# NSRF: Who Has to Report Sustainability Information, and From When

> The National Sustainability Reporting Framework as a reporting obligation with dates and thresholds — the three groups, the RM2 billion non-listed test, the assurance timeline, and the separate SSM proposal that most commentary confuses it with.

- Category: accounting
- Language: en
- Status: published
- Updated: 2026-07-20
- Canonical: https://negaraku.md/en/accounting/nsrf-sustainability-reporting

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Sustainability reporting arrived in Malaysia as a communications topic and is
becoming an accounting one. The National Sustainability Reporting Framework does
not ask for a glossy report. It adopts IFRS S1 and IFRS S2 as **baseline
disclosure standards**, sets an adoption timeline by reporting period, and
targets **reasonable assurance** — the same level as an audit opinion — on Scope 1
and Scope 2 emissions.

That last word is the tell. Once a number carries reasonable assurance, it needs
a control environment, an audit trail and a person who owns it. It has become
finance's problem.

The other reason to treat this precisely: the published commentary is a mess. The
most common error puts large non-listed companies in 2026. A second confuses the
Securities Commission's NSRF with a separate SSM proposal that has completely
different thresholds. Both are dealt with below, from the primary documents.

## The three groups

Table 1 of the NSRF, verbatim in structure:

| Group | Applicable entities | Annual reporting periods beginning on or after |
| --- | --- | --- |
| Group 1 | Main Market listed issuers with market capitalisation, excluding treasury shares, of RM2 billion and above as of 31 December 2024, or as at the date of listing after that date | 1 January 2025 |
| Group 2 | Main Market listed issuers other than those in Group 1 | 1 January 2026 |
| Group 3 | ACE Market listed issuers, and large non-listed companies | 1 January 2027 |

The framework adds a note worth quoting because it removes a common ambiguity:
an annual report for a period beginning 1 January 2025 is the same thing as an
annual report for the financial year ending 31 December 2025.

**Large non-listed companies are in Group 3, from 2027.** Not 2026. Where you see
2026 attached to non-listed companies, the two rows have been merged.

## The RM2 billion test, exactly as written

Paragraph 4.1(c) applies the framework to non-listed companies "if they meet the
prescribed threshold of consolidated group revenue of RM2 billion and above for
two consecutive financial years preceding the current financial year".

Three features of that wording do real work:

**Revenue only.** No asset test, no headcount test. This is unlike the audit
exemption criteria under Practice Directive 10/2024, which run on any two of
revenue, assets and employees.

**Two consecutive preceding years.** Not the current year. A company that crosses
RM2 billion for the first time this year is not in scope this year.

**Consolidated, unless there is no consolidation.** Where there is no requirement
to prepare consolidated accounts, the threshold applies at company level — which
the framework says is intended to align with the entity's existing financial
reporting practices.

Paragraph 4.2 explains the policy: economically or environmentally significant
companies are not limited to listed entities, and non-listed companies are
integral to the broader supply chain. Paragraph 4.3 encourages voluntary
adoption, and specifically names hard-to-abate sectors and CBAM sectors — cement,
iron, steel, aluminium, chemicals, fertilisers, electricity, hydrogen and
petroleum.

## Group relief for subsidiaries of foreign parents

Two provisions matter to any Malaysian company inside a multinational group.

Paragraph 5.2: a large non-listed company whose holding company **already reports
using ISSB-aligned standards or equivalent standards** such as the European
Sustainability Reporting Standards **may leverage** the holding company's
sustainability- and climate-related disclosures.

Paragraph 5.3: where the holding company reports using **other** international
standards and frameworks — GRI and TCFD are the named examples — the subsidiary
**may be given exemption from reporting for three reporting periods**, but this is
subject to the policy decision of the Registrar. The framework footnotes
"Registrar" as the Chief Executive Officer of SSM under s.20A(1) of the Companies
Commission of Malaysia Act 2001. After that, the standard applies for annual
periods beginning on or after 1 January 2030.

The difference between the two paragraphs is the difference between a
self-assessed leverage and a discretionary exemption you have to ask for.

## Transition reliefs

The NSRF layers three additional transition reliefs (ATR) on top of the ISSB's
own proportionality mechanisms. They run for **two years for Groups 1 and 2, and
three years for Group 3**, measured from the first annual reporting period.

- **ATR 1** — disclose only climate-related risks and opportunities under IFRS S2, applying IFRS S1 only so far as it relates to climate. Using this relief also removes the requirement to disclose comparative information in the first annual reporting period.
- **ATR 2** — focus climate-related disclosures on principal business segments.
- **ATR 3** — do not disclose Scope 3 GHG emissions, except for categories already required by the entity's own regulator.

The stated year count is **inclusive of the ISSB's existing one-year relief**, so
do not add them together. And the comparative-information reliefs remain subject
to each regulator's own requirements.

At the end of ATR 3, Scope 3 must be disclosed in accordance with the categories
in the GHG Protocol Corporate Value Chain standard.

## Assurance

This is the part with a date attached and a caveat attached to the date.

Paragraph 7.2: external assurance is **currently voluntary**. The aim is to
mandate **reasonable assurance on Scope 1 and Scope 2 GHG emissions** on this
timeline:

| Group | Reasonable assurance for annual reporting periods beginning on or after |
| --- | --- |
| Group 1 | 1 January 2027 |
| Group 2 | 1 January 2028 |
| Group 3 | 1 January 2029 |

Two qualifications sit in the document itself. The table is footnoted as
**subject to further consultations**. And paragraph 7.4 says the framework for
assurance, **including the assurance providers**, will be announced after further
consultation — so the question of who may sign a sustainability assurance report
is open. Paragraph 7.3 does say engagements are expected to be performed in
accordance with assurance standards adopted by the Malaysian Institute of
Accountants.

Plan for it. Do not budget it as settled.

## Where the conflicting sources come from

Most of the contradiction in circulation traces to a single conflation, and it is
worth naming because both documents are real.

**The NSRF** is the Securities Commission and ACSR framework described above:
RM2 billion, three groups, 2025 to 2027, ISSB standards.

**SSM's Consultative Document on the Proposed Amendments to the Companies Act
2016 on Sustainability Reporting**, issued for comment closing 2 June 2026, is a
different instrument aimed at a different population — non-listed companies
**below** the NSRF threshold. It proposes a comply-or-explain regime, with the
Registrar empowered to determine the requirements, and it proposes qualifying
thresholds beginning at **RM15 million** of revenue or 100 employees, phased
between **2028 and 2033**, starting with Scope 1 and Scope 2 emissions before
simplified sustainability disclosures and, for the largest tier only, IFRS S2.

Those proposed numbers get quoted as if they were NSRF thresholds. They are not.
They are consultation proposals under a different statute, aimed at companies the
NSRF does not reach, and at the date of this page the outcome of that
consultation has not been published. Nothing in it should be treated as a
current obligation.

## What this means for a finance function

The NSRF is a reporting framework, and its legal force for a listed issuer runs
through Bursa's listing requirements rather than through the Companies Act.
Section IX contemplates consequential amendments to the Financial Reporting Act
1997, the Companies Act 2016, the Securities Commission Malaysia Act 1993, the
Capital Markets and Services Act 2007, the listing requirements and Bank Negara
standards — and an expanded MASB mandate to set Malaysian sustainability
disclosure standards, expected around early 2027.

Until those amendments are in place, a large non-listed company's obligation is
a framework expectation supported by the Registrar's role in paragraph 5.3,
rather than a section you can cite. That is an honest description of the position
and a reason to start early, not a reason to wait.

## Common mistakes

- **Putting large non-listed companies in 2026.** Group 3 begins with annual
  reporting periods beginning on or after 1 January 2027.
- **Testing the RM2 billion threshold on the current year.** It is two
  consecutive financial years *preceding* the current one.
- **Applying an asset or employee test.** The NSRF threshold is revenue only.
- **Quoting SSM's proposed RM15 million revenue or 100-employee tiers as NSRF thresholds.**
  Different regime, different statute, still a consultation.
- **Treating mandatory assurance as fixed.** The timeline is footnoted as subject
  to further consultation and the provider framework is unannounced.
- **Adding the ISSB relief to the NSRF relief.** The two and three-year durations
  are stated as inclusive of the existing one-year ISSB relief.
- **Assuming a foreign parent's GRI report is an automatic pass.** Paragraph 5.2
  covers ISSB-aligned reporting; paragraph 5.3 makes other frameworks a
  discretionary three-period exemption decided by the Registrar.

## What's next

If your group revenue is anywhere near RM2 billion, run the two-preceding-years
test now against your last two sets of consolidated accounts. If it is met, the
first reporting period begins on or after 1 January 2027 and the practical
deadline is the emissions data, not the report — Scope 1 and Scope 2 measurement
has to be running for a full period before it can be reported, and running under
control before it can be assured.

## Sources

- National Sustainability Reporting Framework — https://www.sc.com.my/api/documentms/download.ashx?id=e98c3900-7b35-4cf5-a07d-fd17acf8734e (Securities Commission Malaysia)
- National Sustainability Reporting Framework — implementation summary and additional transition reliefs — https://www.sc.com.my/api/documentms/download.ashx?id=20efbd8f-b5a0-4122-994f-edbccd53c2b2 (Securities Commission Malaysia)
- National Sustainability Reporting Framework — https://www.sc.com.my/nsrf (Securities Commission Malaysia)
- Consultative Document on the Proposed Amendments to the Companies Act 2016 [Act 777] on Sustainability Reporting — https://www.ssm.com.my/Pages/Legal_Framework/Document/%5BENG%5D20260422_External%20ESG%20Framework_Consultative%20Document_BI.pdf (SSM)
- Companies Act 2016 (Act 777), updated text as at 1 August 2022 — https://www.ssm.com.my/Pages/Legal_Framework/Document/Companies%20Act%202016_Akta%20777_BI%20(1.8.2022).pdf (SSM)

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