Overview NSRF
Introduced: September 24, 2024 (final framework issued)
Effective from: FY 2025 (climate-first reporting phase begins)
Last modified: October 21, 2024 (public response paper)
Region(s): Malaysia
About NSRF
Malaysia’s National Sustainability Reporting Framework (NSRF) lays the groundwork for mandatory ESG disclosure across capital markets, transitioning the country from voluntary TCFD adoption to full compliance with IFRS S1 (General Disclosures) and IFRS S2 (Climate Disclosures).
Spearheaded by the Securities Commission Malaysia, the NSRF introduces a phased and proportionate approach to climate and ESG transparency, reinforced by national capacity-building initiatives like the PACE Hub.
The framework begins with climate-related disclosure for the largest issuers and eventually scales to include general ESG data and Scope 3 emissions, with assurance requirements on the horizon post-2027.
Criteria for compliance
Group 1
Main-Market issuers with market capitalization ≥ RM 2 billion.
- FY 2025: IFRS S2 compliance begins
- FY 2026: IFRS S1 compliance begins
- FY 2027: Scope 3 and full ESG disclosures due
Group 2
All remaining Main-Market issuers.
- FY 2026: IFRS S2 compliance begins
- FY 2027: IFRS S1 compliance begins
- FY 2028: Scope 3 and full ESG disclosures due
Group 3
ACE-Market issuers and large non-listed companies (≥ RM 2 billion annual revenue).
- FY 2027: IFRS S2 compliance begins
- FY 2028: IFRS S1 compliance begins
- FY 2030: Scope 3 and full ESG disclosures due
Compliance timelines
FY 2025
Group 1 begins mandatory climate reporting under IFRS S2.
FY 2026
Group 2 climate reporting; Group 1 adds general ESG (IFRS S1).
FY 2027
Group 3 begins climate reporting; Group 2 adds ESG; Group 1 must include Scope 3.
FY 2028
Group 3 adds ESG; Group 2 must include Scope 3.
FY 2030
Group 3 must report full-scope ESG and Scope 3 emissions.
Post-2027
Mandatory assurance requirements under review.
Disclosure requirements
- Scope 1 and 2 emissions required from the start; Scope 3 phased by entity group
- IFRS S1 ESG disclosures begin in second reporting year, covering additional material topics such as labor, biodiversity, and supply chain risks
- IFRS S2-aligned climate disclosures: Governance, strategy (including scenario analysis), risk management, metrics, targets
- Reports must be filed in XBRL format via Bursa Malaysia or the Companies Commission (SSM) portal
Key obligations
- Include NSRF disclosures in annual reports
- Submit filings via approved digital platforms
- Maintain audit-ready documentation for emissions and scenario planning
- Obtain board-level signoff
- Prepare for limited assurance requirements within two cycles of first reporting year
Third-party assurance
Assurance is not required initially. However, limited assurance on key metrics is expected within two reporting cycles for each group, with Group 1 potentially facing assurance as early as FY 2027.
Penalties for non-compliance
Failure to comply may result in:
- Fines and administrative action under Bursa Malaysia Listing Requirements
- Public reprimands or delisting risks
- Enforcement under the Companies Act for private entities
- Reputational harm and investor confidence impacts
