If your company is listed on Bursa Malaysia’s Main Market, 2026 is the year your sustainability report moves to the ISSB Standards. The Securities Commission Malaysia (SC) set this date in the National Sustainability Reporting Framework (NSRF). Its media release, published 24 September 2024, says the largest issuers start in 2025 (Group 1). It goes on: "This will extend to other Main Market listed issuers in 2026 (Group 2)".
Your 2026 figures are being made right now. The report that explains them comes out in your next annual report. This guide is a plan to get from here to there.
> Key points
> – Group 2 covers every Main Market company outside Group 1. Its first ISSB year is 2026.
> – Most of the work is data and decisions. Writing and design come last.
> – Plan backwards from the date your annual report must reach shareholders.
> – Keep clean records now. The SC aims to require reasonable assurance from 2027.
What changes for a Group 2 sustainability report
Main Market companies already publish a sustainability statement. What changes is the standard behind it. The NSRF uses the IFRS Sustainability Disclosure Standards from the International Sustainability Standards Board (ISSB) as the baseline. The Malaysian government copy of the announcement also states.
The climate part follows four areas. The SC release names them: governance, strategy, risk management, and metrics and targets. Listed companies know these from the TCFD rules already in the Bursa Listing Requirements. So you are not starting from zero.
The bigger change is how firm the numbers must be. The release says the advisory committee "aims to mandate reasonable assurance of sustainability information commencing in 2027". That is still subject to more consultation. Reasonable assurance means an outside party checks your figures, much like an auditor checks your accounts. A report you build for 2026 should be ready for that kind of check.
Not sure which group you are in? Our guide to whether ESG reporting is compulsory in Malaysia sets out all three groups.
A planning timeline that works back from your annual report
The dates below assume a December year end. Shift each step if your year ends in another month. The order matters more than the exact weeks.
Now to December: name an owner and fix the data
- Pick one owner. One person or committee signs off every number. Without one, drafts stall in review.
- List your data sources: electricity bills, fuel records, company vehicles, generators, water and waste. These feed your Scope 1 and Scope 2 emissions.
- Check for gaps. If a branch has no meter reading for some months, fix the process now. You cannot rebuild missing months later.
- Ask your auditor which records they would want to see. Keeping a receipt today is easier than finding it next year.
January and February: close the year’s numbers
- Collect 12 months of data from every site.
- Calculate your emissions and other metrics. Keep the workings in one file.
- Get the owner to approve the figures before anyone writes about them.
February and March: write the report
- Write the four sections in plain language. Say who oversees climate risk, what the risks are, how you manage them and which numbers you track.
- Set targets you can explain. A target with a base year and a clear method is easier to defend than a big promise.
- Mark every figure with its source inside the draft, so reviewers can trace it.
March and April: design, review and sign-off
- Lay out the pages inside the annual report design, with tables and charts for the main figures.
- Run a full review with finance, legal and the board.
- Leave time for one more round of changes after the board reads it. Late design changes are where dates slip.
What to prepare before writing starts
A writer or designer cannot fix missing inputs. Have these ready before the first draft:
- A one-page summary of the business: sites, staff numbers, main products and main customers.
- A list of climate risks and opportunities, such as floods, heat, energy prices and new customer demands.
- Board papers or minutes that show how often climate topics come up, and who decides.
- A data file with every metric, its unit, its period and its source.
- Last year’s sustainability statement, so you can show what changed.
Scope 3 refers to value chain emissions, and it is often the hardest part. These come from suppliers, transport and how customers use your products. Bursa Malaysia’s media release of 23 December 2024 gives Main Market companies a climate-first relief for 2 full financial years. During that time they may report on climate topics only and leave out Scope 3, unless another regulator requires it. The relief ends, so start asking key suppliers for data now.
Planning the sustainability report’s design early
Many companies leave layout to the last month. That is a common reason a first report looks rushed. The sustainability section sits inside the same annual report your investors read. It has to match the rest in style and quality.
Decide these four things while you plan:
- How many pages the sustainability section will take.
- Which figures get a chart and which go in a table.
- How you will show change over time, even in the first year.
- Where the four sections sit, so readers can find governance or targets quickly.
Our guide on how to design an ESG report that investors will read covers layout and charts in detail. If you are still deciding whether to publish a separate document, see Annual Report vs Sustainability Report.
Why first reports run late
Five problems come up again and again:
- Nobody owns the data, so each department waits for another.
- Data arrives as scanned bills, spreadsheets and emails, and nobody joins it up.
- Targets are agreed late, and the strategy section has to be rewritten.
- Design starts after the text is final, leaving no time for charts and checks.
- Figures cannot be traced back to a bill or meter reading, which will fail an assurance check.
All five are planning problems, and each costs less to fix in November than in March.
Once the data is closed and the four sections are drafted, the work left is turning them into pages an investor can scan in a few minutes. That covers the chart style for your emissions table, the page order and the print and PDF files, and it is what the QC Fixer annual report design team does.
Frequently asked questions
Which companies are in Group 2 of the NSRF?
Every Main Market listed company that is not in Group 1. Group 1 is Main Market companies with a market value of RM2 billion and above. They started in 2025.
Do ACE Market companies need to report in 2026?
No. The SC release puts ACE Market companies and large non-listed companies in Group 3, which starts in 2027.
How long does a first sustainability report take to prepare?
Plan for several months. Data collection takes the longest. For a December year end, start fixing data sources in the last quarter of the year you report on.
Will an auditor check our sustainability figures?
Not yet as a rule. The advisory committee aims to require reasonable assurance from 2027, subject to further consultation. Keep records as if a check is coming.
Can the sustainability report be a separate document?
Listed companies publish a sustainability statement in the annual report. Some also release a standalone version for investors and customers. Either way, the figures in both must match.
