Your 12-Month Sustainability Compliance Roadmap for Group 2 Companies (FY2026)

The clock is ticking for Group 2 public listed companies (PLCs) in Malaysia. Under Bursa Malaysia's National Sustainability Reporting Framework (NSRF), if your company is listed on the Main Market with a market capitalisation below RM2 billion, your first IFRS S1/S2-compliant sustainability report must cover the financial year beginning 1 January 2026 — to be published in 2027.

That may sound like you have time. But sustainability reporting under IFRS standards is not a box-ticking exercise you can complete in a few weeks. It requires governance restructuring, data collection systems, stakeholder engagement, and board-level oversight. Companies that start early will be in a far stronger position than those who leave it to the last quarter of 2026.

This post gives you a practical, month-by-month roadmap to get your company ready for FY2026 reporting.

Months 1 to 2: Gap Assessment and Team Formation

The first step is understanding where your company currently stands relative to IFRS S1 and IFRS S2 requirements. Conduct a gap assessment — comparing your existing sustainability disclosures (if any) against what the standards require. This will reveal which areas need the most work.

At the same time, form your internal sustainability task force. This should include representatives from finance, operations, legal, HR, and the company secretary's office. Appoint a project lead — ideally someone with direct access to the CEO and board. If you do not have in-house ESG expertise, this is the time to engage an external sustainability consultant.

Key actions: Conduct gap assessment, form sustainability committee, appoint project lead, brief the board on upcoming requirements.

Months 3 to 4: Materiality Assessment

A materiality assessment identifies which of Bursa's 9 Material Sustainability Matters are most significant to your business and your stakeholders. This is not optional — it is a core requirement of both IFRS S1 and the NSRF.

The assessment involves stakeholder surveys and interviews, a materiality matrix mapping topics by stakeholder importance and business impact, and board-level validation of the final results. The output of your materiality assessment determines the scope of your reporting — so getting it right is critical.

Key actions: Identify stakeholders, conduct stakeholder engagement, build materiality matrix, validate with board, document findings.

Months 5 to 6: Data Collection Framework

Once you know what matters are material, you need to set up systems to collect the relevant data. For IFRS S2, this means establishing a greenhouse gas (GHG) emissions tracking process for Scope 1 and Scope 2 emissions. For your material IFRS S1 matters, you need to identify data owners, data sources, and reporting templates.

This is often the most technically challenging phase. Many companies discover at this stage that they do not have systems in place to capture energy consumption, water usage, workforce data, or supply chain information at the level of detail required. The earlier you identify these gaps, the more time you have to fix them.

Key actions: Set up GHG data collection, identify data owners per material matter, build internal reporting templates, assess data quality and completeness.

Months 7 to 8: Governance Structure and Board Training

Bursa Malaysia and IFRS S1 require companies to demonstrate board-level oversight of sustainability risks and opportunities. If your board does not currently have a sustainability or ESG committee, now is the time to consider establishing one.

Directors also need to understand what they are overseeing. Board training on IFRS S1/S2, climate risk, and sustainability governance is not just good practice — it is increasingly expected by regulators and institutional investors. Document the training undertaken and the board's sustainability oversight activities throughout the year.

Key actions: Establish sustainability committee, conduct board ESG training, integrate sustainability into board KPIs, document governance structures.

Months 9 to 10: Drafting the Sustainability Statement

With data collected and governance in place, you can begin drafting your sustainability statement. This is the core disclosure document that covers all four IFRS S1 pillars (Governance, Strategy, Risk Management, Metrics and Targets) and the climate-specific disclosures under IFRS S2.

The draft should be reviewed by your legal, finance, and investor relations teams — as well as your external sustainability consultant. Cross-reference your disclosures against the Bursa Malaysia NSRF requirements and the IFRS standards to ensure completeness.

Key actions: Draft sustainability statement, internal review and cross-checking, legal and finance sign-off, prepare quantitative data tables.

Months 11 to 12: Assurance, Final Review, and CSI Platform Submission

Before your report is finalised, consider whether you need third-party assurance. Bursa Malaysia has phased assurance requirements — but even where it is not yet mandatory, assurance significantly enhances credibility with investors and analysts.

Submit your sustainability data via Bursa Malaysia's Centralised Sustainability Intelligence (CSI) Platform. Ensure all required data fields are complete and accurate. The published sustainability report should be incorporated into or accompany your Annual Report.

Key actions: Engage assurance provider (if applicable), final board approval of sustainability report, submit to CSI platform, publish sustainability statement with Annual Report.

Start Your Roadmap with Brandford Consulting

The 12-month roadmap above is a guide — your specific timeline and priorities will depend on your company's size, industry, and current sustainability maturity. Starting too late is the single biggest risk for Group 2 PLCs. The good news is that companies that invest in proper preparation now will build lasting systems and capabilities that benefit the business well beyond compliance.

Brandford Consulting specialises in guiding Group 2 PLCs through every stage of this journey — from gap assessment to CSI platform submission. Contact us today to build your customised compliance roadmap.

Not sure if your company is ready for Bursa NSRF compliance? Take our free Self-Assessment and get your personalised gap analysis report in minutes.

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