ESG Malaysia: Who Needs to Comply With the NSRF?

ESG Malaysia: Who Needs to Comply With the NSRF?

If you've heard the term NSRF and aren't sure whether it applies to your company, you're not alone. ESG Malaysia reporting requirements are rolling out in phases, and the eligibility rules depend on where your company is listed, how large it is, and by when. This isn't a how-to-comply guide. It's the narrower question that usually comes first: does this apply to us, and if so, from when?

Here's what the Securities Commission Malaysia has actually published on scope and timing, without the compliance-process detail that usually comes bundled in.

 

What the NSRF Actually Is

The National Sustainability Reporting Framework, or NSRF, is the core of ESG Malaysia's mandatory reporting regime. It's Malaysia's adoption of the IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB), specifically IFRS S1 for general sustainability disclosures and IFRS S2 for climate-related disclosures. The Securities Commission Malaysia's own NSRF framework describes it as a phased, developmental approach designed to bring Malaysian corporate reporting in line with global sustainability disclosure standards.

It was developed by the Advisory Committee on Sustainability Reporting, a body that includes representatives from the Securities Commission, Bank Negara Malaysia, the Companies Commission of Malaysia, and Bursa Malaysia, among others. Together, these agencies form the regulatory backbone behind ESG Malaysia reporting today.

Who Falls Into Scope, and When

The NSRF applies to three groups of entities, phased in over several years rather than all at once.

 

Group 1: Bursa Malaysia Main Market issuers with market capitalisation of RM2 billion and above

This group, including certain large financial institutions above the same threshold, began adopting IFRS S1 and S2 for annual reporting periods starting on or after 1 January 2025.

Group 2: Remaining Main Market listed issuers

Companies on Bursa Malaysia's Main Market that fall below the Group 1 threshold follow in 2026.

Group 3: ACE Market listed issuers and large non-listed companies

This includes ACE Market issuers and non-listed companies with consolidated group revenue of RM2 billion or more for two consecutive financial years. This group adopts the standards in 2027.

Companies that don't meet any of these thresholds aren't required to comply, though the framework allows voluntary adoption for organisations that want to report ahead of any mandatory timeline, often to satisfy investor or supply chain expectations.

Why the Standards Themselves Matter

The NSRF didn't invent its own reporting standards. It adopted the ISSB's IFRS S1 and S2, which the IFRS Foundation describes as establishing a high-quality global baseline for investor-focused sustainability disclosures. That matters for scope questions specifically because it's why the NSRF's phasing so closely tracks company size and listing status: the ISSB standards were built around investor materiality, which scales with a company's market footprint.

What This Means If You're Not Sure Where You Fall

A few quick checks can clarify your position. If you're listed on Bursa Malaysia's Main Market, your market capitalisation against the RM2 billion threshold determines whether you're in Group 1 or Group 2. If you're listed on the ACE Market, or unlisted with group revenue at or above RM2 billion for two consecutive years, you're most likely in Group 3.

If none of those apply, the NSRF doesn't currently require anything from you, though it's worth watching for future phases, and for supply chain pressure from larger customers who are already in scope and starting to ask their vendors similar questions.

How ESG Malaysia Compliance Is Likely to Widen

The three-group structure isn't the end state. The NSRF was explicitly designed with room to widen, both in terms of which companies are covered and what has to be disclosed. Scope 3 emissions reporting, for instance, is being phased in with additional lead time precisely because it depends on data from suppliers who may not yet be collecting it themselves.

That's a practical reason smaller, currently out-of-scope companies are paying attention to ESG Malaysia developments even without a mandatory deadline of their own. If your customers are in Group 1 or Group 2, their Scope 3 reporting obligations eventually flow back to you as a supplier, well before any formal requirement applies to your own company directly.

Frequently Asked Questions

1. Does the NSRF apply to private, unlisted companies?

Only if they meet the large non-listed company threshold: consolidated group revenue of RM2 billion or more for two consecutive financial years. Smaller private companies aren't currently in scope.

2. What happens if a company doesn't comply once it's in scope?

The Advisory Committee on Sustainability Reporting has set out a regulatory approach to non-compliance, published through the Securities Commission Malaysia. Details of enforcement sit with the relevant regulator for each entity type.

3. Can a company voluntarily adopt the NSRF before it's required to?

Yes. Entities outside the mandatory scope can adopt the framework voluntarily, which is increasingly common for companies anticipating future phases or responding to investor expectations.

4. Is the NSRF the same as ESG reporting generally?

The NSRF is Malaysia's specific mandatory framework, based on the ISSB's global IFRS S1 and S2 standards. "ESG reporting" is the broader practice; the NSRF is the regulatory mechanism enforcing parts of it in Malaysia.

5. Does NSRF compliance affect how a company should approach its corporate events?

Indirectly, yes. Companies in scope are increasingly expected to show ESG consistency across all their activities, including the events they run and the partners they choose. Our ESG policy outlines how we support clients navigating that expectation. Get in touch if you'd like to talk it through.

Getting Clarity Before You Plan a Response

Scoping questions are worth settling before anything else. Knowing which group you fall into, and by when, determines everything downstream: what your reporting team needs to prepare, what data collection has to start now versus later, and how much runway you actually have.

Once that's clear, the compliance and implementation work becomes a much more concrete project rather than an open-ended concern.

The first question in ESG Malaysia compliance isn't how. It's whether, and by when.

If your organisation touches ESG reporting and you'd like to talk through how that shapes your event and communications strategy, reach out to a.c.e.

About Above Creative Events (a.c.e) 

a.c.e is the 1st Certified B Corp Corporate Event Agency in Southeast Asia, meeting B Lab's integrated social, environmental, and governance standards. 

a.c.e is also an award-winning events agency specialising in conferences, leadership summits, corporate townhalls and large-scale multinational events. Since 2007, a.c.e has been known as the "Magic Makers", combining creative ideas with disciplined execution to bring events to life for GF500, GLCs, MNCs and PLCs. We transform imagination into reality so that our clients can strengthen their brand and amplify their market presence. 

If you need any service in any aspect of event planning, drop us a message or an email. Visit our website to know more!