Bursa Sustainability Statement Checklist

Since Bursa Malaysia amended its listing requirements to align with the National Sustainability Reporting Framework (NSRF), the sustainability statement in your annual report is built on the IFRS Sustainability Disclosure Standards (IFRS S1 and IFRS S2). For many Main Market companies, financial year 2026 is the first year these rules apply.

This checklist walks through what your sustainability statement needs to cover, so your team can spot gaps early instead of in the final weeks before the annual report goes to print. If your internal team requires hands-on assistance with data collection or drafting, you can explore our professional sustainability report writing service in Malaysia for end-to-end guidance.

Who needs to comply, and when?

The NSRF is being rolled out in phases:

• Group 1: Main Market companies with market capitalisation of RM2 billion or more, for financial years starting 1 January 2025.
• Group 2: All other Main Market companies, for financial years starting 1 January 2026.
• ACE Market companies and large non-listed companies (annual revenue of RM2 billion or more), from 1 January 2027.

Transition reliefs are available. Main Market companies may take a “climate-first” approach for their first two financial years, focusing on climate-related disclosures before full IFRS S1 reporting. ACE Market companies get three years. Scope 3 emissions reporting is also deferred, so check the relief timeline that applies to your group.

The Bursa Sustainability Statement Checklist

1. Governance and Oversight

• [ ] The board has approved the sustainability statement.
• [ ] The statement explains how the board oversees sustainability and climate-related risks and opportunities.
• [ ] The roles of management and any sustainability committee are clearly described.

2. Scope and Basis of Reporting

• [ ] The reporting period matches your financial statements.
• [ ] The reporting entity (group boundary) is the same as in your financial statements.
• [ ] The statement says whether it is prepared under IFRS S1 and S2 in full, or using the climate-first transition relief.

3. Material Sustainability Matters

• [ ] Your materiality assessment is documented: how matters were identified, who was consulted, and how they were prioritised.
• [ ] Material matters are linked to their potential effect on the company’s financial position, performance or prospects, not just listed as topics.
• [ ] You have checked Bursa’s latest guidance on prescribed sustainability matters, as the earlier common sustainability matters have been revised under the new framework.

4. Climate-Related Disclosures (IFRS S2)

• [ ] Governance: Who oversees climate risks and how often they are reviewed.
• [ ] Strategy: The climate-related risks and opportunities that could affect the business, and any transition plan.
• [ ] Risk management: How climate risks are identified, assessed and managed.
• [ ] Metrics and targets: The measures you track and the targets you have set.

5. Greenhouse Gas (GHG) Emissions

• [ ] Scope 1 (direct) and Scope 2 (purchased electricity) emissions are calculated with a documented method, such as the GHG Protocol.
• [ ] Emission factors, organisational boundaries and data sources are recorded so the figures can be checked later.
• [ ] You know when Scope 3 (value chain) emissions become mandatory for your group, and supplier data collection has started.

6. Performance Data and Targets

• [ ] Key data is presented with prior-year comparisons where available.
• [ ] Targets are stated, along with progress made during the year.
• [ ] Figures are consistent between the sustainability statement and the rest of the annual report.

7. Assurance Statement

• [ ] The statement says whether it has been internally reviewed by your internal auditor or independently assured under a recognised assurance standard.
• [ ] If assured, the scope (which matters were covered) and the conclusions are disclosed.
• [ ] You have a plan for future assurance. Regulators are moving towards reasonable assurance of Scope 1 and 2 emissions, so building reliable data systems now saves cost later.

8. Publication and Submission

• [ ] The sustainability statement is included in the annual report and published together with the financial statements.
• [ ] Required data has been submitted through Bursa’s designated platform in the prescribed format.

Common Mistakes to Avoid

• Listing topics without explaining their impact: Under IFRS S1 and S2, investors want to know how sustainability matters affect the business financially.
• Mismatched boundaries: If your emissions data covers fewer subsidiaries than your financial statements, say so clearly, or fix it.
• Starting data collection too late: Energy, fuel, and electricity records are much easier to collect monthly than to reconstruct at year-end.
• Reusing last year’s statement: The NSRF changes are significant. A copy-and-update approach often leaves critical gaps.

Frequently Asked Questions

Who must prepare a sustainability statement under Bursa’s rules?
All Main Market and ACE Market listed companies must include a sustainability statement in their annual report. Under the NSRF, it is prepared using IFRS S1 and S2, phased in from 2025 for large Main Market companies, 2026 for other Main Market companies, and 2027 for ACE Market companies.

Is external assurance mandatory?
Not yet. Companies must state whether their sustainability statement was internally reviewed by the internal auditor or independently assured, and disclose the conclusions if it was assured. Regulators have proposed reasonable assurance of Scope 1 and 2 emissions in future, subject to further consultation.

What is the climate-first transition relief?
Main Market companies may focus on climate-related disclosures under IFRS S2 for their first two financial years before full IFRS S1 reporting. ACE Market companies get three years.