years |
| Timing of the report | With the financial statements (relief removed) | Timing relief for 5 years; within three months of year-end |
| External assurance, Scope 1 and 2 | Limited, from FY2029 | Limited or higher, from FY2027, no relief |
| GHG method | ISSB / GHG Protocol | GHG Protocol or an equivalent national method such as TGO’s, at first |
So neither market is simply “ahead”. Singapore’s large caps will have three years of ISSB-based climate reports behind them (FY2025 to FY2027) by the time the first Thai One Report-S is filed, and they have had to disclose Scope 3 since FY2026. Thailand, in exchange for a later start and longer reliefs, puts assurance at the very start: the SEC’s release says greenhouse gas data must be verified by an assurance provider working to recognised international standards, and its training deck lists ISAE 3410 or TSAE 3410, ISSA 5000 or TSSA 5000, ISO 14064-3 and AA1000, by a TGO-registered or other qualified verifier. Our note on Thailand’s ISSB rules coming into force covers the Thai side in detail.
Why a Thai board should care
Three reasons, in order of how directly they bite.
Groups with a Singapore listing or subsidiary. A Thai group with an SGX-listed entity reports under the SGX regime there and the SEC regime at home, on different first years, different Scope 3 rules and different assurance dates. The numbers have to reconcile even though the reports do not line up. Building one inventory, typically on TGO CFO for Scope 1 and 2, that can feed both is cheaper than two.
Regional capital compares the two directly. An Asia ex-Japan fund holding Singapore and Thai names will set an STI company’s SFRS S2 statement next to a SET50 company’s One Report-S. Singapore’s regime is written in English. Thailand’s is not required to be: clause 37 of SEC Notification TorJor. 44/2556 says annual filings are made in Thai, and clause 38 allows an English version, which must not differ in substance and must be certified accurate. Whether a Thai company publishes that English edition, and how faithful it is, is a choice. FTSE Russell, which scores Thai listed companies from public disclosure without a questionnaire, names English, French, Spanish, German, Japanese and Chinese as its key research languages in its ESG Scores FAQ (v1.5, §1.8), and Thai is not on that list. The English edition is the version a regional analyst is most likely to read, which is why we treat its accuracy as risk control. See FTSE Russell and English disclosure.
The assurance work starts sooner than people assume. Singapore deferring assurance to FY2029 is not a signal that Thailand will follow. The SEC listed five transition reliefs, and assurance is not among them. For a SET50 company, FY2027 starts on 1 January 2027, so the inventory boundary, method and verifier need to be settled within weeks.
Where the evidence runs out
Stated plainly, so nobody over-reads this comparison:
- Singapore’s standards are a draft. The Interim SSC will consider feedback before finalising them, they carry no effective date, and they depend on legislation. The 1 January 2028 date for listed companies is what the paper says is expected.
- Singapore’s reporting timeline (who reports what, when) sits in the August 2025 release and the SGX Listing Rules, not in the standards. It could move again, as it did in 2025.
- On the Thai side, we have read the SEC’s release, its training deck and SET’s roadmap hub, but not yet the nine notifications themselves. Relief durations come from SET’s hub.
- Neither regulator says anything about how ESG raters or investors will weigh assured against unassured data, or English against Thai. Nothing here shows that one market’s companies score better or worse because of these choices, and we do not claim it.
What to do with this
- If your group has an SGX-listed entity, map both regimes now: first years, Scope 3 and assurance dates differ, and the numbers must reconcile.
- If you could be in the December 2026 SET50 list, plan for assured FY2027 Scope 1 and 2. Singapore’s deferral does not change Thailand’s rule.
- Pick one GHG method and one inventory boundary that can serve the SEC, a verifier and, if relevant, Singapore.
- Decide early whether you publish an English One Report-S, and build it so the substance matches the Thai, as clause 38 requires.
- Track the final Singapore SDS. Our ESG regulatory tracker will carry the issued dates.
One inventory, two regimes, one accurate English edition
We build the TGO-certified carbon numbers behind your first One Report-S, map them to IFRS S2, and produce an ISO 17100 English edition that matches the Thai clause by clause.
See TSRS S1 & S2 readinessSingapore and Thailand have taken the same climate-first route to the ISSB at different speeds. Singapore is ahead on reporting, Thailand on assurance. For the full SET50 timeline see SET50’s first climate disclosure, and for how verified carbon data flows into what raters read, from TGO carbon to FTSE disclosure. If the English edition is the gap, our technical translation team works to ISO 17100.
Sources: ACRA, Public Consultation on Singapore’s Sustainability Disclosure Standards (27 July – 25 October 2026) and the Interim Sustainability Standards Committee’s consultation paper on draft SFRS S1 and SFRS S2; ACRA and SGX RegCo, “Extended Timelines for Most Climate Reporting Requirements to Support Companies” (25 August 2025); SEC Thailand, News 231/2569 (28 October 2026) and training deck on Form 56-1 One Report-S (21 October 2026); SET ISSB roadmap hub; SEC Notification TorJor. 44/2556, clauses 37–38; FTSE Russell ESG Scores and Indices FAQ v1.5 (December 2025), §1.8.
See where your English edition is losing FTSE points.
A free Gap Audit maps your published English disclosure against FTSE Russell’s 14 themes — and shows exactly which gaps are quietly costing you points, index inclusion and investor attention.
