ESG reporting in Malaysia - NSRF and Bursa requirements
Breathe ESG supports all major global reporting frameworks, from IFRS S1 and S2 and Bursa rules to CSRD, GRI and CDP, from one managed dataset.
Last reviewed: 11 November 2026. Sources: Securities Commission Malaysia, NSRF launch (24 September 2024), NSRF summary, assurance timeline update (17 September 2026).
The short answer
Malaysia's National Sustainability Reporting Framework (NSRF) makes the ISSB standards (IFRS S1 and S2) the baseline for sustainability reporting. It is being phased in over three groups, starting with large Main Market companies for reporting periods from 1 January 2025. Mandatory reasonable assurance of Scope 1 and 2 emissions starts from 2028.
Separately, a carbon tax on iron, steel and energy was announced for 2026 but isn't in force yet. More on that below.
Who reports, and from when
| Group | Who | IFRS S1 and S2 from | Reasonable assurance (Scope 1 and 2) |
|---|---|---|---|
| Group 1 | Main Market issuers with market cap of RM2bn or more | 1 Jan 2025 | 2028 |
| Group 2 | All other Main Market issuers | 1 Jan 2026 | 2029 |
| Group 3 | ACE Market issuers, and large non-listed companies with group revenue of RM2bn or more for two consecutive years | 1 Jan 2027 | 2030 |
Example: which group are you in?
A Main Market manufacturer with a RM1.4bn market cap is Group 2, reporting from 1 January 2026. A private plantation group with RM2.3bn revenue in 2024 and 2025 is Group 3, reporting from 1 January 2027. A non-listed group with RM1.8bn revenue isn't in scope today, but watch the SSM proposals below.
Transition reliefs
- Climate first: companies can disclose only climate-related risks and opportunities for two years (Groups 1 and 2) or three years (Group 3).
- Scope 3: companies can leave out Scope 3 emissions for the same period, except categories that other regulators already require.
- Subsidiaries: large non-listed subsidiaries can rely on a holding company's ISSB or ESRS report.
Reliefs buy time, not an exemption. Groups 1 and 2 will need full IFRS S1 and Scope 3 soon after, so start supplier data collection now.
What IFRS S2 asks for
- Governance: who oversees climate risk and how.
- Strategy: material climate risks and opportunities, their financial effects, and resilience under different scenarios.
- Risk management: how climate risk is identified and managed.
- Metrics and targets: Scope 1 and 2 (and Scope 3 after the relief), industry metrics and progress on targets.
Bursa Malaysia requirements
Bursa Malaysia's Listing Requirements adopt IFRS S1 and S2 on the same timeline. Its Sustainability Reporting Guide (3rd edition) also sets common sustainability matters with indicators, disclosed in a prescribed format through the CSI Platform. Check Bursa's current guidance for the exact list.
Carbon pricing: where things stand
- Carbon tax: announced in the 2026 Budget, starting with the iron, steel and energy sectors. In April 2026 the government said the timing was under review (Eco-Business). In June 2026 the Finance Ministry told Parliament the Carbon Tax Bill was in its final drafting stage (New Straits Times). As of this review it isn't in force.
- National Carbon Market Policy: published in April 2026. It sets out how domestic and Article 6 carbon markets will work, with details on credit use still to come.
- Climate Change Bill: expected to set up the monitoring, reporting and verification system that carbon pricing will rely on.
If you're in steel or energy, build facility-level Scope 1 data now. It's the base for the tax, for NSRF reporting and for EU CBAM buyers.
What's being proposed next
The Companies Commission of Malaysia (SSM) has consulted on extending reporting to smaller non-listed companies from 2028 onwards. This is a proposal, not yet law. SMEs in supply chains are already getting data requests from listed customers, and Capital Markets Malaysia's Simplified ESG Disclosure Guide gives them a starting format.
Checklist
- Work out your group: Main Market by market cap, ACE Market, or non-listed by revenue.
- Build complete, traceable Scope 1 and 2 data now. Reasonable assurance follows within three years.
- Use the climate-first relief to get IFRS S2 right before expanding to IFRS S1.
- Plan Scope 3 for when your relief ends.
- If you're a subsidiary of a foreign group, check whether you can rely on the parent's report.
- Steel and energy companies: track the Carbon Tax Bill.
How Breathe ESG helps
Breathe ESG calculates Scope 1, 2 and 3 emissions with an audit trail back to source data and maps one dataset to IFRS S1 and S2, Bursa indicators and buyer requests.
- People: ESG consulting and fractional CSOs for first-year reports.
- Training: Breathe Academy.
- Community: Breathe Zero, a network of ESG professionals.
FAQs
Is ESG reporting mandatory in Malaysia?
Yes for listed companies, under Bursa rules and the NSRF. Large non-listed companies with RM2bn+ revenue join from 2027.
When does Malaysia require IFRS S1 and S2?
From 2025 for Group 1, 2026 for Group 2 and 2027 for Group 3.
Is Scope 3 mandatory in Malaysia?
Not during the transition relief period: two years for Groups 1 and 2, three years for Group 3. After that, yes.
Does Malaysia have a carbon tax?
Not yet. It was announced for 2026 for iron, steel and energy, but the bill was still being drafted as of mid-2026.
What assurance is required?
Reasonable assurance of Scope 1 and 2, from 2028 for Group 1, 2029 for Group 2 and 2030 for Group 3.
Related: ESG and carbon reporting in Southeast Asia · Singapore mandatory climate reporting · ISSB standards · CBAM-ready emissions tools