No. Bursa Malaysia asks for a Sustainability Statement inside the annual report. A Main Market company meets the rule when its annual report holds that statement, written to IFRS S1 and IFRS S2. A second, separate report is your choice. Some firms publish one as well, to give more detail to readers who want it.
The rule is item 29 in Part A of Appendix 9C of the Main Market Listing Requirements (Chapter 9, updated as at 9 July 2026). Item 29 is part of the list of what an annual report must contain. It asks for a written account of how the company manages its "sustainability-related risks and opportunities". Bursa calls this the Sustainability Statement.
Where the Sustainability Statement must sit
The statement belongs in the annual report. Bursa said so when it changed the rules. Its media release of 23 December 2024 says "a listed issuer must prepare its sustainability statement in the annual report". The same release names the IFRS standards it must follow.
Bursa’s Practice Note 9 (listed as updated as at 31 December 2024) sets out what goes in it. Paragraph 1.2A repeats that a listed issuer "must include in its annual report" this statement. Paragraph 6.1A says it must follow IFRS S1 and IFRS S2. Paragraph 6.2 adds three items:
- Metrics and targets for the last 3 years, phased in for a new metric
- A note on whether the statement was checked by the internal auditor or by an outside assurer, with the scope. If an outside assurer checked it, the findings are shown too
- A summary of the metrics and targets, in a set format
So the required content has one home. A separate report cannot take the place of the statement in the annual report.
Statement only, or a sustainability report as well: the decision table
The choice left is whether to add a second document. The table compares the two options. The first two rows come from the rules. The rest are points to plan around.
| Question | Statement in the annual report only | Statement in the annual report plus a separate sustainability report |
|---|---|---|
| Meets Bursa’s rule? | Yes, if it follows IFRS S1, IFRS S2 and Practice Note 9 | Yes, through the statement in the annual report. The separate report is extra |
| Rules for the separate document | Not applicable | The Listing Requirements we read set no format for a voluntary report |
| Documents to produce | One | Two, which should stay consistent with each other |
| Who reads it | Shareholders and investors reading the annual report | Also customers, suppliers, staff and others who want more detail |
| Room for extra stories | Limited to what fits the annual report | More room for case studies, community work and photos |
| Best for | Companies reporting to the standard in their first years, or with a lean team | Companies with a wider audience asking for more ESG detail |
Who must follow the new statement rules, and when
The new statement rules start in two steps. Bursa’s Practice Note 9A (effective 31 December 2024) sets two groups for the Main Market:
| Group | Who | Applies to the statement in the annual report for |
|---|---|---|
| Group 1 | Market capitalisation of RM2 billion and above as at 31 December 2024, or at listing after that date | Financial years ending on or after 31 December 2025 |
| Group 2 | All other Main Market listed issuers | Financial years ending on or after 31 December 2026 |
For the first 2 full financial years, a company may use some reliefs. It may report on climate risks and opportunities only, under IFRS S2. It may focus on its main business segments. It may also leave out Scope 3 emissions, except where other regulators already ask for them. Our September guide on which companies must report under the NSRF covers the wider framework, including ACE Market and non-listed companies.
What a Group 2 company reports before 2026
A Group 2 company still has rules to follow before its start date. Practice Note 9A, paragraph 4.1, sets the content of its statement in the meantime. That content is in Annexure PN9A-A.
For financial years ending on or after 31 December 2025, the statement follows Part A of that annexure. Part A asks for:
- The governance structure that manages economic, environmental and social risks and opportunities
- The scope of the statement and the basis for it
- The material sustainability matters, how they were found, why they matter and how they are managed
- Indicators with data for the last 3 financial years, and targets if the company set any
- A note on internal audit review or outside assurance
- A summary of the data and targets in a set format
Part B lists nine common matters with set indicators. Examples include anti-corruption, energy use, health and safety, and water. Part B applies to statements for financial years ending on or after 31 December 2024. From the 2025 year, paragraph 4.1(b) names Part A only.
All of this still sits in the annual report. So a Group 2 company can plan its 2025 and 2026 annual reports as one design project. The 2026 statement then adds the IFRS S1 and IFRS S2 content to the same section.
What a separate sustainability report looks like in practice
Bursa Malaysia does both for its own reporting. Its Sustainability Report 2025 describes itself as a "standalone SR" that "complements our Integrated Annual Report (IAR) 2025". The same report says Bursa produced its first ISSB Sustainability Statement in-house. That statement sits in the integrated annual report.
Other listed companies can use the same split. The annual report holds the required statement. The separate report tells the longer story and points back to the statement for the regulated figures.
If you do publish both, plan them together. The metrics, targets and scope should match across the two documents. Readers compare the two. A figure that differs will raise questions. Our planning guide for a 2026 sustainability report sets out when each step should start. Our earlier article on annual reports and sustainability reports explains what each document is for.
How to choose
Start from the rule: the statement goes in the annual report either way. Then ask who else needs to read your sustainability story. If the answer is mainly investors, one well-designed statement in the annual report may be enough. If large customers, lenders or staff want more, a separate sustainability report gives you the space without crowding the annual report.
QC Fixer’s annual report design service can lay out the statement inside your annual report. It can also design a matching separate report if you choose to publish one.
Frequently asked questions
Can a standalone sustainability report replace the statement in the annual report?
No. Item 29 of Appendix 9C and Practice Note 9 place the Sustainability Statement in the annual report. A separate report can add detail but does not take its place.
Which standards must the Sustainability Statement follow?
IFRS S1 and IFRS S2, under paragraph 6.1A of Practice Note 9, with the transition reliefs in Practice Note 9A for the first 2 full financial years.
When does a smaller Main Market company start?
A Group 2 company applies the new rules to the statement for financial years ending on or after 31 December 2026, under Practice Note 9A.
Does the Sustainability Statement need external assurance?
Not in every case. Practice Note 9 asks the company to say whether the statement was checked by its internal auditor or by an outside assurer. If an outside assurer checked it, the findings must be shown.
