Yes, for a growing list of companies. Under Malaysia’s National Sustainability Reporting Framework (NSRF), companies listed on Bursa Malaysia’s Main Market and ACE Market, and non-listed companies with annual revenue of RM2 billion and above, will report using the ISSB sustainability standards. The rule arrives in three phases from 2025 to 2027. If your company is not listed on those markets and its annual revenue is below RM2 billion, the NSRF does not require you to report, but your customers may still ask.
This guide explains which group you fall into, when your first report is due, and what that first report has to include.
What the NSRF is
The NSRF was announced in Kuala Lumpur on 24 September 2024. It was developed by the Advisory Committee on Sustainability Reporting (ACSR), a group that includes the Securities Commission Malaysia, Bank Negara Malaysia, the Companies Commission of Malaysia (SSM) and Bursa Malaysia.
The framework adopts two global standards from the International Sustainability Standards Board (ISSB):
- IFRS S1, which covers general sustainability-related financial information
- IFRS S2, which covers climate-related disclosures
In simple terms, the NSRF tells companies to report sustainability information in the same format used by investors around the world, so the numbers can be compared.
Which group is your company in?
The official announcement sets out three groups.
| Group | Who is in it | Reporting starts |
|---|---|---|
| Group 1 | Main Market listed companies with market capitalisation of RM2 billion and above | Annual periods from 2025 |
| Group 2 | All other Main Market listed companies | Annual periods from 2026 |
| Group 3 | ACE Market listed companies, and large non-listed companies with annual revenue of RM2 billion and above | Annual periods from 2027 |
“Annual periods from 2025” means financial years that begin on or after 1 January 2025. A company with a December year end in Group 1 reports on the year from January to December 2025.
If your company is not on this table, the NSRF does not require you to publish a report today. That does not mean the topic can be ignored, as the next section shows.
Why smaller suppliers are being asked anyway
A listed company that reports under IFRS S2 has to describe climate risk across its business. For many companies, a large part of that risk sits with suppliers. So procurement teams are starting to send questionnaires to their vendors asking about energy use, emissions and sustainability policies.
This is why many SMEs meet ESG reporting through a tender form or a supplier audit, long before any law applies to them. A short, honest sustainability statement can help you answer these requests quickly and look prepared when you bid for work.
What the first report has to cover
The NSRF starts with climate. According to the Securities Commission’s NSRF page, its transition reliefs include focusing on climate-related disclosures first and allowing additional time for more complex reporting, such as Scope 3 emissions (indirect emissions across the wider value chain, from suppliers to customers’ use of your products). The exact relief periods differ by group, so check the SC’s guidance for yours.
The climate disclosures follow four areas, which listed companies already know from the TCFD recommendations:
- Governance: who in the company oversees climate risk, and how often the board discusses it
- Strategy: which climate risks and opportunities affect the business, and over what time frame
- Risk management: how the company finds, assesses and manages those risks
- Metrics and targets: the numbers used to track progress, such as Scope 1 and Scope 2 emissions
Assurance is coming later. The ACSR aims to require reasonable assurance of sustainability information from 2027, subject to further consultation. Reasonable assurance means an independent party checks the figures, much like an auditor checks financial statements. It is sensible to keep clean records of energy bills and fuel use from now on.
Where the report sits
Bursa-listed companies already publish a sustainability statement in their annual report, and NSRF reporting builds on that. Large non-listed companies do not publish annual reports in the same way, so they should follow SC and SSM guidance on how and where to file.
Because the statement goes into the annual report, the design of the two documents is now linked. Charts for emissions, tables for targets and clear section headings all need to work inside the same document your shareholders already read. We explain the difference between the two documents in Annual Report vs Sustainability Report.
A simple checklist to prepare
Whether your first report is due next year or your customers are simply asking questions, these steps help:
- Confirm your group. Check your market and your market capitalisation or revenue against the table above.
- Name an owner. Pick one person or committee who is responsible for sustainability data.
- Collect 12 months of data. Electricity bills, fuel use, company vehicles and any generators are the starting point for Scope 1 and Scope 2 emissions.
- List your climate risks. Floods, heat, rising energy costs and changing customer demand are common ones in Malaysia.
- Plan the document early. Decide how the sustainability section will look inside your annual report, including charts and tables, before the data arrives.
Our annual report design team can help you lay out the sustainability statement so readers can find the figures they need.
Frequently Asked Questions
Is ESG reporting compulsory for SMEs in Malaysia?
Not under the NSRF today. The framework covers Main Market and ACE Market listed companies and non-listed companies with annual revenue of RM2 billion and above. Many SMEs are still asked for ESG information by larger customers during tenders or supplier checks.
When does Group 3 start reporting under the NSRF?
Group 3, which includes ACE Market companies and large non-listed companies, starts with annual reporting periods from 2027.
What standards does the NSRF use?
It uses the ISSB standards IFRS S1 and IFRS S2, which cover general sustainability information and climate-related disclosures.
Will sustainability reports need to be audited?
The ACSR aims to require reasonable assurance of sustainability information from 2027, subject to further consultation. This means an independent party would check the reported figures.
Is a sustainability report part of the annual report?
For Bursa-listed companies, yes. The sustainability statement is published in the annual report. Large non-listed companies should follow SC and SSM guidance on how to file.
