Last updated: May 26, 2026. Malaysia sustainability reporting is now moving through a clear transition from Bursa Malaysia's earlier Sustainability Statement framework to the National Sustainability Reporting Framework, or NSRF. The NSRF uses the ISSB Standards, specifically IFRS S1 and IFRS S2, as Malaysia's baseline sustainability disclosure standards for listed issuers and large non-listed companies.
Short answer: Sustainability reporting is required for Bursa Malaysia listed issuers through the Sustainability Statement in the annual report. Large Main Market issuers started the ISSB-aligned NSRF cycle for annual reporting periods beginning on or after January 1, 2025. Other Main Market issuers start from January 1, 2026. ACE Market issuers and large non-listed companies with annual revenue of RM2 billion and above start from January 1, 2027. Companies should check whether they are still reporting under the transitional Bursa Sustainability Statement requirements or already preparing IFRS S1 and IFRS S2 disclosures under the NSRF.
Who needs to report sustainability information in Malaysia?
The main mandatory sustainability reporting regime applies to companies listed on Bursa Malaysia's Main Market and ACE Market. These companies prepare a Sustainability Statement as part of their annual reporting obligations.
The NSRF also brings large non-listed companies into scope. For this purpose, large NLCos are companies with annual revenue of RM2 billion and above. SC Malaysia's NSRF materials explain that the revenue threshold is calculated based on consolidated group revenue of RM2 billion or more for two consecutive financial years before the current financial year, or at company level where group-level revenue is not available.
Other companies may not be directly in scope, but may still receive ESG, climate, or GHG data requests from listed customers, banks, investors, parent companies, or supply-chain programmes. In Malaysia, supplier data requests are likely to increase as listed issuers move into IFRS S2 climate reporting, Scope 3 emissions preparation, and Bursa's Centralised Sustainability Intelligence, or CSI, supplier engagement workflows.
How Malaysia's reporting framework evolved
Malaysia's listed-company sustainability reporting framework has developed in stages. Bursa Malaysia first amended the Main Market and ACE Market Listing Requirements in 2015 to require listed issuers to include a Sustainability Statement in annual reports, replacing the earlier corporate social responsibility statement approach.
In September 2022, Bursa Malaysia introduced enhanced sustainability reporting requirements. These pushed listed issuers toward more structured disclosure on sustainability governance, scope and basis, material sustainability matters, climate-related disclosures, assurance or internal review, and performance data.
The more important current shift is the NSRF, launched by the Securities Commission Malaysia on September 24, 2024. The NSRF formally adopts IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures as Malaysia's baseline sustainability disclosure standards. Bursa Malaysia then amended the Main Market and ACE Market Listing Requirements in December 2024 to align listed-issuer Sustainability Statements with the NSRF.
NSRF adoption timeline
The NSRF timeline is phased by entity group. For companies with a December 31 financial year end, the timing broadly maps to annual reports for financial years ending December 31, 2025, December 31, 2026, and December 31, 2027 respectively.
- Group 1: Main Market listed issuers with market capitalization of RM2 billion and above. These companies use the ISSB Standards for annual reporting periods beginning on or after January 1, 2025.
- Group 2: Other Main Market listed issuers. These companies use the ISSB Standards for annual reporting periods beginning on or after January 1, 2026.
- Group 3: ACE Market listed issuers and large non-listed companies. These companies use the ISSB Standards for annual reporting periods beginning on or after January 1, 2027.
For listed issuers, Bursa Malaysia Practice Note 9A expresses the effective dates through the annual report. Group 1 listed issuers apply the IFRS-aligned Sustainability Statement requirement in annual reports issued for financial years ending on or after December 31, 2025. Group 2 listed issuers apply it in annual reports issued for financial years ending on or after December 31, 2026.
What the NSRF requires
The NSRF is built around IFRS S1 and IFRS S2. IFRS S1 covers general sustainability-related financial information. IFRS S2 covers climate-related disclosures. In practical terms, companies need to connect sustainability and climate risks and opportunities to governance, strategy, risk management, metrics, targets, financial effects, and investor-useful decision making.
The first implementation phase is climate-first. Under NSRF transition reliefs, Group 1 and Group 2 companies may focus on climate-related risks and opportunities under IFRS S2 for their first two annual reporting periods. Group 3 companies may use that climate-first relief for their first three annual reporting periods.
The relief does not mean companies can ignore governance, data boundaries, or controls. IFRS S2 still requires structured disclosure on climate governance, strategy, risk management, metrics and targets, greenhouse gas emissions, climate-related risks and opportunities, transition risks, physical risks, and scenario analysis where relevant.
Scope 1, Scope 2, and Scope 3 emissions
GHG emissions are a major part of the Malaysia transition. The NSRF and PACE materials point companies toward Scope 1, Scope 2, and Scope 3 emissions measurement, with practical support such as emissions calculators and capacity-building programmes.
Scope 3 disclosure is phased. Group 1 companies are expected to disclose relevant Scope 3 emissions from the third year of reporting, which means 2027. Group 2 companies are expected to disclose relevant Scope 3 emissions from 2028. Group 3 companies are expected to disclose relevant Scope 3 emissions from 2030.
This matters for suppliers. Even where a supplier is not directly regulated under the NSRF, the supplier may be asked by a listed customer to provide energy, fuel, logistics, purchased goods, waste, or other activity data that supports Scope 3 calculation.
What changed about common sustainability matters?
The older Bursa enhanced reporting framework introduced common sustainability matters, including topics such as anti-corruption, community, diversity, energy, health and safety, labour practices, supply chain, data privacy, and water. Many older Malaysia sustainability reporting summaries still describe these as a mandatory live list.
Bursa Malaysia has since clarified that the common sustainability matters introduced on September 26, 2022 are disapplied with immediate effect and are no longer required in Sustainability Statements issued for financial years ending on or after December 31, 2025.
That does not make those topics irrelevant. A company may still disclose them where material, where required by IFRS S1 or IFRS S2, where needed for stakeholder decision making, or where relevant under other frameworks such as GRI. The important point is that companies should not build a 2026 reporting workplan around the old nine-common-matters list as if it were still the main mandatory Bursa requirement.
Assurance and internal review
Assurance is also in transition. Bursa's transitional Sustainability Statement requirements refer to a statement on whether the Sustainability Statement has been subjected to internal review by internal audit or independent assurance under recognized assurance standards.
Under the NSRF, the broader sustainability assurance framework is still being developed. SC Malaysia has stated an aim to mandate reasonable assurance on Scope 1 and Scope 2 GHG emissions starting with Group 1 from annual reporting periods beginning on or after January 1, 2027, followed by Group 2 from 2028 and Group 3 from 2029. That timeline is subject to the final sustainability assurance framework and further consultation.
Companies should therefore prepare evidence and controls now, especially around energy, fuel, emissions factors, calculation methods, boundaries, assumptions, and data ownership, while checking final assurance rules before signing off the formal assurance scope.
Bursa Sustainability Reporting Guide and PACE
Bursa's Sustainability Reporting Guide and Toolkit remains a useful reference during transition, but it should be read in context. Bursa has said the third edition guide remains applicable for Group 1 listed issuers until FYE December 31, 2024 and for Group 2 listed issuers until December 31, 2025. As the NSRF takes over, companies should rely on the ISSB Standards, SC Malaysia's NSRF materials, Bursa Listing Requirements, Practice Note 9A, and PACE guidance for the current reporting cycle.
PACE, which stands for Policy, Assumptions, Calculators and Education, is the ACSR initiative supporting NSRF implementation. It provides guidance, emissions calculators, and capacity-building programmes. Bursa's CSI solution also supports sustainability reporting and supplier engagement, including IFRS S1 and IFRS S2 disclosure support, Scope 1 and Scope 2 tools, and supplier-focused Scope 3 workflows.
What companies should prepare
A practical Malaysia reporting workplan should start with the entity's group and reporting year. Companies should then build the disclosure and data workstream around the applicable regime.
- Confirm whether the company is Group 1, Group 2, Group 3, a large NLCo, or outside direct NSRF scope.
- Confirm whether the current report is still transitional Bursa Sustainability Statement work or already IFRS S1 and IFRS S2 reporting.
- Map sustainability and climate governance, board oversight, management roles, and internal controls.
- Identify climate-related risks and opportunities, including transition risks and physical risks.
- Define reporting boundaries, principal business segments, subsidiaries, and value-chain boundaries.
- Calculate Scope 1 and Scope 2 emissions and prepare for relevant Scope 3 categories.
- Document GHG methodologies, emission factors, assumptions, exclusions, and data-quality checks.
- Review whether old common sustainability matters are still useful as material topics, while avoiding outdated mandatory language.
- Prepare for internal review or external assurance readiness, especially for Scope 1 and Scope 2 GHG emissions.
- Use PACE and Bursa CSI resources where relevant for reporting, emissions calculation, and supplier engagement.
Common reporting mistakes
The first mistake is treating the NSRF as a simple rebrand of the old Bursa Sustainability Statement. It is a move toward IFRS S1 and IFRS S2, which asks companies to connect sustainability information to financial relevance, governance, strategy, risk management, metrics, and targets.
The second mistake is relying on the old common sustainability matters list without checking the current Bursa position. The old list may still help with materiality and stakeholder topics, but it is no longer required for Sustainability Statements issued for FYE on or after December 31, 2025.
The third mistake is delaying GHG data collection until Scope 3 becomes mandatory. Scope 1 and Scope 2 emissions should be controlled early, and Scope 3 preparation should start before the formal disclosure year because supplier engagement and data-quality improvement take time.
The fourth mistake is assuming the assurance framework is settled. Companies should prepare evidence for assurance, but should confirm final rules, standards, provider requirements, and timelines before setting a formal assurance engagement.
How Keslio can help
Keslio helps companies turn Malaysia sustainability reporting requirements into a practical reporting workplan, data request, and evidence-backed disclosure. Depending on the trigger, we can support:
- NSRF, IFRS S1, and IFRS S2 readiness reviews;
- Bursa Sustainability Statement gap checks;
- climate-risk and opportunity mapping;
- GHG emissions calculations for Scope 1, Scope 2, and relevant Scope 3 categories;
- supplier and value-chain data collection for Scope 3 preparation;
- methodology notes, evidence trackers, and assurance-readiness files;
- sustainability reporting and communications for annual reports or standalone sustainability reporting; and
- supplier request support where the ESG trigger comes from a customer, buyer, or investor rather than direct listing-rule applicability.
This guide is not legal advice. If your company is determining formal applicability, filing obligations, or interpretation of Bursa Malaysia or SC Malaysia requirements, legal counsel, company secretarial advisers, or the relevant regulator should confirm the obligation while Keslio supports the ESG data, calculations, reporting, and evidence workstream.
Sources and further reading
- Securities Commission Malaysia NSRF microsite
- SC Malaysia media release launching the NSRF
- SC Malaysia National Sustainability Reporting Framework summary
- SC Malaysia FAQ on the National Sustainability Reporting Framework
- SC Malaysia PACE implementation resources
- Bursa Malaysia Main Market Practice Note 9A
- Bursa Assist clarification on common sustainability matters
- Bursa Assist explanation of the CSI solution
