NSRF Isn't One Deadline — It's Three, and Most Companies Are Planning for the Wrong One

NSRF compliance deadlines

Ask most finance teams when the National Sustainability Reporting Framework applies to them, and you'll get a single date back — usually whichever one came up first in a webinar or a LinkedIn post. That's the problem. NSRF isn't one deadline. It's three, phased by company size and listing status, and getting your group wrong means either scrambling late or over-investing early.

Group 1 covers Main Market issuers with a market cap above RM2 billion, reporting from FY2025. Group 2 covers the rest of the Main Market issuers, from FY2026. Group 3 covers ACE Market issuers and large non-listed companies with revenue above RM2 billion, from FY2027. Scope 3 emissions disclosure — the hardest category, because it requires data from your suppliers and customers, not just your own operations — is phased separately again: Group 1 from FY2027, Group 2 from FY2028, Group 3 from FY2030.

That gap between when Scope 1/2 reporting starts and when Scope 3 kicks in matters more than most companies realize. It's not extra time to relax — it's the exact window where the infrastructure for Scope 3 needs to get built, quietly, while the pressure is still on Scope 1 and 2. Companies that wait until their Scope 3 deadline is visible on the calendar to start asking suppliers for data are starting a multi-year data-collection problem with a multi-month runway.

There's a second layer worth naming for government-linked companies specifically: many GLCs sit inside Group 1 or Group 2 by virtue of being Main Market-listed, and their NSRF timeline now runs alongside the National Smart City Blueprint's own 2026–2040 rollout. Two mandates, two different origins, landing on the same finance and operations teams at roughly the same time. Companies that treat these as separate compliance tracks end up duplicating work; the ones getting ahead of it are building one data infrastructure that answers both.

The practical move, regardless of which group you're in: find out your exact group now, map backward from your Scope 3 date rather than your first reporting date, and start the supplier data conversation years before the framework technically requires it. The framework gives you the runway. Most companies just don't realize they're already using it.

What would change in your reporting roadmap if you planned backward from your hardest deadline instead of forward from your easiest one?