Bursa NSRF Group 1: what changes before 1 January 2027

Group 1 has been disclosing climate information under Malaysia's National Sustainability Reporting Framework since 2025. The larger change is closer than it looks: full IFRS S1 and IFRS S2 application lands on 1 January 2027, the start of Group 1's third reporting period. Mandatory reasonable assurance over Scope 1 and Scope 2 emissions no longer starts on that same date: on 17 September 2026 the Securities Commission Malaysia said the requirement had been deferred a year, and it now takes effect for annual reporting periods beginning on or after 1 January 2028.

Updated 30 September 2026: the Securities Commission Malaysia (SC) stated on 17 September 2026 that the Advisory Committee on Sustainability Reporting (ACSR), which it chairs, has deferred the start of mandatory reasonable assurance for Group 1 from 1 January 2027 to 1 January 2028. The full IFRS S1 and IFRS S2 reporting mandate below is unaffected; only the assurance date moved. Detail under "Reasonable assurance, deferred to 2028" below.

Who Group 1 is

Group 1 covers Main Market listed issuers, corporations, REITs and business trusts, with market capitalisation of MYR2 billion or more as at 31 December 2024, or at the date of listing if an issuer listed after that date. It is the largest-capitalisation cohort under the NSRF and the first to reach every phase-in date.

The framework itself was released on 24 September 2024 by the Advisory Committee on Sustainability Reporting, chaired by the Securities Commission Malaysia and including the Audit Oversight Board, Bank Negara Malaysia, Bursa Malaysia, the Companies Commission of Malaysia and the Financial Reporting Foundation. Bursa Malaysia amended its Main Market and ACE Market Listing Requirements on 23 December 2024 to require a sustainability statement prepared in accordance with IFRS S1 and IFRS S2, phased in by group.

Two dates, not one

Every NSRF group carries two dates: a climate-first date, when climate-related disclosure under IFRS S2 begins, and a full-application date, when the full scope of IFRS S1 and IFRS S2 applies. Group 1 reached the first date already. The second is what this page is about.

Group and date structure quoted directly from the IFRS Foundation's jurisdictional profile for Malaysia, updated 12 June 2025, read 2026-09-17. Full detail on all three groups, and on the majors outside Malaysia, is in IFRS S2 adoption by jurisdiction.

For a calendar-year reporter, Group 1 is currently inside its second climate-first year, the period beginning 1 January 2026. The period beginning 1 January 2027, the first year of full application, starts a little over three months after this page was written.

What changes on 1 January 2027

Four things change at once for Group 1, and treating any one of them as the whole of it is the most common way to run out of runway.

The disclosure scope widens. Climate-first lets an entity apply IFRS S1 only insofar as it relates to the climate information required by IFRS S2. From the period beginning 1 January 2027, the full scope of IFRS S1 applies alongside IFRS S2: governance, strategy, risk management and metrics and targets, not narrowed to climate.

Scope 3 becomes part of that scope. The ISSB baseline lets an entity omit Scope 3 GHG emissions in its first year of applying IFRS S2. Malaysia extends that to two annual reporting periods for Group 1. Read together with the dates above, that covers the periods beginning 1 January 2025 and 1 January 2026, meaning Scope 3 becomes part of what Group 1 discloses from the period beginning 1 January 2027, the same period full application begins. That reading is this page working through two separately dated facts, the two-period duration and the full-application date, rather than a single sentence quoted from the source. Treat it as the working assumption, not a separately confirmed deadline.

The principal-business-segments relief narrows to the full entity. Malaysia permits an entity to focus its climate disclosures on its principal business segments, rather than the full reporting entity, for two annual reporting periods for Group 1. By the same arithmetic as above, that relief runs out at the same point: full-entity scope from 1 January 2027. This is a Malaysia-only addition, not present in IFRS S1 or IFRS S2 at all. A full comparison of this and the other Malaysia-specific reliefs is in Malaysia's IFRS S2 transition reliefs.

Comparative information already applies, and did before this date. Malaysia's own list of extensions to the ISSB baseline does not include the comparative-information relief (IFRS S1 paragraph E3, replicated at IFRS S2 paragraph C3). The unextended, one-year ISSB default applied to Group 1's first year of applying IFRS S1, the period beginning 1 January 2025. On that reading, comparative information has applied to Group 1 since the period beginning 1 January 2026, not from 2027. It is the one relief on this list that has already run out.

Reasonable assurance, deferred to 2028

Malaysia has mandated reasonable assurance on Scope 1 and Scope 2 GHG emissions for Group 1. The requirement no longer starts on 1 January 2027, the date full IFRS S1 and IFRS S2 application begins. On 17 September 2026 the Securities Commission Malaysia (SC) issued a media release, ACSR's Mandatory Sustainability Assurance Requirement to Take Effect in 2028, saying that the Advisory Committee on Sustainability Reporting (ACSR), which the SC chairs, has deferred the commencement of mandatory reasonable assurance requirements on Scope 1 and Scope 2 GHG emissions disclosures for Group 1 applicable entities. The requirement now takes effect for annual reporting periods beginning on or after 1 January 2028, instead of 1 January 2027. Mandatory assurance for Group 2 and Group 3 applicable entities is delayed by one year, to 2029 and 2030 respectively. Reasonable assurance is the higher of the two engagement types the applicable global baseline standard, the International Standard on Sustainability Assurance 5000, covers; the exact paragraph-level detail of how ISSA 5000 itself distinguishes limited from reasonable assurance was not independently verified in the regulatory research behind this page.

The SC's stated basis for the deferral is a review by the Minority Shareholders Watch Group and Climate Governance Malaysia of the first cohort of 91 Group 1 listed issuers, which found that further improvements to the quality of disclosures are needed. The release says the additional year aims to support preparers in strengthening reporting processes, controls and data quality ahead of mandatory assurance. It also says any independent assurance must now be performed in accordance with the designated recognised assurance standard, ISSA 5000 only, and that the ACSR will be issuing a Sustainability Assurance Guide. Until mandatory assurance starts, the release says listed issuers continue to be required under the Main Market and ACE Market Listing Requirements to state whether their sustainability disclosures have been subject to internal review by internal auditors or independently assured.

Not everything is decided. The release says the remaining proposals on the assurance framework will be communicated in due course, and the policy document it links to says mandatory assurance for Scope 3 GHG emissions and other sustainability disclosures will be determined and announced at a later stage. The 17 September documents also do not address who may provide the assurance.

ISSA 5000 becomes the reference standard for engagements on periods beginning on or after 15 December 2026, with early application permitted unless a jurisdiction states otherwise. Group 1's first fully-applied period, and now its mandatory assurance start, both fall after that date. In Malaysia, auditors of public interest entities are regulated by the Securities Commission's Audit Oversight Board, established 1 April 2010; whether its remit has been or will be extended to sustainability assurance practitioners specifically is not confirmed in the source read for this page.

The deferral gives Group 1 an extra year against the assurance date specifically, not against full IFRS S1 and IFRS S2 application, which is unchanged. Group 2 and Group 3 follow a year later each, from 1 January 2029 and 1 January 2030, according to the policy document the release links to. The extra year is time to build the controls, and the record of who prepared, reviewed and approved each figure, before an assurance provider tests them. The SC's earlier wording, the interim duty, the standard and the first assured period for each group are set out in why the reasonable assurance date moved to 2028.

Malaysia's reliefs, and where they run out for Group 1

Malaysia both extends and removes pieces of the ISSB's own transition-relief package, and adds one relief of its own. For Group 1 specifically, the picture is:

The "Ends" column for the first three rows is this page's own reading of two dated facts held together, not a separately quoted deadline; see the caveats in the section above. The full detail behind every row, including how the durations differ for Group 2 and Group 3, is in Malaysia's IFRS S2 transition reliefs, sourced to the same regulatory baseline.

Publication timing is worth stating plainly on its own: Malaysia removed the relief that lets an entity publish its sustainability statement after its financial statements. That was never available to Group 1, or to any group, in any year. The sustainability statement publishes alongside the financial statements, from the first cycle.

What to have in place before period start

None of the four changes above are exotic. What tends to catch a Group 1 reporter out is treating them as one project rather than four with different runways.

• The consolidation boundary for the full entity. If disclosure has been scoped to principal business segments, the entities and activities outside that scope need to be brought in before the period beginning 1 January 2027, not during it.
• Scope 3 categories and data sources. If Scope 3 has been omitted under the relief, the category boundary, the data sources and the calculation method need to exist before the figure has to be published, not after.
• Comparative-period data. On the reading in this page, comparative information already applies. If the period beginning 1 January 2026 has not been tracked with that in mind, that gap gets harder to close the longer it is left.
• A methodology that survives comparison. Reasonable assurance, when it applies, tests consistency year over year: the same emission factor source, the same Scope 2 method, the same boundary. A method chosen and recorded once is easier to defend than one reconstructed after the fact.
• A preparer, reviewer and approver record. Reasonable assurance is a materially higher bar than limited assurance. The evidence an assurance provider tests starts with who entered a figure, who reviewed it, and who approved it, captured as it happens rather than reconstructed from an email thread when the engagement begins.

For how Malaysia's reliefs compare to the ISSB baseline in full, including Group 2 and Group 3, see Malaysia's IFRS S2 transition reliefs. For what an assurance provider actually tests once reasonable assurance applies, see what auditors check in a first-cycle IFRS S2 review. Or have a look at the product.

Common questions