Contents
- The short answer
- What changed, and why most guides are now wrong
- The state of play in August 2026
- The EU: who is still in scope after Omnibus I
- Singapore: the timeline that actually applies
- The United States: one deadline, moved three times
- ISSB and GRI: the two that matter when no regulator names one
- If no regime binds you, your customers will
- What to stop, what to keep, what to start
- Where MASSIVUE fits
- Frequently asked questions
- Sources
For CFOs, heads of sustainability, company secretaries and the finance teams who have been asked to confirm what the company is actually obliged to publish. The answer changed twice in eighteen months, and it is now narrower than almost every published guide says. Current as at 20 August 2026. Reading time about 12 minutes.
The short answer
Four tests decide it, and you should apply all four because more than one can bind you at once.
- EU. You are in CSRD scope only if you have more than 1,000 employees and more than EUR 450 million net turnover. First reporting is for financial years beginning on or after 1 January 2027, using the revised ESRS published in July 2026.
- Singapore. If you are listed on SGX you already report Scope 1 and 2 emissions for FY2025. Everything else was pushed back, in some cases by five years.
- United States. If you have more than USD 1 billion revenue and do business in California, SB 253 applies. The first deadline is now 10 November 2026, having moved three times.
- None of the above. No regulator requires a report from you. Your customers, lenders and exchange still will, and since July 2026 EU law caps how much they can demand from smaller suppliers.
The practical consequence is that the compliance question and the data question have come apart. Far fewer companies now have a legal reporting obligation. Almost none have less demand for sustainability data, because the companies that are still in scope need it from everyone they buy from.
What changed, and why most guides are now wrong
If you are working from anything written before 2026, three things in it are likely to be wrong.
The EU reversed course. Directive (EU) 2026/470, the Omnibus I directive, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. It raised the CSRD threshold from 250 employees and EUR 50 million turnover to more than 1,000 employees and more than EUR 450 million turnover, removed listed SMEs from scope entirely, and deleted the requirement to produce sector-specific standards.
Three of the six things commonly listed as "standards" are no longer separate standards. This is the most common error in circulation, and it predates the Omnibus.
- TCFD no longer exists. The Financial Stability Board declared its work complete in July 2023 and the task force disbanded in October 2023. Its recommendations are fully incorporated into IFRS S2, and the FSB asked the IFRS Foundation to take over monitoring company climate disclosure from 2024. Reporting "to TCFD" in 2026 means reporting to IFRS S2.
- SASB is not an independent standard-setter. SASB merged with the International Integrated Reporting Council to form the Value Reporting Foundation, which was consolidated into the IFRS Foundation in 2022. The ISSB has maintained the SASB Standards since August 2022. They remain useful and are referenced as guidance under IFRS S1, but they are ISSB material now.
- CDP is a disclosure platform, not a reporting standard. It is where you submit environmental data, not a set of standards you report against. Its corporate questionnaire has been aligned with IFRS S2 since 2024, and more than 22,100 companies disclosed through it in 2025.
Singapore moved its dates. On 25 August 2025, ACRA and SGX RegCo extended most of the climate reporting timeline, citing the uncertain global economic landscape and the readiness of smaller issuers. Some obligations moved by two years, others by five.
The state of play in August 2026
| Regime | Who it binds | From when | Status |
|---|---|---|---|
| CSRD and ESRS (EU) | More than 1,000 employees and more than EUR 450m net turnover | Financial years beginning on or after 1 January 2027 | In force. Revised ESRS published 3 July 2026. |
| CSDDD (EU due diligence) | More than 5,000 employees and more than EUR 1.5bn net worldwide turnover | Applies from 26 July 2029 | In force. Transposition due 26 July 2028. |
| SGX climate rules (Singapore) | All SGX-listed issuers, phased by index and market capitalisation | Scope 1 and 2 from FY2025; other disclosures FY2025 to FY2030 | In force, timeline extended August 2025. |
| SB 253 (California) | More than USD 1bn revenue, doing business in California | First Scope 1 and 2 report due 10 November 2026 | In force. Deadline moved three times. |
| SB 261 (California) | More than USD 500m revenue, doing business in California | Statutory date was 1 January 2026 | Enforcement stayed pending Ninth Circuit appeal. |
| IFRS S1 and S2 (ISSB) | Whoever a jurisdiction or investor requires | Varies by jurisdiction | 28 jurisdictions adopting as at April 2026. |
| GRI Standards | Voluntary, impact-focused | GRI 102 and 103 effective 1 January 2027 | Voluntary. New climate and energy standards issued 2025. |
| Voluntary Standard (VSME) | SMEs in the value chain of in-scope companies | Delegated act adopted 3 July 2026 | Voluntary to use, binding as a limit on what may be asked. |
The EU: who is still in scope after Omnibus I
Only large undertakings with more than 1,000 employees and net turnover above EUR 450 million are required to report. Both tests must be met. Listed SMEs, which the original CSRD would have captured, are now fully exempt.
Non-EU parent companies are caught on a separate test: EUR 450 million net turnover generated in the EU in each of the last two consecutive years, together with an EU subsidiary or branch above a turnover threshold of its own. If you are a Singapore or US group with substantial European revenue, that is the test to run, not the employee count.
Three consequences follow that are easy to miss.
The first reporting year is later than most plans assume. The revised scope applies to financial years beginning on or after 1 January 2027, so the first reports under the new regime land in 2028. Member states have twelve months from entry into force to transpose. Member states may also exempt companies that fall below the new thresholds from reporting for financial years starting between 1 January 2025 and 31 December 2026, which is the mechanism that releases companies who had already started.
The standards themselves shrank. The European Commission published the delegated act containing the revised ESRS on 3 July 2026, following EFRAG technical advice delivered in December 2025. Mandatory datapoints fell by 61 percent. Because the voluntary datapoints were removed as well, the total number of datapoints in the standards fell by roughly 70 percent. The revised standards apply to financial years beginning on or after 1 January 2027, with early application permitted for financial year 2026 once the act is in force.
Assurance did not escalate. The obligation stays at limited assurance rather than moving to reasonable assurance, with assurance standards to be adopted by 1 July 2027. If you built a plan around a future reasonable assurance requirement, that plan can be relaxed.
Singapore: the timeline that actually applies
Singapore took a climate-first, ISSB-informed route rather than adopting IFRS S1 and S2 directly into law. The requirements sit in the SGX listing rules and in the ACRA regime for large non-listed companies, and they draw on IFRS S2. On 25 August 2025 most of the dates were extended.
| Who | What | From |
|---|---|---|
| All SGX-listed issuers | Scope 1 and 2 GHG emissions | FY2025 |
| STI constituents | Other ISSB-based climate disclosures | FY2025 |
| STI constituents | Scope 3 GHG emissions | FY2026 |
| Non-STI issuers, market cap S$1bn and above | Other ISSB-based climate disclosures | FY2028 (was FY2025) |
| Non-STI issuers, market cap below S$1bn | Other ISSB-based climate disclosures | FY2030 |
| Large non-listed companies: revenue S$1bn and above and total assets S$500m and above | ISSB-based climate disclosures including Scope 1 and 2 | FY2030 |
| Listed issuers | External limited assurance on Scope 1 and 2 | FY2029 (was FY2027) |
| Large non-listed companies | External limited assurance on Scope 1 and 2 | FY2032 |
Two points matter for planning. Scope 1 and 2 for listed issuers was not deferred, so that obligation is already live for FY2025. And the large non-listed population, which many Singapore groups assumed would be caught in 2027, now has until FY2030, with assurance not required until FY2032. That is a materially different capability build than the one most Singapore boards approved in 2024.
The United States: one deadline, moved three times
There is no federal sustainability reporting mandate in force. California is the operative jurisdiction, and it captures a large number of non-Californian companies because the test is doing business in the state rather than being headquartered there.
SB 253 requires US companies with more than USD 1 billion in annual revenue that do business in California to report Scope 1 and Scope 2 emissions, with Scope 3 anticipated to follow from 2027. CARB adopted its initial implementing regulations on 26 February 2026. The first reporting deadline has now been set three times: staff initially floated 30 June 2026, the adopted regulation set 10 August 2026, and on 24 June 2026 CARB announced a postponement to 10 November 2026. First-year relief is unusually generous. No third-party assurance is required for the first report, CARB has said it will credit good-faith effort, and companies that genuinely were not tracking emissions may file a short explanatory letter rather than a full report.
SB 261 requires companies with more than USD 500 million revenue to publish a biennial climate-related financial risk report. Its statutory deadline was 1 January 2026, but enforcement is stayed under a Ninth Circuit injunction while an appeal proceeds. CARB has said it will set an alternative reporting date once the appeal is resolved.
The planning implication is that California is real but unstable. Build the Scope 1 and 2 inventory, because that requirement has survived every revision. Do not build a fixed calendar around either deadline.
ISSB and GRI: the two that matter when no regulator names one
Once the regulatory tests are answered, the remaining question is which framework to use. In 2026 that is a choice between two, and for many companies the honest answer is both, because they answer different questions.
IFRS S1 and S2 are the investor-facing baseline. They ask how sustainability matters affect the company's own prospects, which is financial materiality. As at 22 April 2026, 28 jurisdictions had adopted the ISSB Standards on a voluntary or mandatory basis, with a further 12 planning to. If a regulator, exchange or major investor asks you to align with a global baseline, this is what they mean. TCFD reporting and SASB industry metrics both live inside this framework now.
GRI is the impact-facing standard. It asks how the company affects the economy, environment and people, which is impact materiality. It remains voluntary everywhere, and it is what most stakeholders other than investors are reading. GRI published new topic standards in 2025, GRI 102: Climate Change and GRI 103: Energy, effective for reports published on or after 1 January 2027 with earlier adoption encouraged. They expand climate reporting well beyond an emissions inventory into transition planning, adaptation, governance and climate-related expenditure.
The two are designed to work together rather than compete. GRI 102 accepts equivalent IFRS S2 disclosures for Scope 1, 2 and 3 emissions provided they follow the GHG Protocol, so a company using both does not calculate its inventory twice. That interoperability is the practical reason the old question of "which framework do we pick" has become less important than it was.
If you want the detail on either, we have separate pieces on the IFRS sustainability taxonomy and on how the GRI Standards are structured.
If no regime binds you, your customers will
This is the part the deregulation coverage mostly missed. Shrinking the reporting population does not shrink the demand for the underlying data, because the companies still in scope have to report on their value chains, and their value chains are full of companies that are now out of scope.
The EU recognised this and did something specific about it. The same delegated act of 3 July 2026 that revised the ESRS also gave binding legal force to the Voluntary Standard for non-listed SMEs, commonly still called VSME. Reporting under it remains voluntary. Its other function is not voluntary at all: it operates as a statutory value chain cap. A company subject to CSRD cannot require a company in its value chain with 1,000 employees or fewer to provide more sustainability information than that standard requires.
So for a mid-sized supplier the position in 2026 is this. No regulator will ask you for a sustainability report. Your largest customers will, your bank may, and if you are listed your exchange probably already has. But there is now a defined ceiling on what an EU customer can demand, and that ceiling is a published standard you can prepare against once rather than answering forty different questionnaires.
MASSIVUE's reading of what this means in practice, which is an editorial judgement rather than a legal one, is that the useful planning unit has shifted from the report to the dataset. A company that can produce a verified Scope 1 and 2 inventory, a basic set of workforce and governance data, and a defensible account of its material impacts can satisfy a customer questionnaire, a bank's onboarding, an exchange rule and a voluntary report from the same source. Building towards a specific report, in a period when the reports keep being redefined, is what has repeatedly proved wasteful.
That bank question has since become a supervised requirement rather than a possibility. The EBA guidelines on managing ESG risks began applying on 11 January 2026, and we set out what lenders can still require from companies outside CSRD scope in Green Finance After the EU Omnibus.
What to stop, what to keep, what to start
Most sustainability programmes in Singapore and Europe were scoped against the 2024 rules. The following is where the work now sits, and it is deliberately as much about stopping as starting.
| Stop | Keep | Start |
|---|---|---|
| Preparing full ESRS datapoint coverage if you are below 1,000 employees or EUR 450m turnover | Scope 1 and 2 emissions measurement, whatever your size | Re-running the scope tests, including the non-EU turnover test, and writing down the answer with its date |
| Building towards sector-specific ESRS, which are no longer required | Double materiality assessment, which still drives ESRS and is useful regardless | Mapping which customer, lender and exchange requests you actually receive, and against which standard |
| Planning for reasonable assurance in the EU, which did not happen | The Singapore Scope 1 and 2 obligation for listed issuers, which was not deferred | Preparing against the Voluntary Standard if you are an SME supplier to EU groups |
| Treating TCFD, SASB and CDP as three separate reporting exercises | The GHG Protocol as the measurement basis under every regime named here | Diarising the ESRS early-application decision for FY2026 and the GRI 102 and 103 change for 2027 |
One caution on stopping. Several of these obligations were deferred rather than removed, and the Singapore and California dates have each moved once already. Deferral is not repeal, and a capability that takes two years to build should not be scheduled to start two years before the deadline.
Where MASSIVUE fits
MASSIVUE is a Singapore-based transformation and capability firm, and sustainability reporting sits inside both our advisory work and MASSIVUE Academy. The relevant help here is usually capability rather than a one-off gap analysis, because the rules have changed three times and will change again.
If your team needs to understand the frameworks properly before choosing between them, the ESG & Sustainability Fundamentals micro-credential covers materiality, the three ESG pillars, greenwashing risk and the major reporting frameworks. If the immediate problem is the emissions inventory and the assurance that now follows it, GHG & Carbon Management Professional covers the full carbon lifecycle from inventory to data quality to assurance. For risk and finance teams who have to get double materiality and climate scenario analysis into an enterprise risk framework with evidence that survives challenge, the Certified ESG Risk Specialist certification is the fuller route.
Related reading on this site: the EU Taxonomy, which is a separate classification system rather than a reporting standard and is often confused with one, and net zero, which is the commitment the emissions data is usually collected to support.
Frequently asked questions
Which sustainability reporting standards apply to my company in 2026?
Run four tests. In the EU, CSRD applies only if you have more than 1,000 employees and more than EUR 450 million net turnover, first reporting for financial years beginning on or after 1 January 2027. In Singapore, SGX-listed issuers report Scope 1 and 2 emissions from FY2025. In the United States, California SB 253 applies above USD 1 billion revenue if you do business in the state, with a first deadline of 10 November 2026. If none of those apply, no regulator requires a report, but customers, lenders and exchanges commonly do.
Is CSRD still happening after the Omnibus?
Yes, for a much smaller group. Directive (EU) 2026/470 entered into force on 18 March 2026 and raised the threshold to more than 1,000 employees and more than EUR 450 million net turnover, removed listed SMEs from scope and deleted the sector-specific standards requirement. Reporting applies to financial years beginning on or after 1 January 2027, so the first reports under the revised regime appear in 2028.
Do I still report against TCFD?
Not as a separate exercise. The Financial Stability Board declared the TCFD's work complete in July 2023 and the task force disbanded in October 2023. Its recommendations are fully incorporated into IFRS S2, and the FSB asked the IFRS Foundation to take over monitoring climate-related disclosure from 2024. A company applying IFRS S2 meets the TCFD recommendations.
What is the difference between ISSB and GRI?
They answer different questions. IFRS S1 and S2 cover financial materiality, meaning how sustainability matters affect the company's own prospects, and are aimed at investors. GRI covers impact materiality, meaning how the company affects the economy, environment and people, and is aimed at a wider stakeholder group. They are interoperable: GRI 102 accepts equivalent IFRS S2 disclosures for Scope 1, 2 and 3 emissions where they follow the GHG Protocol, so companies using both do not calculate emissions twice.
When do Singapore's climate reporting rules apply to non-listed companies?
From FY2030, following the extension announced by ACRA and SGX RegCo on 25 August 2025. The threshold is annual revenue of S$1 billion and above together with total assets of S$500 million and above. External limited assurance on Scope 1 and 2 follows from FY2032. Listed issuers were not deferred on Scope 1 and 2 and report those from FY2025.
My company is too small to be in scope. Can I ignore sustainability reporting?
Not if you sell to companies that are in scope, because they need value chain data to complete their own reports. What changed in your favour is that there is now a ceiling. Since the delegated act of 3 July 2026, a company subject to CSRD cannot require a value chain company with 1,000 employees or fewer to provide more sustainability information than the Voluntary Standard requires. Preparing once against that standard is more efficient than answering each customer questionnaire separately.
Is CDP a reporting standard?
No. CDP is an environmental disclosure platform through which companies submit data, not a set of standards to report against. Its corporate questionnaire has been aligned with IFRS S2 since 2024 and partially maps to the new GRI climate and energy standards, so disclosing through CDP normally reuses work done for those frameworks rather than adding a separate one.
Sources
- Directive (EU) 2026/470 (Omnibus I), amending the CSRD and CSDDD. Published in the Official Journal 26 February 2026; entered into force 18 March 2026. Summary and thresholds: Accountancy Europe, Omnibus explained: key changes to the CSRD and CSDDD. https://accountancyeurope.eu/publications/omnibus-explained-key-changes-to-the-csrd-and-csddd/
- Norton Rose Fulbright, European Union adopts Omnibus Directive amending CSRD and CS3D. Scope thresholds, CSDDD transposition and application dates. https://www.nortonrosefulbright.com/en/knowledge/publications/1679488b/european-parliament-votes-to-adopt-omnibus-proposal-amending-csrd-and-cs3d
- PwC Viewpoint, Omnibus directive finalised. First reporting financial year, removal of sector standards, transposition period and the simplified ESRS timetable. https://viewpoint.pwc.com/gx/en/pwc/in-briefs/ib_int202527.html
- EFRAG, European Commission publishes delegated act on revised ESRS and voluntary sustainability reporting standard, 3 July 2026. Datapoint reductions and application dates. https://www.efrag.org/en/news-and-calendar/news/european-commission-publishes-delegated-act-on-revised-esrs-and-voluntary-sustainability-reporting
- Accounting and Corporate Regulatory Authority (Singapore), Sustainability reporting and assurance requirements: requirements and timeline. Entity thresholds, financial years and assurance dates. https://www.acra.gov.sg/regulations/sustainability-reporting/requirements-timeline/
- ACRA and SGX RegCo, Extended timelines for most climate reporting requirements to support companies, 25 August 2025. https://www.acra.gov.sg/news-events/news-announcements/887/
- California Air Resources Board implementation of SB 253 and SB 261. Regulation adopted 26 February 2026; SB 253 deadline moved to 10 November 2026 on 24 June 2026; SB 261 enforcement stayed pending Ninth Circuit appeal. Sidley, SB 253 Update: CARB delays reporting deadline to November 2026, 30 June 2026. https://environmentalhealthsafetybrief.sidley.com/2026/06/30/sb-253-update-carb-delays-reporting-deadline-to-november-2026-and-proposes-to-clarify-requirements/
- IFRS Foundation, ISSB and TCFD. TCFD disbandment, transfer of monitoring responsibilities and incorporation of TCFD recommendations into IFRS S2. https://www.ifrs.org/sustainability/tcfd/
- IFRS Foundation, SASB Standards. ISSB responsibility for the SASB Standards since August 2022. https://www.ifrs.org/issued-standards/sasb-standards/
- S&P Global Sustainable1, Where does the world stand on ISSB adoption?, May 2026. 28 jurisdictions adopting as at 22 April 2026, 12 more planning to. https://www.spglobal.com/sustainable1/en/insights/research-reports/issb-q2-2026
- Global Reporting Initiative, Topic Standard for Climate Change and Energy. GRI 102: Climate Change 2025 and GRI 103: Energy 2025, effective 1 January 2027, earlier adoption encouraged. https://www.globalreporting.org/standards/standards-development/topic-standard-for-climate-change-and-energy/
- CDP, Alignment with disclosure frameworks and standards. IFRS S2 alignment since 2024; 22,100 companies disclosing in 2025. https://www.cdp.net/en/about/framework-alignment
This article is editorial analysis current at 20 August 2026 and is not legal or accounting advice. Thresholds and dates in this area have changed repeatedly; confirm the current position for your jurisdiction before acting.