Does NSRF apply to your company?
Malaysia’s National Sustainability Reporting Framework (NSRF) applies to Main Market listed issuers, ACE Market listed issuers and certain large non-listed companies. Your reporting start date depends on your NSRF reporting group—not on when your organisation considers itself ready.
The NSRF adopts the International Sustainability Standards Board (ISSB) Standards, specifically IFRS S1 and IFRS S2, as Malaysia’s baseline for sustainability-related financial disclosures. The framework is introduced through a phased, climate-first approach to help companies build credible governance, climate-risk assessment, GHG data and reporting controls.
For wider guidance on Malaysia’s changing sustainability disclosure landscape, visit Bernard Business Consulting’s ESG and sustainability insights. The hub includes practical articles on NSRF readiness, IFRS S1, IFRS S2, climate scenario analysis, Scope 1, Scope 2 and Scope 3 emissions, and sustainability assurance preparation.
Takeaways
- NSRF covers Main Market and ACE Market listed issuers, plus large non-listed companies that meet the RM2 billion revenue threshold.
- Group 1 starts reporting for annual periods beginning on or after 1 January 2025; Group 2 starts from 1 January 2026; and Group 3 starts from 1 January 2027.
- IFRS S1 and IFRS S2 apply together from the relevant start date, although eligible entities may use climate-first transition reliefs.
- Transition reliefs reduce the immediate reporting burden, but they do not remove the need for governance, reliable data, documentation and internal controls.
- A readiness diagnostic should cover reporting scope, governance, climate risks and opportunities, GHG data, financial connectivity, evidence and assurance preparation.
Table of Contents
Step 1: Identify your NSRF reporting group
Are you a Main Market listed issuer?
A Main Market issuer is generally in Group 1 if its market capitalisation, excluding treasury shares, is RM2 billion or above as at 31 December 2024. Issuers listed after that date are assessed at the point of listing.
Other Main Market listed issuers are generally in Group 2.
Are you an ACE Market listed issuer?
ACE Market listed issuers are generally in Group 3.
Are you a large non-listed company?
A non-listed company is generally in Group 3 where its consolidated group revenue is RM2 billion or more for the two consecutive financial years preceding the current financial year. Where consolidated financial statements are not required, the assessment may be made using the company’s own revenue.
NSRF group | Applicable entity | Reporting starts for annual periods beginning on or after |
Group 1 | Main Market issuer with market capitalisation of RM2 billion or above | 1 January 2025 |
Group 2 | Other Main Market issuers | 1 January 2026 |
Group 3 | ACE Market issuers and large non-listed companies | 1 January 2027 |
For the official requirements, refer to the Securities Commission Malaysia’s NSRF page and the National Sustainability Reporting Framework.
SMEs and LEAP Market issuers are not currently the main mandatory target entities. However, voluntary alignment can still help companies respond to sustainability-data requests from customers, lenders, investors, multinational parents and supply-chain partners.
Step 2: Understand climate-first reporting
Climate-first reporting does not mean climate will be the only sustainability issue forever. It gives companies time to develop reliable climate-related disclosures before progressing to broader sustainability-related financial disclosures.
During the relevant transition period, eligible entities may focus their disclosure on climate-related risks and opportunities in accordance with IFRS S2 and related IFRS S1 requirements. Companies should use this period to strengthen climate governance, risk management, GHG accounting, financial-impact assessment and reporting controls.
Group | Climate-first transition period | Full IFRS S1 and IFRS S2 reporting, including Scope 3 |
Group 1 | First two reporting periods | 2027 |
Group 2 | First two reporting periods | 2028 |
Group 3 | First three reporting periods | 2030 |
For example, a Group 1 company with a 31 December financial year end begins NSRF reporting for FY2025. It may use the climate-first relief for FY2025 and FY2026, but should prepare for full sustainability-related reporting and Scope 3 GHG emissions disclosure from FY2027.
To prepare for this transition, read our guidance on GHG Scope 1, Scope 2 and Scope 3 emissions and climate scenario analysis under IFRS S2. These are particularly relevant for organisations establishing their emissions inventory and assessing physical and transition climate risks.
Step 3: Build an NSRF readiness roadmap
A credible NSRF implementation plan should not begin only when the reporting deadline approaches. Start with a structured readiness assessment that identifies capability gaps and assigns clear accountability.
- Confirm the reporting boundary: Identify relevant legal entities, operations, joint ventures, business segments and value-chain activities.
- Establish governance: Document board oversight, management accountability, decision-making processes and escalation routes.
- Assess climate risks and opportunities: Evaluate how physical and transition risks could affect strategy, operations, financial performance, cash flows and access to capital.
- Create a controlled data register: Set clear owners, methodologies, evidence requirements and review controls for GHG, energy, operational and financial information.
- Prepare Scope 1 and Scope 2 data early: Build an auditable emissions inventory supported by documented boundaries, activity data and emission factors.
- Map Scope 3 data gaps: Identify material categories, supplier-data requirements, calculation approaches and improvement opportunities even where Scope 3 disclosure is deferred.
- Record transition reliefs used: Document the relief applied, the reason it is available and the plan to close the related reporting gap.
- Prepare for assurance: Develop evidence trails, control procedures and management-review processes that can support future verification and assurance.
For a practical starting point, explore Bernard Business Consulting’s articles on
What should your company do next?
If your company falls within the NSRF scope, do not treat transition reliefs as a reason to delay. Use the climate-first period to build the foundations for reliable reporting: board-level oversight, defined reporting boundaries, robust GHG methodologies, climate-risk assessment, financial connectivity and auditable evidence.
Need to confirm whether NSRF applies to your organisation? Contact Bernard Business Consulting to assess your reporting group, evaluate transition reliefs, identify data and disclosure gaps, and develop a practical implementation roadmap.
Frequently asked questions
Does NSRF apply to private companies in Malaysia?
NSRF applies to large non-listed companies with consolidated group revenue of RM2 billion or more for two consecutive financial years preceding the current financial year.
When does NSRF reporting start?
NSRF begins for annual reporting periods beginning on or after 1 January 2025 for Group 1, 1 January 2026 for Group 2 and 1 January 2027 for Group 3.
Does NSRF require IFRS S1 and IFRS S2?
Yes. The NSRF uses IFRS S1 and IFRS S2 as its baseline standards. Eligible companies may apply climate-first transition reliefs for a limited period.
When is Scope 3 reporting required under NSRF?
Scope 3 GHG emissions disclosure is expected from 2027 for Group 1, 2028 for Group 2 and 2030 for Group 3, following the applicable transition relief periods.
Can a subsidiary use its parent company’s sustainability report?
A large non-listed company may be able to rely on or leverage its holding company’s sustainability disclosures in certain circumstances. The company should carefully assess eligibility, reporting coverage and applicable exemption conditions before doing so.
eBook
The C-Suite Guide to Malaysia’s National Sustainability Reporting Framework (NSRF)
Developed by BBC’s ESG and sustainability consultants, this practical roadmap guide helps leaders understand, plan and apply the NSRF effectively. It provides a clear roadmap to strengthen governance, enhance reporting and create business value.