NSRF Malaysia: IFRS S2 Reporting Starts with Energy Data

Here is the short version for anyone asked to "handle NSRF" this year. NSRF Malaysia, the National Sustainability Reporting Framework released on 24 September 2024, adopts the ISSB's IFRS S1 and IFRS S2 as the baseline disclosure standards for Malaysian companies, phased across three groups: Main Market issuers with market capitalisation of RM2 billion and above started climate-first reporting for FY2025, the rest of the Main Market started FY2026, and ACE Market plus RM2 billion-revenue non-listed companies start FY2027. The hard part is not the report. Every Scope 2 tonne in an IFRS S2 disclosure is metered kWh multiplied by a grid emission factor, and from FY2027 Group 1's Scope 1 and 2 numbers are slated for reasonable assurance: audit-level scrutiny. That makes NSRF compliance an energy-data engineering problem before it is a reporting problem.

What does the NSRF require? The short answer

The NSRF requires in-scope Malaysian companies to publish sustainability disclosures prepared in accordance with IFRS S1 (general requirements) and IFRS S2 (climate-related disclosures), inside the annual report, at the same time as the financial statements.

The framework was released by the Advisory Committee on Sustainability Reporting, chaired by the Securities Commission Malaysia with the Audit Oversight Board, Bank Negara Malaysia, Bursa Malaysia, the Companies Commission of Malaysia (SSM) and the Financial Reporting Foundation. On 23 December 2024, Bursa Malaysia amended the Main Market and ACE Market Listing Requirements to make the annual report's Sustainability Statement follow IFRS S1 and S2 on a phased basis.

Two details matter operationally. Companies must make an explicit, unreserved statement of compliance with the ISSB standards: GRI or other frameworks can sit alongside but cannot obscure what IFRS S1/S2 require. And Malaysia removed the IFRS S1 relief that allowed sustainability disclosures to lag the financial statements: your emissions numbers close on the same calendar as your accounts, per the IFRS Foundation's Malaysia jurisdictional profile.

Who must comply with NSRF Malaysia, and when?

Three groups, phased by size and market. All dates refer to annual reporting periods beginning on or after the date shown.

- Group 1: Main Market issuers (including REITs and business trusts) with market capitalisation of RM2 billion and above as of 31 December 2024. Climate-first reporting from 1 January 2025; full IFRS S1 + S2 from 1 January 2027. Their first NSRF climate reports (FY2025) are being published in 2026.
- Group 2: all remaining Main Market issuers. Climate-first from 1 January 2026 (so FY2026 is their first reporting year, with reports due in 2027); full IFRS S1 + S2 from 1 January 2028.
- Group 3: ACE Market corporations plus large non-listed companies (NLCos) with annual revenue of RM2 billion and above. Climate-first from 1 January 2027; full IFRS S1 + S2 from 1 January 2030.

"Climate-first" means you start with IFRS S2's climate disclosures before the broader IFRS S1 sustainability requirements switch on. There are reliefs: Groups 1 and 2 may omit Scope 3 for their first two annual periods (Group 3 for three), though Main Market issuers must still disclose business travel and employee commuting under existing Bursa rules, and a Malaysia-specific relief lets entities focus climate disclosures on principal business segments for the first two or three periods.

For non-listed companies, SSM will set the disclosure location through Companies Act 2016 amendments, with MASB becoming the national standard-setter for sustainability disclosures. An NLCo whose holding company already reports under ISSB-aligned standards can be exempted for three annual periods, subject to the Registrar's decision.

If your company also exports to the EU, the same underlying emissions data feeds a second regime: see our post on CBAM for Malaysian exporters.

What energy and emissions data does IFRS S2 actually demand?

IFRS S2 requires gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions, disclosed in metric tonnes of CO2 equivalent, measured in accordance with the GHG Protocol Corporate Standard (2004). Scope 2 must be reported using the location-based method (your actual grid electricity consumption times the grid's emission factor), with separate information about contractual instruments such as RECs if you use them, per the IFRS S2 educational material on GHG disclosures.

This is not a step change from zero. Bursa's existing Sustainability Reporting Guide (3rd edition, 2022) already prescribes "Energy management" as a common sustainability matter, with indicator C4(a) "Total energy consumption" and at least three years of quantitative data. What NSRF changes is the rigour: gross tCO2e under a named methodology, published simultaneously with audited financials, and heading toward independent assurance.

Scope 2 in Malaysia = your kWh × the grid emission factor

The entire location-based Scope 2 calculation for a Malaysian facility is: metered grid electricity per site, multiplied by the official Grid Emission Factor (GEF) for that site's grid.

Suruhanjaya Tenaga published Malaysia's official GEF for 2022–2024 (provisional) in February 2026. The 2024 provisional figures:

- Peninsular Malaysia: 0.740 tCO2e/MWh (down from 0.760 in 2023 and 0.769 in 2022)
- Sabah: 0.539 tCO2e/MWh
- Sarawak: 0.199 tCO2e/MWh

Worked example: a plant consuming 1 GWh of grid electricity a year in Peninsular Malaysia reports roughly 740 tCO2e of location-based Scope 2 (1,000 MWh × 0.740). The identical load in Sarawak is about 199 tCO2e. Two consequences follow. Your kWh must be attributable per site, because the factor differs by grid region. And your kWh must be right, because every metering error propagates straight into a disclosed emissions figure at 0.74 kg CO2e per kWh.

One caveat from ST's notes: the GEF includes generation from RE plants that may issue RECs. If you buy mGATS RECs or green tariffs, IFRS S2 still requires the location-based number first, with contractual instruments disclosed separately. RECs change the story you tell; they do not remove the need for metered consumption data.

The real deadline is assurance: FY2027 for Scope 1 and 2

The NSRF's stated aim is to mandate reasonable assurance (the same confidence level as a financial audit, not the lighter "limited assurance" review) on Scope 1 and Scope 2 emissions for Group 1 entities from annual periods beginning on or after 1 January 2027, with Groups 2 and 3 following. The assurance framework is still under consultation by the Sustainability Assurance Working Group, with engagements expected under ISAE 3000 (Revised) or ISSA 5000, per the SC's NSRF page and the IFRS jurisdictional profile.

From the facility side, the assurance provider will not accept a summary number. They will ask for:

- the source data: meter registers, interval readings, utility bills, fuel purchase records
- the meter inventory: which meters cover which sites and boundaries, calibration status, what happens when one fails
- the calculation trail: kWh to MWh to tCO2e, which GEF vintage was applied, where the conversion happened, who changed what and when
- completeness evidence: proof that no site, tenant or month is missing from the consolidation

That is FY2027 data for Group 1, meaning the systems producing it need to be in place during 2026. At a Group 1 issuer, the assurance clock has effectively already started.

Why spreadsheet-built Scope 2 numbers fail assurance

A spreadsheet fed by manual bill transcription fails on exactly the dimensions an assurance provider tests: provenance, completeness and traceability. Typed-in kWh figures have no link back to a meter register. Missing months get interpolated silently. A formula edited in March quietly changes the January total, with no record of who did it or why. And when sub-meter totals don't reconcile to the TNB bill (they never match exactly), there is no documented method for resolving the gap.

We have written before about the sustainability manager's impossible spreadsheet; under NSRF, its weaknesses stop being an internal inefficiency and become audit findings. Under limited assurance, an unexplained gap earns a question. Under reasonable assurance, it can earn a qualified conclusion attached to your annual report.

What does an assurance-ready energy data pipeline look like?

Four layers, all boring, all necessary:

1. Interval metering per site and boundary. Automatic reads from the TNB revenue meter and your sub-meters, mapped to reporting entities and grid regions. No manual transcription anywhere in the chain.
2. Automated aggregation with gap handling. Consumption rolls up from meter to site to group on a schedule, with missing intervals flagged and estimation methods documented, not silently patched.
3. Bill and tariff reconciliation. Metered totals checked against utility invoices monthly, with variances investigated when they occur, not reconstructed two years later during an assurance engagement.
4. Evidence retention. Raw readings, applied emission factors, calculation versions and user actions kept and retrievable, so the trail from disclosed tCO2e back to a specific meter is a query, not an archaeology project.

This is the same thesis we made for Malaysia's energy-efficiency regime in EECA reporting starts with data, pointed at a different regulator: EECA answers to Suruhanjaya Tenaga about efficiency; NSRF answers to investors about emissions. Both run on the same metered kWh — build the pipeline once and it serves both.

How CobiNeural maps to NSRF disclosures

CobiNeural's modules line up with the NSRF data chain without a separate carbon tool. Insights → Energy captures interval consumption, demand and EUI per site and per equipment. Billing & Tariffs reconciles metered data against TNB invoices and allocates tenant costs. The Sustainability module tracks Scope 1, 2 and 3 against net-zero targets, and Reporting produces ESG/GHG outputs alongside EECA reports, with EnMS covering the ISO 50001 policy and committee structure many issuers run in parallel. Because it deploys standalone or as an overlay on an existing BMS, PLC or SCADA, the metering you already have becomes the evidence base, not another silo.