Singapore

Yes.

Mandatory ESG disclosure requirements apply to listed companies, large non-listed companies (NLCos), funds with an ESG focus, and financial institutions in Singapore:

Issuers listed on the Singapore Exchange (SGX)

Listing Rule 711A requires every issuer to prepare an annual sustainability report, which must describe the issuer's sustainability practices with reference to the primary components set out in Listing Rule 711B on a 'comply or explain' basis. The primary components are (i) material environmental, social and governance factors; (ii) climate-related disclosures (CRD); (iii) policies, practices, and performance in relation to material ESG factors; (iv) targets; (v) sustainability reporting framework; and (vi) a board statement and associated governance structure for sustainability practices. These are to be disclosed on a mandatory basis from FY2026.^[1]

Additionally, effective from FY2026, an issuer must issue a sustainability report for its financial year at the same time as the issuance of its annual report, or where the issuer has conducted external assurance on the sustainability report, no later than five months after the end of the financial year. Issuers are also required to set a board diversity policy that addresses gender, skill and experience, as well as other relevant aspects of diversity. Issuers must describe the board diversity policy and details relating to the diversity targets, plans, timelines and progress in their annual reports.^[2]

SGX further recommends a list of 27 Core ESG Metrics for issuers to use as a starting point for sustainability reporting. They include metrics such as GHG emissions, occupational health and safety, age-based diversity, and alignment with frameworks.^[3]

Enhanced CRD apply under a three-tier structure that phases reporting obligations based on market capitalisation:^[4]

(a) For all listed companies, Scope 1 and 2 GHG emissions reporting is mandatory while external limited assurance for Scope 1 and 2 GHG emissions is mandatory by FY2029.

(b) For listed companies that are constituents of the Straits Times Index (STI)^[5], other ISSB-based CRD is mandatory, and Scope 3 GHG emissions reporting is mandatory from FY2026.

(c) For non-STI constituent listed companies with a market capitalisation of S$1 billion and above, other ISSB-based CRD is mandatory from FY2028 while those with a market capitalisation of less than S$1 billion will follow from FY2030. Scope 3 GHG emissions reporting will be voluntary for non-STI constituent listed companies until further notice.

Large NLCos

The Accounting and Corporate Regulatory Authority (ACRA) will require reporting by NLCos with an annual revenue of at least S$1 billion and total assets of at least S$500 million (Large NLCos) on ISSB-aligned CRD (including Scope 1 and 2 GHG emissions) – this has been deferred to FY2030.^[6] Scope 3 GHG emissions reporting remains voluntary until further notice. External limited assurance for Scope 1 and 2 GHG emissions is deferred to FY2032.

ACRA will further review whether to mandate climate reporting by smaller NLCos limited by shares with annual revenue of at least S$100 million to less than S$1 billion.

Retail funds with ESG investment focus

Under Circular No. CFC 02/2022 (Circular) issued by the Monetary Authority of Singapore (MAS) in 2022, disclosure and reporting guidelines apply to companies offering retail ESG funds that are lodged with MAS on or after 1 January 2023. It also sets out MAS’s expectations on how existing requirements under the Code on Collective Investment Schemes (CIS Code) and the Securities and Futures (Offers of Investments) (Collective Investment Schemes) Regulations 2005 (SF(CIS)R) apply to retail ESG funds.

Under the Circular, a scheme whose name includes or uses ESG-related or similar terms such as “sustainable” or “green” should reflect such an ESG focus in its investment portfolio and/or strategy in a sustainable manner and comply with the guidelines in the Circular.

Financial institutions (FIs)

The Guidelines on Environmental Risk Management by MAS (ENRM Guidelines), published in 2020, recommend that FIs make regular and meaningful disclosure of their environmental risks and refer to international reporting frameworks so as to enhance market discipline by investors. FIs are to implement the ENRM Guidelines in a manner commensurate with the size and nature of its activities as well as its risk profile.

The ENRM Guidelines also set out MAS’s supervisory expectations for FIs, including banks, insurers and asset managers, in their governance, risk management and disclosure of environmental risk. Boards and senior management of FIs are expected to incorporate environmental considerations into their strategies, business plans, and product offerings, and maintain effective oversight of the management of environmental risk. FIs should also put in place policies and processes to assess, monitor, and manage environmental risk.

An addendum to the ENRM Guidelines, the Guidelines on Environmental Risk Management – Transition Planning (TPG), was published in 2026 – see section B.3 below for more detail.

CRD and sustainability reporting for SGX-listed issuers 

Please refer to the responses in section A.2 above. Scope 1 and 2 GHG emissions reporting is mandatory for all listed companies. For STI constituents, other ISSB-related CRD reporting is mandatory and Scope 3 GHG emissions reporting is mandatory from FY2026 onwards as ACRA and Singapore Exchange Regulation (SGX RegCo) noted that STI constituent companies demonstrated a higher degree of readiness and capabilities for ISSB-aligned climate disclosures. Other ISSB-related CRD are mandatory from FY2028 for non-STI constituent listed companies whose market capitalisation is at least S$1 billion and from FY2030 for companies whose market capitalisation is less than S$1 billion.

Other primary components of a sustainability report are also mandatory as of FY2026.

SGX’s Core ESG Metrics serve as guidance for listed issuers to use as a starting point for reporting.

CRD for Large NLCos

Large NLCos are required to report ISSB-aligned CRD, excluding Scope 3 GHG emissions, from FY2030.

Retail ESG funds

Disclosures under the SF(CIS)R, read together with the Circular, are mandatory for a fund that represents itself as ESG-focused and includes ESG or green-related terms in its name. While the CIS Code is a non-binding code, in the event of non-compliance, MAS may revoke or suspend the fund’s authorisation under sections 286 and 287 of the Securities and Futures Act 2001.

Financial institutions

The ENRM Guidelines and TPG addendum set out MAS’s supervisory expectations for banks, insurers and asset managers to strengthen their governance, risk management, and disclosure of environmental risk, as well as build effective risk assessment and risk management capabilities for resilience against climate-related risks. They are illustrative rather than prescriptive, with the intention to encourage FIs to adopt best practices as part of their low-carbon transition. How well an FI observes the guidelines and assesses, monitors, mitigates and discloses its risk exposures will contribute to MAS’s overall risk assessment of the FI.

Sector-specific entities

On a sector-specific basis, there are mandatory disclosure requirements prescribed by laws such as the Energy Conservation Act 2012 and the Resource Sustainability Act 2019 that mandate disclosures relating to energy consumption, GHG emissions, e-waste, and packaging waste for companies that meet the prescribed thresholds.

The requirements are primarily focused on climate and the environment, but the requirements by SGX for disclosures by listed issuers and MAS’s requirements on retail ESG funds also include other ESG factors. 

SGX Listing Rules

SGX-listed issuers (please see timelines in section A.2 above) are required to report CRD in accordance with all applicable requirements of IFRS S2, including any reliefs provided by the standards. Issuers are also required to apply the climate-relevant provisions in IFRS S1. The same approach will apply to Large NLCos (please also see timelines in section A.2 above).

Each metric from SGX’s Core ESG Metrics is mapped against globally accepted reporting frameworks such as the GRI Standards, SASB Standards, TCFD Recommendations and World Economic Forum’s metrics.

MAS Circular

While the Circular does not mandate adherence to a specific global standard like the ISSB Standards or the TCFD, it recognises equivalent standards such as the EU Sustainable Finance Disclosure Regulation. The Circular is also aligned in principle with the global standards that are aimed at enhancing transparency and preventing greenwashing.

ENRM Guidelines

The ENRM Guidelines are aligned with international standards, particularly the TCFD framework.

CRD for SGX-listed issuers and Large NLCos 

In line with the ISSB Standards, the requirements adopt a single materiality approach whereby the materiality of information is judged in relation to whether omitting, misstating or obscuring the information could reasonably be expected to influence decisions of primary users of general purpose financial reports. However, issuers are likely to adopt a double materiality approach in practice, as SGX requires, as part of the Material ESG factors primary components, the sustainability report to consider relevance or impact to key stakeholders’ needs.^[1]

ENRM Guidelines

The ENRM Guidelines require FIs to disclose based on a single materiality approach and focus on how environmental risks affect the financial performance and resilience of FIs.

Scope 1 and 2 GHG emissions

Scope 1 and 2 GHG emissions reporting is mandatory for all listed companies. The required measurement methodology is in line with IFRS S2.

Scope 3 GHG emissions

Scope 3 GHG emissions reporting is mandatory for STI constituent listed companies from FY2026. This requirement is currently voluntary until further notice for non-STI constituent listed companies and large NLCos.

MAS Circular

MAS does not require ESG funds to disclose GHG emissions.

ENRM Guidelines

The disclosures of FIs should be aligned with the TCFD framework, which includes GHG emissions as a core metric. FIs are encouraged to disclose Scope 1 and 2, and where appropriate, Scope 3 emissions.

There are currently no external or third-party assurance requirements for ESG reporting in Singapore. However, there are internal review requirements by SGX for issuers.

The requirement to conduct external limited assurance on Scope 1 and 2 GHG emissions will be phased-in as follows:

1. from FY2029 for all listed companies; and
2. from FY2032 for large NLCos.

However, SGX does not propose to mandate external assurance until details on assurance standards and registration criteria for climate auditors are finalised.

There is no mandatory requirement for external or third-party assurance of ESG disclosures under the MAS Circular or in the ENRM Guidelines and TPG.

In general, voluntary ESG disclosures by non-publicly listed companies are still in a nascent stage in Singapore.

In 2023, the Green Finance Industry Taskforce, convened by MAS, published the Singapore-Asia Taxonomy for Sustainable Finance (SAT), which sets out clear, science-based thresholds and criteria across eight sectors for defining green and transition activities in Asia that substantially contribute to climate change mitigation. The SAT is not mandatory and is particularly relevant for sectors facing challenges in reducing emissions and meeting a 1.5 degree aligned outcome due to technological constraints. It has introduced a “traffic light system” to classify the degree of environmental damage that certain activities pose, as well as a “measures-based approach” that seeks to encourage capital investments into decarbonisation measures or processes to reduce emissions intensity of activities. The SAT is aligned with the ASEAN Taxonomy for Sustainable Finance Version 4 launched in 2025.

The Multi-Jurisdiction Common Ground Taxonomy (M-CGT), a comparison of the sustainable finance taxonomies of China, the EU and Singapore, was launched in 2024.^[1] This initiative enhances the interoperability of taxonomies across China, the EU and Singapore. The M-CGT serves as a technical reference document for a wide range of market participants including financial institutions, corporates, investors and external reviewers. It allows them to assess what could be considered green across the three jurisdictions in scope, based on the activities, environmental objectives, and criteria covered in the M-CGT. While the M-CGT is not legally binding, green bonds and funds that align with the M-CGT criteria can be considered by cross-border investors.

In March 2025, MAS published an information note setting out how market participants can use the SAT as a reference tool to achieve their green and transition financing objectives and in developing internal decarbonisation strategies.^[2] The SAT’s transition thresholds and criteria have been adapted to reflect local or regional contexts by considering local regulations and market standards, technology availability and level of deployment, as well as existing production processes.

Yes, the climate-related disclosures in IFRS S1 and IFRS S2 have been incorporated into the SGX Listing Rules on a full-alignment basis. Please see response in sections A.2 and A.3 above on the phased approach.

The use of ISSB Standards beyond climate-related disclosures is encouraged but not mandated. SGX proposes to review the application of the ISSB Standards for disclosure of sustainability-related information beyond climate-related disclosures (e.g. biodiversity, human capital, etc.) a few years later.

There has not been any specific TNFD-related updates or guidance from SGX RegCo.

MAS intends to consult on mandatory disclosure requirements by FIs based on both IFRS S1 and IFRS S2 standards.

Nature-related risks and unlocking financing opportunities

The Singapore Sustainable Finance Association (SSFA) released a white paper titled “Financing Our Natural Capital” to help FIs in Singapore and the region address nature-related risks and opportunities. Through the SSFA, MAS continues to support the financial sector in building capacity to address nature-related risks and unlock financing opportunities.^[1]

Project Greenprint and Project Savannah

MAS is actively working with regulators and organisations such as the Association of Banks in Singapore, ACRA and Enterprise Singapore to standardise and streamline sustainability data to support relevant stakeholders in the industry in mobilising capital to sustainable projects, monitoring commitments and measuring impact. ^[2] MAS announced an initiative named Project Savannah on 22 June 2023 to generate ESG data credentials for micro, small and medium-sized enterprises (SMEs), and simplify the ESG reporting process. It launched ESGpedia in March 2025 as the Project Greenprint ESG Registry in Singapore with the goal of providing a one-stop platform for ESG data.

Taxonomies

The SSFA is driving several initiatives to promote the application of the SAT. It has also released “Guidance for Leveraging the SAT in Green and Transition Financing” to help industries raise transition financing with greater confidence.^[3]

Workforce Transformation

In 2024, MAS, together with the Institute of Banking and Finance, launched the Sustainable Finance Jobs Transformation Map (JTM). The JTM lays out the impact of sustainability trends on jobs in the financial sector, and identifies the skills required for growing sustainable finance in the region. The Enterprise Sustainability Programme by Enterprise Singapore also supports SMEs to build their sustainability capabilities and provides workshops and a playbook for sustainability reporting for SMEs.^[4]

Yes. Singapore has committed to achieving net zero emissions by 2050 under the Singapore Green Plan 2030 and its Long-term Low Emissions Development Strategy. Singapore has also committed to reduce emissions to between 45 and 50 million tonnes of carbon dioxide equivalent by 2035 after peaking emissions earlier as part of its revised 2035 NDC.^[1]

These targets are embedded in national climate policy and strategic frameworks rather than standalone climate legislation. However, sector-specific requirements and measures are implemented through legislation and regulations including measures relating to energy efficiency, carbon pricing and emissions reporting. To facilitate the attainment of these goals, Singapore plans to reduce emissions by:

1. Transforming industries, the economy and society towards greater energy efficiency, adopting renewable energy, and reducing energy consumption.
2. Adopting advanced low-carbon technologies and using low-carbon fuels.
3. Pursuing effective international cooperation, relating to international climate action, regional power grids, and market-based mechanisms.
4. Adopting low-carbon practices such as greener mobility and cleaner vehicles.  

Singapore has also adopted sectoral decarbonisation roadmaps and transition strategies, including the Singapore Sustainable Air Hub Blueprint for aviation, the Maritime Singapore Decarbonisation Blueprint for maritime, the Singapore Green Building Masterplan and the Built Environment Decarbonisation Technology Roadmap for the built environment, energy transition strategies for the power sector, as well as the Land Transport Master Plan 2040 and the Zero Waste Masterplan for transport and waste respectively. 

Whilst Singapore does not have an ETS, it has a carbon tax which is levied on industrial facilities that directly emit at least 25,000 tonnes of GHG emissions annually. These generally cover the manufacturing, power, waste and water sectors. In 2025, the carbon tax rate is S$25 per tonne  and will be raised to S$45 per tonne in 2026 and 2027, with a view of reaching S$50 to S$80 per tonne by 2030. Additionally, eligible taxable facilities can now use high-quality international carbon credits to offset up to 5% of their taxable emissions. Under a Transition Framework, Emissions-intensive Trade Exposed^[1] (EITE) companies which face significant carbon leakage risk are provided transitory allowances for a portion of their emissions. 

Singapore has been engaging like-minded countries in carbon trading on a bilateral basis under Article 6 of the Paris Agreement. This is underpinned by legally binding Implementation Agreements, which will require corresponding adjustments to prevent double counting of emissions reductions across countries and for carbon credit developers to make a monetary contribution equivalent to a 5% share of proceeds towards the host countries’ adaptation actions and/or the UNFCCC Adaptation Fund.

As of 2025, Singapore hosts more than 120 firms offering a wide range of carbon-related services, including project origination, verification, trading, and advisory. The National Climate Change Secretariat (NCCS) of Singapore is actively exploring opportunities to anchor international sectoral carbon trading schemes, such as the Carbon Offsetting and Reduction Scheme for International Aviation.

It is currently not mandatory for companies to have a transition plan. However, requirements are being phased in (as outlined in section A.2 above) for SGX-listed companies to make climate-related disclosures based on the ISSB Standards, which includes information related to transition planning.

On 8 September 2023, SGX RegCo affirmed that the disclosure of transition plans by issuers is important to fulfil the growing interest from investors and other stakeholders on how the issuer intends to meet its climate ambitions. SGX RegCo has provided guidance on its expectations for credible climate transition plans. However, this has not been made mandatory.

FIs can voluntarily put in place transition plans, with the MAS having issued the TPG (as mentioned in section A.2(d) above) to support FIs in developing credible and effective transition strategies. While MAS has not set out expectations for FIs to publish a transition plan, it provides guidance to FIs on the internal processes that underpin transition planning, including governance, risk management and client engagement.

In particular, the TPG elaborates MAS’s supervisory expectations for FIs to manage the transition and physical risks they and their portfolios face from climate change. FIs are to assess and manage the risks associated with both physical and transition risks arising from climate change, engage their customers and investee companies to better understand the climate-related risks they face and their management of such risks to avoid the indiscriminate withdrawal of credit, insurance coverage or investments. FIs should also keep pace with the development of knowledge and capabilities relating to the measurement and management of climate-related risks.

The TPG will take effect from September 2027, after an 18-month transition period.

Please see section B.3 above. There is no mandatory requirement to set climate-related targets. Nevertheless, the ISSB Standards require the disclosure of any targets used by the organisation to manage climate-related risks and opportunities or climate-related targets the organisation is required to meet under relevant laws, and performance against such targets.

A mandatory EPR scheme is in place for e-waste. A mandatory packaging reporting framework has also been implemented for producers of packaged products, as well as large retailers, laying the foundation for a mandatory EPR regime to manage packaging waste including plastics. This includes the submission of packaging data and reduction plans. A beverage container return scheme, as the first phase of the EPR approach for packaging waste management, has been implemented from April 2026.

Singapore does not currently have economy-wide mandatory corporate sustainability due diligence requirements. Instead, certain sector-specific and disclosure-related requirements are in place that encourage companies to assess and manage sustainability-related risks. For example, listed companies are required to make disclosures on ESG risks as part of sustainability disclosures under the SGX Listing Rules, while FIs are subject to supervisory expectations from MAS on environmental risk management, including the management of environmental risks arising from their activities.  

The MAS actively promotes the development of sustainable finance and investment in Singapore, with the aim of strengthening Singapore’s position as a leading centre for Green and Sustainable Finance in Asia and globally. Key initiatives include:

Taxonomy development

Please refer to our response in section A.10 above.

Sustainable finance incentives

To encourage more sustainable bond and loan issuances, and greater investment in green projects, MAS provides grants under the Sustainable Bond Grant Scheme and Green and Sustainability-linked Loan Grant Scheme.

Blended finance initiatives

MAS has established the Financing Asia’s Transition Partnership (FAST-P), which aims to catalyse private capital for sustainable infrastructure and transition projects through partnerships involving public, private and philanthropic capital providers.

Transition finance initiatives

MAS has also established the Transition Credits Coalition (TRACTION) and issued guidance on credible transition planning for FIs to facilitate financing for emissions-intensive sectors transitioning towards lower-carbon pathways.  

International and regional collaborations

MAS partners with international organisations including the International Finance Corporation (IFC) to support the growth of green bond markets in Asia.

Industry ecosystem development

MAS supports the development of the sustainable finance ecosystem through industry collaboration and capacity-building initiatives, including engagement with industry associations such as the SSFA to strengthen sustainable finance capabilities and promote market development.

Enterprise Singapore also supported the formation of the Action for a Resilient Climate Coalition in 2026 to aggregate corporate demand for high-integrity carbon credits and channel financing towards projects that generate them.

Voluntary Carbon Markets

The NCCS, the Ministry of Trade and Industry, and Enterprise Singapore jointly issued draft guidance on how companies can voluntarily use and purchase voluntary carbon credits as part of a credible decarbonisation plan. The public consultation period for the draft guidance closed on 20 July 2025. The SSFA is also surveying companies for a potential Claims Guidance Code to complement the Singapore Government’s guidance and is cooperating with regional carbon market associations under the ASEAN Common Carbon Framework to support high-quality credit supply and demand signals.

Green Plan 2030^[1]

Pursuant to the Singapore Green Plan 2030 and Singapore’s long-term low emissions development strategy, the Singapore Government will continue to implement policies to facilitate the reduction of GHG emissions and the transition to net-zero.

One such notable policy is the policy on carbon tax, which will be implemented through a progressive framework as outlined in section B.2 above.  

Transition Credits

In September 2023, MAS and McKinsey & Company jointly published a working paper setting out how high-integrity carbon credits (Transition Credits) may be utilised as a complementary financing instrument to accelerate and scale the early retirement of coal-fired power plants. MAS has since announced two pilot projects to facilitate the retirement of coal plants.

In December 2023, the Advertising Standards Authority of Singapore (ASAS) made the nation’s first ruling against a company for making misleading environmental claims about a product. The advertisement in question involved an electronics retailer advertising its air-conditioner as a “best tip” to “save Earth”, depicting an influencer setting the air-conditioner to 23 degrees Celsius to do so.

ASAS requested that the retailer remove the advertisement as it breached the Singapore Code of Advertising Practice (SCAP). The SCAP requires that advertisements not mislead by “inaccuracy, ambiguity, exaggeration or omission”, and not to misrepresent any matter likely to influence consumers’ attitudes to the product. The retailer maintained that it did not violate said guidelines, but nonetheless complied with the request in furtherance of its “cooperative stance towards ASAS”. Although the SCAP guidelines are not legally binding, this ruling signals a move towards greater greenwashing accountability for companies in Singapore.

On 24 February 2026, Market Forces, a climate activist group in Australia, filed a complaint with SGX against a Singapore bank for potential misleading conduct over finance enabling industrial coal power plants in Indonesia. The complaint outlined that the bank’s public disclosures may be materially misleading, as it had not provided complete information regarding the true extent of its exposure to companies reliant on industrial coal power plants and the full extent of the climate-related transition plan posed by this exposure. This is the second complaint by Market Forces following its prior complaint to SGX in 2023 against a power generation company for not fully disclosing risks related to its US$300 million bond issue on SGX in 2022. Neither of these complaints filed with the SGX has thus far resulted in any formal public response or enforcement action from the regulators.  

The Competition and Consumer Commission of Singapore (CCS) has published a Guide on Quality-related Claims to provide clarity to businesses when making claims on the qualities, uses or benefits associated with their products of business that could amount to unfair practices under the Consumer Protection (Fair Trading) Act 2003 (CPFTA), including environmental-related claims.

There is no specific law that is aimed at greenwashing in Singapore, but there are various laws and regulations that can be applied to address greenwashing:

Misrepresentation

Companies engaged in greenwashing may be liable for fraudulent or negligent misrepresentation and be liable for damages under section 2(1) of the Misrepresentation Act 1967 should civil proceedings be commenced against them.

Consumer protection

Greenwashing in respect of consumer transactions can contravene section 4 of the CPFTA as an “unfair practice”. Consumers have the right to obtain redress against the company for engaging in an unfair practice through the Consumers Association of Singapore (CASE) and may be able to claim damages for losses due to the greenwashing or obtain an injunction from the court to restrain the business from continuing to engage in the said unfair practice.

Securities laws and regulations

Amongst other provisions, section 199 of the Securities and Futures Act 2001 provides that persons must not make statements that are false or misleading and that are likely to induce other persons to subscribe for, induce the sale or purchase of, or have the effect of raising, lowering, maintaining or stabilising the market price of securities without care as to the truth of the statement, or with actual or constructive knowledge that the statements are false or misleading.

Directors’ duties

Greenwashing can expose directors to a breach of directors’ duties under common law or the Companies Act 1967. Under section 157 of the Companies Act 1967, directors are under a duty to act honestly and use reasonable diligence in the discharge of their duties, which may be breached if the company is found to have engaged in greenwashing and in breach of relevant laws.

Advertising standards

The abovementioned SCAP requires all advertisements to be legal, decent, honest, and truthful. Although this is not legally enforceable, it may be used by ASAS against unsubstantiated environmental product claims.

CCS has also issued non-binding advice to suppliers to:

1. be specific in their environmental claims and to present any qualifying or supporting information accurately and clearly alongside such claims;
2. avoid making claims that would imply or convey an overall impression that the environmental benefit of the product is more than it is; and
3. ensure that all environmental claims can be substantiated with valid and credible evidence.

CCS and CASE have developed a set of tips to raise awareness among consumers of greenwashing and other false environmental claims when buying products.

Separately, MAS published an information paper on Good Disclosure Practices for Retail ESG Funds on 4 December 2024 and updated it on 10 June 2026.

Please see the response in section C.2 above.

There are also risks of regulatory enforcement pursuant to, for example, codes or guidance issued by financial regulators on the marketing of financial products and SGX Rulebooks.

Separately, CCS has released a Guidance Note on Business Collaborations Pursuing Environmental Sustainability Objectives which clarifies that certain agreements pursuing collaboration on environmental sustainability objectives may be found to be anti-competitive and hence prohibited under the Competition Act 2004, such as those involving market-sharing or imposing output limitations. CCS has adopted a streamlined two-phase approach to assess and identify such agreements.

The risk of greenwashing litigation against companies (in particular, listed companies) is expected to grow as reporting requirements become more robust and various stakeholders become more proactive in combatting potential greenwashing, including through litigation. Beyond greenwashing considerations, Singapore’s regulatory approach is moving towards greater corporate accountability for sustainability-related governance and risk management, with increasing scrutiny on the credibility of sustainability strategies, targets and disclosures.