Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
A written parliamentary reply this year confirmed that mandatory external assurance on Scope 1 and Scope 2 emissions disclosures by Singapore-listed companies does not begin until FY2029. Until then, board oversight is the primary control over whether reported emissions figures are accurate — a responsibility, not a reassurance.
The last time I sat in a committee meeting where the sustainability report was tabled for approval, the emissions figures took less airtime than a single disputed line in the management accounts. That is the wrong ratio, and a written parliamentary reply this year has made the point for me better than I have managed to.
Mr Dennis Tan asked what ACRA and SGX RegCo have put in place to ensure the accuracy and reliability of Scope 1 and Scope 2 greenhouse gas emissions disclosures by listed companies from FY2025, given that mandatory external limited assurance on those disclosures is only required from FY2029. The reply, from Mr Gan Kim Yong as Chairman of MAS, pointed to the machinery already in place: the Greenhouse Gas Protocol as the required measurement standard, disclosure of measurement approaches, inputs and assumptions, internal review of reporting processes, and — his words — appropriate board oversight on all their disclosures. He also noted that reporting rates have climbed from around 50 to 87 per cent for Scope 1, and 61 to 93 per cent for Scope 2, between 2023 and 2025.
Completeness is not accuracy
Those reporting-rate numbers are real progress, and I do not want to be dismissive of them. But they measure whether a company disclosed a figure, not whether the figure is right. Between now and FY2029 — four full reporting cycles — boards are approving emissions data that no external assurer will examine. The reply is explicit that the control in the interim is the company's own processes and its board. That is a responsibility being placed on directors, not a comfort being offered to them.
“For four more reporting cycles, the only assurance on your emissions numbers is your own board's diligence. The regulator has said so in writing.”
What I would ask before signing off
- Who owns the emissions calculation, and have they walked the committee through the boundary decisions — which legal entities, which sites, which activities are in and out, and why?
- Where are the estimates, and how large are they? A number built on supplier averages and extrapolation is not the same as one built on metered data, and the report rarely makes the difference visible.
- What changed since last year, and is the change operational or methodological? A 12 per cent fall driven by a new emissions factor is not a 12 per cent decarbonisation, and should not be presented as one.
- If this figure were assured today, where would the assurer push back first — and can we answer that now, or are we hoping to have three years to work it out?
The FY2029 assurance deadline is being treated in some boardrooms as the date the emissions numbers start to matter. It is the opposite. It is the date someone outside the building starts checking them. Until then, the accuracy of what a Singapore-listed company reports about its emissions is governed entirely by its own management and its own board — and, in too many cases I have seen, by a committee that gives it ten minutes at the end of a long agenda.
Common Questions
Do Singapore-listed companies need external assurance on Scope 1 and Scope 2 emissions before FY2029?
No. Mandatory external limited assurance on Scope 1 and Scope 2 greenhouse gas emissions applies to listed issuers only from FY2029. For FY2025 to FY2028 disclosures the safeguards are the Greenhouse Gas Protocol measurement standard, disclosure of methods and assumptions, internal review of reporting processes, and board oversight — there is no independent third-party check in that window.
What is the board's responsibility for emissions disclosure accuracy in Singapore?
SGX RegCo requires listed companies to have robust processes, data governance, internal controls and appropriate board oversight over all disclosures, including greenhouse gas emissions. In the years before assurance becomes mandatory, the board is effectively the primary control over whether reported emissions figures are reliable, and should interrogate calculation boundaries, the share of the number that is estimated, and year-on-year movements.
What should a Singapore audit or risk committee ask about the emissions figures in a sustainability report?
Ask who owns the calculation and what boundary decisions they made, how much of the figure is estimated rather than measured, whether year-on-year changes are operational or methodological, and where an external assurer would most likely challenge the number if assurance applied today.
About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.