Senseible

Does Singapore's mandatory climate reporting apply to my Indian group's Singapore company?

Only if the Singapore company is listed on SGX, or is a large non-listed company with annual revenue of at least SGD 1 billion and total assets of at least SGD 500 million. Listed issuers report Scope 1 and Scope 2 from FY2025; in August 2025 the start for large non-listed companies was pushed back by several years.

Test your Singapore company in three steps

  1. Is it listed on SGX? Then it is in the listed issuer regime: Scope 1 and Scope 2 from FY2025, with fuller ISSB-based disclosures and Scope 3 phased by size and index membership.
  2. If not listed, does it have revenue of at least SGD 1 billion and total assets of at least SGD 500 million? It must pass both. Check on acra.gov.sg whether the test uses the company's own accounts or consolidated group accounts: a holding company earning only dividends fails on its own accounts, but may pass if group revenue from Indian subsidiaries counts.
  3. If it passes, check whether an exemption applies, such as a parent that publishes climate disclosures covering it under ISSB standards or an equivalent framework. Read the exact conditions on acra.gov.sg before relying on one.

What the 2025 deferral changed

ACRA and SGX RegCo first set FY2027 as the start for large non-listed companies. In August 2025 they deferred that start by several years, made Scope 3 voluntary for most companies, and kept Scope 3 mandatory only for the largest listed issuers. Check the current financial year that applies to your company on acra.gov.sg, and the listed issuer phases on sgx.com, before planning.

Why your Indian plants may be in the report

If the Singapore company owns the Indian operating companies and prepares consolidated accounts, its disclosures cover the group it consolidates. Scope 1 and Scope 2 then include the fuel and electricity of Indian factories, measured by the GHG Protocol as the ISSB standard requires. A trading company that owns no plants reports its own offices and any assets it controls.

How this differs from India's BRSR

BRSR is filed by the top 1,000 listed companies in India in SEBI's format. Singapore's regime uses the ISSB standards. An Indian parent's BRSR is not automatically an ISSB report, so do not assume it gives the Singapore company an exemption; check with your Singapore adviser.

What Senseible does here

Senseible turns the fuel invoices and electricity bills of Indian sites into document-backed Scope 1 and Scope 2 figures, with the factor and source on every line, that a Singapore parent can consolidate into its own report.

Sources: IFRS S2 Climate-related Disclosures (ifrs.org), the basis of Singapore's regime, GHG Protocol Corporate Standard, SEBI BRSR circular, July 2023

Last reviewed 2026-10-17. ACRA and SGX RegCo revised the timelines in August 2025; confirm the current start year for large non-listed companies, the threshold basis and parent exemptions on acra.gov.sg.