Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
With mandatory sustainability reporting now in force for SGX-listed companies and MAS guidelines tightening for financial institutions, board directors need more than awareness — they need working fluency. Here is what that looks like in practice.
Singapore entered a new phase of ESG governance in 2025. Mandatory climate-related disclosures under the TCFD framework are now required for all SGX Mainboard issuers with market capitalisation above S$1 billion, with smaller companies following on a phased schedule. MAS has embedded environmental risk management expectations into supervisory guidance for banks, insurers, and asset managers. The ISSB standards — IFRS S1 and S2 — are being adopted progressively across the region.
What this means for board directors is that ESG is no longer a topic that can be left to a sustainability committee or a CSR team. Directors are now signing off on climate disclosures that contain forward-looking assumptions, scenario analyses, and judgements about material risk — all of which carry potential liability exposure if they are materially misleading. That requires a level of board literacy that most director development programmes have not kept pace with.
What working fluency looks like
I want to be precise about what I mean by fluency, because I am not describing a requirement for directors to become sustainability professionals. What I am describing is the ability to:
- Understand the difference between Scope 1, 2 and 3 emissions and why Scope 3 (required from FY2026) is both the most material and the most difficult to measure
- Interpret a climate scenario analysis and ask whether the scenarios are sufficiently severe and relevant to the company's actual business exposure
- Challenge a sustainability report's claims about targets — specifically whether the targets are connected to capital planning and operational decisions, or are aspirational statements without a funding mechanism
- Understand what physical risk means for a specific business — asset impairment, insurance costs, supply chain disruption — and whether management has a credible response
- Know when the company's ESG disclosure requires independent assurance and what level of assurance is appropriate for the risk
“Directors who sign sustainability disclosures without the fluency to challenge them are carrying liability exposure that most of them have not been told about.”
The Singapore regulatory context
The MAS Guidelines on Environmental Risk Management set out expectations that go well beyond disclosure. They require boards of MAS-regulated entities to understand environmental risks as financial risks — embedded in credit assessment, asset valuation, underwriting, and capital management. That is a governance requirement, not a reporting one.
For directors of non-financial companies, the SGX sustainability reporting requirements now include board statements that carry the same weight as financial statements in terms of regulatory expectation. The question is not whether the sustainability team produced an adequate report. The question is whether the board can stand behind its content.
What I cover in ESG board training
When I deliver ESG governance training through SMU Academy and the Singapore College of Insurance, I focus on three modules that I have found directors find most practically useful.
- Understanding material ESG risks for your sector: physical, transition, and social risks translated into financial and governance terms
- Reading and challenging sustainability reports: what the disclosure is actually saying, what is missing, and what questions to put to management
- Director obligations under Singapore's ESG regulatory framework: MAS guidelines, SGX requirements, ISSB standards, and where personal fiduciary duty touches ESG decisions
Directors who have gone through this training consistently report that they feel more confident engaging with management on ESG matters — not because they know more than the sustainability team, but because they know enough to ask better questions. That is the governance value I am trying to produce.
If your board is approaching its next sustainability disclosure cycle without that confidence, it is worth addressing before the disclosure is signed rather than after it is published.
Common Questions
What ESG training do Singapore board directors need?
Singapore board directors need training that covers the regulatory requirements (SGX mandatory sustainability reporting, MAS environmental risk guidelines), how to read and challenge climate scenario analysis and sustainability reports, and the personal fiduciary obligations that now attach to ESG disclosures under Singapore law.
Is ESG reporting mandatory for SGX-listed companies in Singapore?
Yes. From FY2025, all SGX Mainboard-listed companies must disclose climate-related information under a TCFD-aligned framework. The requirements are phased by market capitalisation, with larger companies leading. Scope 3 emissions disclosure is required from FY2026.
Where can Singapore board directors get ESG governance training?
Raymond Cheung delivers ESG governance training through SMU Academy and the Singapore College of Insurance, tailored for board directors and C-suite executives. Training covers the Singapore regulatory framework, board obligations, and how to govern ESG risk effectively.
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.