a. There is currently no duty to implement net zero business strategies as such. Under the SGX Mainboard Listing Rules (“Mainboard Rules”), companies listed on the Singapore Exchange are being required in phases to submit climate reports incorporating the climate-related requirements in the International Sustainability Standards Board standards incorporating climate-related disclosures. From FY 2030, mandatory climate reporting will also begin to be introduced to large unlisted companies in phases.

b. The use of carbon offsets to meet net zero or carbon neutral commitments is not regulated as such, but liability under the Consumer Protection (Fair Trading) Act 2003 may attach to claims about the use of carbon offsets to meet such commitments if the claims are materially false and misleading in the context of a consumer transactions; or under the Securities and Futures Act 2001 if claims about the use of carbon offsets to meet such commitments that are made or disseminated are false or misleading and are likely to induce other persons to subscribe for securities or the sale or purchase of securities, or to have the effect of affecting the market price of securities. The use of carbon credits to meet carbon tax liabilities is regulated under the Carbon Pricing Act 2018.

c. To our knowledge, there have not been any cases brought in Singapore against companies for
undeliverable net zero strategies.

d. To our knowledge, there have not been any cases brought in Singapore against companies for their proportionate contribution to global levels of greenhouse gases.

There is no requirement for projects to demonstrate biodiversity net gain to receive planning permission

(development consent). That said, under the Parks and Trees Act 2005, premises undergoing building works are required to provide for planting areas that conform with prescribed dimensions and the specification of the Commissioner of Parks and Recreation. The planting areas must also be maintained by the occupier and may not be interfered with except with the approval of the Commissioner.

Companies that in a year (a) use more than the threshold volume of water in carrying out any of their business activities at a site (whether or not the water was supplied by the Public Utilities Board); or (b) have more than the threshold volume of water supplied to it at a site by the Board for use in connection with any business activity carried out at the site (whether or not carried out by the company supplied with the water); are required under the Public Utilities Act 2001 to submit to the Board annual reports that inter alia contain water usage information.

To our knowledge, there have not been any test cases brought against companies for product liability or pollution of the environment related to forever chemicals such as Perfluoroalkyl and Polyfluoroalkyl Substances. There are regulatory requirements under the Environmental Protection and Management Act 1999 for the storage, import, and use of certain forever chemicals deemed to be ‘hazardous substances’, namely Pentadecafluorooctanoic acid (PFOA), its salts and related compounds; Perfluorohexane sulfonic acid (PFHxS), its salts and related compounds; and Perfluorooctane sulfonic acid (PFOS).

a. There are no direct requirements on producers, distributors, or retailers of products to ensure levels of recycling and/or a proportionate quantity of recycled materials in products.

b. Under the Resource Sustainability Act 2019, persons who carry on the business of supplying prescribed consumer electronic and electrical products and in the course of such business import or manufacture such goods in excess of the prescribed threshold must join a producer responsibility scheme for the collection and disposal of e-waste operated by a licensed operator.

Retailers supplying regulated consumer products to a consumer; and who in the course of such supply, deliver such products to any premises specified by the consumer, may be required by the consumer to collect from the premises, and dispose of, another regulated consumer product that is of the same class or type as the supplied product. The collected product must be presented to the licensed operator of the e-waste producer responsibility scheme.

Retailers of regulated consumer products that are prescribed as designated regulated consumer products; and who occupy any premises with a floor area of or more than 300 m2 from which any designated regulated consumer product is supplied must accept any designated regulated consumer product brought of the same class or type of consumer products as that supplied at those premises bought to its premises for disposal. The collected product must be presented to the licensed operator of the e-waste producer responsibility scheme.

Persons who carry on the business of supplying a regulated non-consumer product and in the course of such business import or manufacture the product, must when presented with the product for the purpose of disposal by a person or requested by a person to dispose of the product, the producer, within a reasonable time after being presented or receiving the request, collect the product from any premises specified by the person. The product collected must be disposed of by a licensed waste collector or licensed e-waste recycler

From 1 April 2026, importers and local manufacturers of regulated beverages in a sealed beverage containers made from plastic or metal must also not supply such products in Singapore unless they are members of a licensed producer responsibility scheme for beverage containers in Singapore operated by a licensed operator. Licensed operators will be given collection targets and be required to ensure the recycling of the e waste and containers collected under the schemes.

Under the Resource Sustainability Act 2019, persons whose turnover is above the prescribed threshold and who carry on a business of supplying regulated goods in Singapore, and in furtherance of that business: (a) import of specified packaging by importing regulated goods with such packaging; or (b) use specified packaging by packing regulated goods with such packaging, supply regulated goods to a retailer and provide such packaging for the retailer’s use, or provide such packaging as a retailer to a consumer who purchases regulated goods, are required to report on the specified packaging imported or used. The government has announced its intention to introduce extended producer responsibility for packaging waste in the future and have started doing so with beverage containers. See answer to Question 5.

The transport, import, storage, supply or use of plastics that contain prescribed hazardous substances is also regulated under the Environmental Protection and Management Act 1999.

There are no laws that directly require an employer to ensure equality, diversity and inclusion in the workplace.

That said, pursuant to the Mainboard Rules that all companies listed on the Singapore Exchange must abide by, Rule 710A of the Mainboard Rules provides that all listed companies must maintain a board diversity policy which must minimally address gender, skills and experience, and any other relevant aspects of diversity. Further, Rule 710A(2) of the Mainboard Rules provides that the board diversity policy must be described in the company’s annual reports, which must include: (i) the company’s targets to achieve board diversity; (ii) the company’s accompanying plans and timelines for achieving the targets; (iii) the company’s progress towards achieving the targets within the timelines; and (iv) a description of how the combination of skills, talents, experience and diversity of the company’s directors serves the needs and plans of the company.

In addition, Principle 2 of the Code of Corporate Governance (the “Code”), which complements the Mainboard Rules and operates on a comply-or-explain basis, provides that a listed company’s board must have an appropriate level of independence and diversity of thought and background in its composition to enable it to make decisions in the best interests of the company. Provision 2.4 of the Code further provides that the company’s board and board committees should comprise directors who as a group provide an appropriate balance of diversity in skills, knowledge, gender and age.

There are no laws currently in force that impose legal duties on employers to treat employees fairly and with respect.

However, the Workplace Fairness Act 2025, which is slated to take effect in end-2027, will fill this vacuum by imposing statutory obligations on employers to prevent discriminatory practices when making employment decisions when hiring, during employment or when terminating employment (collectively, the “Employment Decisions”). Subject to certain exceptions and exemptions contained therein, it will be unlawful to base Employment Decisions on protected characteristics (i.e., age, nationality, sex, marital status, pregnancy, caregiving responsibilities, race, religion, language ability, disability, and mental health conditions). A breach of the Workplace Fairness Act 2025 would result in administrative or civil liabilities (as the case may be) being incurred by the employers.

In addition, the Workplace Fairness Act 2025 works in tandem with the Tripartite Guidelines on Fair Employment Practices (the “Guidelines”), which addresses workplace discrimination based on characteristics other than the protected characteristics. The Guidelines are formulated by the Tripartite Alliance for Fair and Progressive Employment Practices (the “Alliance”), of which the Ministry of Manpower (“MOM”) is a party. Under the Guidelines, employers are expected to adopt certain fair employment practices, including: (i) recruiting based on merit; (ii) treating employees with respect and fairness; (iii) providing employees with fair and equal opportunities to be considered for training and development; (iv) rewarding employees fairly based on ability, performance, contribution and experience; and (v) abiding by labour laws and to adopt the Guidelines. While the Guidelines are non-legally binding, non-compliant employers will face scrutiny from the MOM and have their work pass privileges curtailed (e.g., debarred from making and renewing work pass applications.)

There is no legal requirement to pay a minimum wage or a wage that is high enough to maintain a normal standard of living.

That said, there are two mandatory schemes promulgated by the MOM to encourage employers to meet certain minimum wage requirements, namely (i) the “progressive wage model” scheme (“PWM”); and (ii) the Local Qualifying Salary scheme (“LQS”). The LQS and PWM work in tandem to ensure that companies continue to meaningfully remunerate all employees.

First, the PWM, which applies to Singaporean or permanent resident employees working full-time or part-time under a contract of service, is applicable only to specific sectors (i.e., cleaning, security, landscape, lift and escalator, retail, food services, driver, administrators and waste management). Pursuant to the PWM scheme, employers are required to (i) pay their employees in accordance with the tiered minimum wage floor that corresponds to employees’ skill levels and productivity; and (ii) upskill workers based on stipulated training requirements, such that employees’ wages can increase progressively in line with the PWM. Compliance with the PWM is required for employers to obtain or renew their licences from the relevant authorities in the selected sectors (e.g., National Environmental Agency, Singapore Police Force, Building and Construction Authority etc.)

Second, companies that employ foreign workers (e.g., Work Permit, S Pass or Employment Pass holder) are required to comply with both the PWM (covered by the relevant sectorial and occupational PWMs) and LQS. The LQS determines the number of local employees counted towards the computation of a company’s foreign employee quota. The LQS requires employers to pay prescribed minimum wages to all its local employees (i.e., Singaporean or permanent resident) not covered under the PWM, including those that work part-time. Companies that fail to comply with either the PWM or the LQS will be unable to apply for new work passes or renew existing work passes.

a. There are no statutory duties to perform due diligence in relation to adverse impacts on human rights of the
environment as such. However, companies listed on the Singapore Exchange are required to submit annual sustainability reports under the Mainboard Rules, to review their businesses in the context of their value chains and determine what ESG factors in relation to the companies’ interaction with their physical environments and social communities and their governance, are material for the continuity of their businesses. The sustainability reports should also set out the companies’ policies, practices and performance in relation to the material ESG factors identified.

b. To our knowledge, no test cases have been brought against companies for failing to do due diligence in relation to adverse impacts on human rights or the environment.

a. There are no statutory duties to perform due diligence in relation to adverse impacts on human rights or the environment in host communities. As explained earlier, there is a requirement under the Mainboard Rules for companies listed on the Singapore Exchange to submit annual sustainability reports , and to include in the reports, a review of their business and determination of the ESG factors in relation to the companies’ interaction with their physical environments and social communities that are material for the continuity of their businesses. The sustainability reports should also set out the companies’ policies, practices and performance in relation to the material ESG factors identified.

b. To our knowledge, no test cases have been brought against companies for failing to do due diligence in relation to adverse impacts on human rights or the environment.

In December 2023, the Advertising Standards Authority of Singapore (ASAS) found an advertisement with the caption “Save Earth and electricity with 5 ticks energy savings”; and claiming that the advertiser’s air-conditioners were the “best tip” to “save the earth” to be misleading and in breach of its Singapore Code of Advertising Practice. The advertiser was notified of the decision and removed its advertisement.

In January 2025, the ASAS asked for an advertisement by an airline to be removed due to concerns about greenwashing. The campaign highlighted the airline’s “fuel-efficient” fleet and use of digital services such as e-tickets and online check-ins as evidence of its environmentally friendly credentials. The advertisement also claimed that travellers could “contribute to a greener future” by choosing the airline’s “eco tickets”. The claims were found to be vague and unsubstantiated.

The Competition and Consumer Commission of Singapore (CCS) has not acted against any businesses for unsubstantiated sustainability claims relating to products or services. In October 2025, CCS issued its new guide on quality-related claims (including environmental or sustainability-related claims) to help businesses communicate clearly and accurately about the qualities, uses and benefits of their products and services, including environmental or sustainability-related claims. These guidelines follow a 2022 review by CCS that found that over half of the environmental claims made online lacked clarity or sufficient evidence. Many relied on technical terms or ambiguous language that the average consumer would struggle to understand.

To our knowledge, no test cases have been brought against businesses for unsubstantiated enterprise-wide
sustainability commitments.

In February 2026 however, a complaint was lodged with the Singapore Exchange against a Singapore bank for potentially failing to comply with sustainability reporting requirements, specifically pertaining to the lack of disclosures around the bank’s exposure to captive coal plants. According to the Australian-based environment group that lodged the complaint, the bank did not provide complete information material to investors, including the true extent of its exposure to carbon-intensive companies that are powering their operations with off-grid coal plants, which are known as captive coal plants. Neither did the bank disclose the material transition risk this exposure poses to it.

Liability may attach under the Consumer Protection (Fair Practice) Act 2003 or Securities and Futures Act 2001 for false and misleading claims. Liability may also attach in a tortious or contractual context for false or misleading statements about enterprise-wide sustainability commitments.

There is no explicit statutory duty on directors to oversee environmental and social impacts, but pursuant to the directors’ duty under the Companies Act 1967 to act honestly and use reasonable diligence in the discharge of their duties, directors may be expected to manage these impacts where material to their company’s interest.

To our knowledge, there have not been any test cases against directors presenting misleading information on environmental and social impacts.

Financial institutions and large or listed corporates are not required to report against sustainable investment criteria. The Singapore-Asia Taxonomy for Sustainable Finance was launched in December 2023, but reporting against the taxonomy has so far been voluntary and the Monetary Authority of Singapore has started to assess the extent to which the taxonomy has been adopted by financial institutions.

Directors have a duty under the Companies Act 1967 to act honestly and with reasonable diligence in the discharge of their duties. This may include a duty to disclose climate related financial risks that are material to the company. They may also consider whether the financial statements laid before the company at its annual general meeting give a true and fair view of the financial position and performance of the company, which in some cases may require how climate related financial risks may impact the financial position and performance of the company.

More explicitly, companies listed on the Singapore Exchange are in phases being required to, and from FY 2030 large unlisted companies will be required to, submit climate reports incorporating the climate-related disclosures in the International Sustainability Standards Board standards, which inter alia require companies to report how they manage climate-related risks and opportunities.

Companies that are in prescribed sectors and whose annual energy consumption cross the prescribed threshold are required under the Energy Conservation Act 2012 to report on prescribed information on their energy usage information.

There is no statutory requirement for businesses to specifically report on pay gaps between genders and across EDI metrics

That said, the Code imposes general requirements on listed companies to disclose their remuneration policies and remuneration amounts of selected personnel on a comply-or-explain basis. Principle 8 of the Code provides that a listed company’s board must be transparent on (i) its remuneration policies; (ii) level and mix of remuneration; (iii) procedure for setting remuneration; and (iv) the relationships between remuneration, performance and value creation. More specifically, Provision 8.1 of the Code requires listed companies to disclose the policy and criteria for setting remuneration, as well as the names, amounts and breakdown of remuneration of selected individuals (i.e., each individual director, CEO, and at least top five key management personnel (who are not directors or CEO) in its annual report.

More generally, there are legal obligations to address workplace discrimination and promote diversity across EDI factors and gender even in the absence of reporting requirements. These include the mandatory requirement under the Mainboard Rules for listed companies to maintain a board diversity policy that addresses gender and any other relevant aspects of diversity, as well as the Guidelines and Workplace Fairness Act 2025 which also apply to unlisted companies.

There is no statutory responsibility to report on modern slavery in the supply chain. There is however a responsibility for companies listed on the Singapore Exchange, who are required to submit sustainability reports, to review their businesses in the context of their value chains and determine what ESG factors in relation to the companies’ interaction with their physical environments and social communities and their governance, are material for the continuity of their businesses. In some cases, this could include modern slavery issues in their supply chain.

Beginning in FY 2025, requirements are being phased in for companies listed on Singapore Exchange to submit annual climate-related disclosures aligned with the International Sustainability Standards Board standards. The Competition and Consumer Commission of Singapore has also published its guidelines on quality-related claims. The Singapore-Asia Taxonomy has also been published since December 2023. Though its adoption remains voluntary, the Monetary Authority continues to encourage its adoption by financial institutions to define credible transition and reduce the risk of green and transition washing. This means we may see greater scrutiny on companies’ climate-related disclosures or consumer-related environment or sustainability-related claims.

With rising carbon tax rates, and the coming into force of a number of foreign ESG legislation with indirect extraterritorial impact on supply chains, we may also see a growing interest in ESG-related projects and transactions, such as carbon credit generating projects, greenhouse gas emission reduction or removal offtake agreements and renewable power purchase agreements, may also give rise to more disputes in such projects and transactions, though they may not necessarily end in litigation.