ACGA Response to ACRA consultation on Singapore Sustainability Disclosure Standards

2026-10-23

On 23 October 2026, ACGA submitted comments to the Accounting and Corporate Regulatory Authority (ACRA) on the exposure drafts of the Singapore Sustainability Disclosure Standards (SDS). The proposals followed a climate-first approach, setting out a mandatory climate-focused standard (SFRS S2) that incorporates the climate-relevant parts of the broader sustainability standard (SFRS S1) as an appendix, whilst leaving the full application of SFRS S1 voluntary. The paper aimed to set out a framework for clear, decision-useful climate reporting aligned with the international ISSB baseline of IFRS S1 and IFRS S2, applied within Singapore’s domestic context.

We supported this structure, the requirement for an explicit compliance statement covering the rules that apply to each company, and the removal of certain transition reliefs from the voluntary standard. However, we recommended keeping the duty to consider industry-based SASB materials and replacing the open-ended relief on Scope 3 emissions with a clear, time-bound phase-in or regular review so that Singapore does not diverge permanently from the global baseline.

We thank our members who contributed their inputs. The ACGA full response can be found here.