Introduction
ESG and sustainability reporting has become a central governance topic for many businesses in Singapore. The article “The Role of the Corporate Secretary in ESG and Sustainability Reporting” explains how the corporate secretary contributes to robust ESG oversight, disclosure and compliance.
Company directors and management increasingly ask how the corporate secretary Singapore role intersects with sustainability obligations, board governance and reporting frameworks. This article outlines practical steps and considerations for companies operating in Singapore.
Who this applies to
- Listed companies required or encouraged to report under SGX guidelines.
- Private companies starting ESG programmes or preparing voluntary disclosures.
- Board members, company secretaries, CFOs and sustainability leads coordinating reporting and compliance.
- SMEs and multinational subsidiaries in Singapore seeking to align with global frameworks such as GRI, TCFD/ISSB.
Key rules and requirements in Singapore
There is not a one-size-fits-all mandatory ESG reporting regime imposed by ACRA for private companies. However, various Singapore-specific requirements and expectations apply and affect disclosure and governance:
- SGX Listing Rules and related sustainability reporting guidance require listed issuers to make appropriate disclosures and board oversight arrangements. Companies listed on SGX should check the SGX Sustainability Reporting Guide.
- Boards remain subject to duties under the Companies Act; directors must consider material risks — including climate and sustainability risks — to the company’s business model and long-term value.
- Frameworks commonly used for disclosures include GRI, TCFD recommendations, SASB and the international ISSB/IFRS Sustainability Disclosure Standards. Choose a framework suited to your stakeholders and operations.
- Data privacy obligations under the PDPA apply when collecting and processing personal data in the course of sustainability reporting (for example, employee demographics).
- Employment-related metrics should be consistent with statutory requirements under the Employment Act, CPF contributions and MOM work pass rules (Employment Pass, S Pass, Work Permit) when reporting workforce matters.
- When ESG claims relate to financial or tax treatment (for example, green incentives or GST treatment for certain transactions), consult IRAS guidance and account for any relevant tax disclosures via IRAS myTax Portal.
Step-by-step process
Corporate secretaries often coordinate ESG reporting rather than produce technical sustainability data themselves. A typical process they facilitate includes:
- Board governance and mandate: Ensure the board sets clear ESG objectives and delegates oversight (a board committee or designated director). Record decisions in board minutes and ensure alignment with the Companies Act duties.
- Materiality assessment: Coordinate cross-functional workshops to identify material ESG topics relevant to the company and stakeholders.
- Policy and control framework: Help formalise ESG policies (environmental, social, governance) and internal controls to ensure data integrity and compliance (including PDPA safeguards).
- Data collection and ownership: Establish data owners across departments (facilities, HR, procurement, finance) and standardise collection templates for emissions, energy use, waste, workforce metrics and supply chain performance.
- Metric selection and alignment: Select reporting metrics and frameworks (e.g. GRI for broad stakeholder reporting, ISSB for investor-focused disclosures) and map metrics to internal systems.
- Assurance and validation: Consider internal or external assurance for key sustainability metrics. Corporate secretaries coordinate engagement with auditors or assurance providers and ensure clear scope and timelines.
- Board review and approval: Arrange board briefings, provide clear board papers and ensure ESG disclosures are approved and accurately reflected in annual reports and other filings where applicable.
- Publication and filing: For listed companies, ensure sustainability reports are published in accordance with SGX and included where required in annual reports. For all companies, maintain records and, where necessary, update disclosures through ACRA BizFile+ or other statutory portals.
- Ongoing monitoring: Set review cycles tied to the company’s Financial Year End and embed ESG into business planning and risk management.
Common mistakes to avoid
- Treating ESG reporting as a marketing exercise rather than a governance and risk management process.
- Failing to secure clear board ownership and documented minutes under Companies Act obligations.
- Relying on inconsistent or unaudited data without clear data governance and PDPA safeguards.
- Neglecting supply chain and procurement risks where upstream emissions or labour practices are material.
- Overlooking statutory HR considerations: ensure CPF contributions, Employment Act compliance and accurate workforce reporting for employees on Employment Pass, S Pass or Work Permit.
Practical examples
Two brief scenarios illustrate the corporate secretary’s role in practice.
Example 1 — Private SME starting ESG reporting
A medium-sized manufacturing company wants to start reporting energy and waste performance. The corporate secretary organises a materiality workshop, documents board approval for the ESG policy, coordinates collection of energy and waste data from operations, and prepares an internal sustainability update for the board. The secretary also advises on PDPA implications when reporting workforce demographics.
Example 2 — Listed company integrating sustainability into annual report
A listed company must align disclosures with SGX expectations. The corporate secretary works with the CFO and sustainability team to map metrics to GRI and ISSB, coordinates external assurance of selected metrics, prepares board papers for approval, and ensures the sustainability section is published alongside the financial statements. Filings are referenced in the company’s ACRA records and SGX announcements where required.
How a corporate secretary can help
The corporate secretary plays a central coordinating and governance role:
- Advising the board on ESG governance, duties under the Companies Act and how to document decisions and approvals.
- Coordinating the materiality process and maintaining records, minutes and board papers.
- Liaising with external advisers, assurance providers and auditors to support credible disclosures.
- Ensuring PDPA compliance when collecting personal data for social metrics and coordinating with HR on CPF and Employment Act matters.
- Helping integrate sustainability reporting into annual governance cycles, Financial Year End timelines and statutory filing processes via ACRA BizFile+ and other portals.
Raffles Corporate Services can assist discreetly with filings, compliance, accounting, tax and payroll support as companies develop and maintain their ESG reporting frameworks.
Frequently Asked Questions
Is ESG reporting mandatory in Singapore?
ESG reporting is mandatory in certain contexts (for example, some SGX-listed issuers face reporting obligations or expectations). For many private companies, ESG reporting remains voluntary but is increasingly expected by investors, customers and lenders. Requirements may evolve, so consult SGX guidance and regulators.
Which reporting frameworks should we use?
Framework selection depends on your stakeholders. GRI is widely used for broad stakeholder reporting, TCFD/ISSB focuses on climate and investor needs, and SASB is sector-specific. A corporate secretary can help map frameworks to stakeholder priorities and regulatory expectations.
Do we need external assurance for ESG data?
External assurance strengthens credibility for material metrics but can be scoped to key indicators. A corporate secretary helps coordinate assurance engagements and records board deliberations on assurance decisions.
How do PDPA and employee rules affect ESG reporting?
When reporting workforce data, ensure personal data handling complies with PDPA. Employment-related disclosures should align with statutory obligations such as CPF contributions and the Employment Act.
Key takeaways
- The corporate secretary is a central coordinator and governance adviser for ESG and sustainability reporting in Singapore.
- Board ownership, documented decisions and alignment with the Companies Act are essential.
- Choose reporting frameworks that match stakeholder needs and consider assurance for material data.
- Observe PDPA, Employment Act and CPF requirements when reporting personnel information.
- Raffles Corporate Services can provide practical support with compliance, filings and back-office functions as part of an ESG reporting programme.
Requirements may change, so always check the latest guidance from ACRA, IRAS or MOM, or consult a professional adviser.
If you would like to find out more about how Raffles Corporate Services can assist with your company’s compliance and corporate secretarial requirements, please get in touch with the team at [email protected].
Yours sincerely,
The editorial team at Raffles Corporate Services
Disclaimer: This does not constitute legal advice. If you require legal advice, please contact a lawyer.