Malaysia ESG Reporting Timeline for Listed Companies: NSRF, Bursa Malaysia & IFRS S1/S2
Updated · By SustenyX
Malaysia’s ESG reporting timeline is phased: Group 1 starts in 2025, Group 2 in 2026 and Group 3 in 2027. The National Sustainability Reporting Framework (NSRF) introduces reporting based on the ISSB Standards (IFRS S1 and IFRS S2), with transition reliefs before full disclosures and Scope 3 emissions reporting apply. Mandatory reasonable assurance over Scope 1 and Scope 2 emissions now starts in 2028 for Group 1, after a one-year deferral announced in September 2026.
For listed companies, preparation starts with identifying the applicable group and financial year, then checking disclosure requirements against existing data and controls.
Malaysia ESG reporting timeline at a glance
| Group | Entities covered | Reporting starts | Full adoption and Scope 3 | Mandatory reasonable assurance, Scope 1 and 2 |
|---|---|---|---|---|
| Group 1 | Main Market issuers with market capitalisation of RM2 billion or more | 2025 | 2027 | 2028 |
| Group 2 | Other Main Market issuers | 2026 | 2028 | 2029 |
| Group 3 | ACE Market issuers and large non-listed companies (annual revenue of RM2 billion or more) | 2027 | 2030 | 2030 |
The NSRF years refer to annual reporting periods beginning on or after 1 January of the stated year, not to a single report-publication deadline. Bursa Malaysia’s requirements use financial-year-end triggers, so check the applicable listing rules for your financial year, particularly if it does not follow the calendar year. The Scope 3 relief does not cover categories already required by the relevant regulator. Non-listed companies should check their own regulator’s rules.
Sources: SC NSRF implementation graphic and SC assurance announcement, 17 September 2026
Malaysia ESG Timeline for Listed Companies: Your 2025 Compliance Roadmap
Our original six-page slide deck, first shared on LinkedIn in August 2025. For the current assurance dates, see the table above.
What is Malaysia’s National Sustainability Reporting Framework?
The NSRF sets IFRS S1 and IFRS S2, issued by the International Sustainability Standards Board (ISSB), as Malaysia’s baseline sustainability disclosure standards. It aims to make company information more consistent, comparable and reliable for investors.
Its climate-first approach gives companies time to build reporting capability. Transition relief does not remove the need to build a reliable reporting process.
Which group does your listed company belong to?
Group 1: larger Main Market issuers
Bursa Malaysia measures market capitalisation excluding treasury shares. For existing issuers the reference date is 31 December 2024; for a new Main Market listing, it is the date of admission. A later fall below RM2 billion does not move an issuer out of Group 1. Group 1 issuers prepare their Sustainability Statement under the IFRS Sustainability Disclosure Standards from the annual report for the financial year ending on or after 31 December 2025.
Group 2: other Main Market issuers
An issuer below RM2 billion on 31 December 2024 stays in Group 2 even if its market capitalisation later rises above the threshold. Group 2 issuers apply the standards from the annual report for the financial year ending on or after 31 December 2026.
Source: Bursa Assist, How do listed issuers determine their Group?
Group 3: ACE Market issuers and large non-listed companies
Group 3 covers ACE Market issuers and non-listed companies with consolidated group revenue of RM2 billion or more for the two consecutive financial years before the current one. Where there is no group-level revenue, the threshold is measured at company level. Non-listed companies should check their own regulator’s implementation rules and exemptions.
Source: SC NSRF implementation graphic
What is the difference between IFRS S1 and IFRS S2?
IFRS S1 covers sustainability-related risks and opportunities that could reasonably be expected to affect a company’s prospects. IFRS S2 covers climate-related risks and opportunities.
Both are organised around four core areas:
| Area | The question your report needs to answer |
|---|---|
| Governance | Who oversees these risks and opportunities, and through which processes? |
| Strategy | How do they affect the business model, plans and financial prospects? |
| Risk management | How are they identified, assessed, prioritised and monitored? |
| Metrics and targets | Which measures and targets does the company use, and what progress has it made? |
Source: IFRS Foundation, Introduction to the ISSB Standards
A report that describes community programmes or environmental activities alone will not answer these questions. Disclosures need to connect to business decisions, financial planning and risk oversight.
How does the climate-first transition work?
Groups 1 and 2 receive two reporting periods of additional relief; Group 3 receives three. During that time a company may disclose climate-related information only (under IFRS S2), focus those disclosures on its principal business segments, and leave out Scope 3 emissions, except for categories already required by its regulator. The table above shows the resulting full-adoption years.
Source: SC NSRF implementation graphic
Use the relief period to close gaps. Procurement teams can identify the supplier information they will need, operations can organise activity data, and finance can help set up consistent evidence and review procedures.
What changed for sustainability assurance in September 2026?
On 17 September 2026 the Securities Commission announced that the Advisory Committee on Sustainability Reporting (ACSR) had deferred mandatory reasonable assurance over Scope 1 and Scope 2 greenhouse gas emissions. For Group 1 it now applies to annual reporting periods beginning on or after 1 January 2028, instead of 2027. The requirement covers those emissions disclosures, not the whole sustainability report.
Listed issuers must still state whether their sustainability disclosures were reviewed by internal auditors or independently assured. Independent assurance must be performed under ISSA 5000.
Source: SC announcement, 17 September 2026
The practical priority is evidence quality. A reported emissions figure should be traceable to its source records, calculation method, reporting boundary and review decisions.
What should Malaysian listed companies do now?
This is a suggested preparation workflow, not a regulatory checklist:
- Confirm applicability. Record your group, the determination date, your financial year and the requirements that apply.
- Assess disclosure gaps. Map existing statements against IFRS S1 and S2 and identify missing explanations or evidence. Tools such as Gap Analysis InsightX for IFRS S1/S2 can do this indicator by indicator.
- Assign data owners. Agree responsibilities across sustainability, finance, operations, procurement, risk and internal audit.
- Document emissions methods. Keep activity records, emission factors, assumptions, boundaries and calculation versions.
- Prepare value-chain data. Identify likely Scope 3 information needs and engage suppliers before your milestone.
- Strengthen review controls. Set up approvals, reconciliations and an evidence trail that supports assurance.
- Connect reporting with decisions. Bring material risks and opportunities into budgets, strategy and board discussions.
For example, if electricity consumption is compiled from invoices across several locations, assign a data owner for each location and reconcile the consolidated total. Record how estimates and missing invoices are handled. The number is then easier to explain and to assure.
How does NSRF reporting relate to ESG ratings?
Keep disclosure compliance separate from the criteria individual rating providers use. Meeting a reporting requirement does not guarantee a particular rating or index inclusion.
For related reading, see FTSE4Good criteria decoded for Malaysian companies, the most common FTSE4Good disclosure gaps we see in Malaysian PLCs, and our guide to ESG ratings for Malaysian PLCs.
Frequently asked questions
Is sustainability reporting mandatory for Bursa Malaysia listed issuers?
Yes. Listed issuers have sustainability reporting obligations. Which requirements apply depends on the market, the issuer’s group and its financial year. See Bursa Malaysia’s group guidance and the NSRF overview.
Are the timeline years report-publication deadlines?
No. They mark reporting periods. Check Bursa Malaysia’s financial-year-end triggers and your annual report deadline for the date that applies to your company.
What is the difference between IFRS S1 and IFRS S2?
IFRS S1 covers sustainability-related financial disclosures in general; IFRS S2 focuses on climate-related disclosures. Both cover governance, strategy, risk management, and metrics and targets.
Does the assurance update cover the entire sustainability report?
No. The mandatory reasonable assurance requirement covers Scope 1 and Scope 2 greenhouse gas emissions disclosures. The current dates are in the timeline table above.
Should we wait until the reliefs expire to collect supplier data?
No. Identify information needs, responsible teams and evidence requirements while the reliefs apply, so gaps can be fixed before full reporting starts.
Check your disclosures against IFRS S1 and S2
Gap Analysis InsightX for ISSB IFRS S1/S2 assesses sustainability and annual reports against IFRS S1 and S2 disclosure requirements. It works indicator by indicator, shows which criteria are met, partially met or missing, and ranks the gaps by compliance impact so effort goes where it matters most.
This article provides general information, not legal or regulatory advice. Check current requirements and guidance from your regulator when assessing your company’s obligations.
