Sustainability reporting is a duty for companies listed on Bursa Malaysia's Main Market or ACE Market, and for non-listed companies with annual revenue of RM2 billion and above. The Main Market is Bursa's board for larger companies, and the ACE Market is for smaller, growing ones. If that is you, keep three waste figures by weight. They are waste generated, waste diverted from disposal and waste sent to disposal. Diverted means reused, recycled or recovered another way. The table below shows when your group reports.
A supplier has no duty of its own. A listed customer may still ask you for the same figures. Not sure which you are? Start with what ESG (environmental, social and governance) means for a Malaysian business.
Your reporting group sets when each duty starts
The dates come from the National Sustainability Reporting Framework, published in September 2024. Listed companies already publish a Sustainability Statement. The table shows when it must follow the framework. Each year means a financial year beginning on or after 1 January.
Three terms in the table need a plain meaning. Scope 3 counts emissions you cause but do not control, like the gas your landfilled waste gives off. Scope 1 and 2 cover the fuel you burn and the electricity you buy. Assurance means an independent auditor checks your reported figures.
| Reporting group | Reporting starts | Scope 3 falls due | Assurance aim |
|---|---|---|---|
| Main Market, market capitalisation of RM2 billion and above | 2025 | 2027 | 2027, Scope 1 and 2 only |
| Other Main Market companies | 2026 | 2028 | 2028, Scope 1 and 2 only |
| ACE Market, and non-listed with revenue of RM2 billion and above | 2027 | 2030 | 2029, Scope 1 and 2 only |
Three notes help you read it. The reliefs and the assurance dates are in Tables 3 and 4 of the framework document.
- Scope 3 is where the emissions from your waste sit. It covers emissions in your value chain. The GHG Protocol, a widely used global rulebook for counting carbon emissions, lists waste generated in operations as Category 5.
- Scope 3 can wait at first. You may leave it out for your first two years of reporting, or three in the last group, unless your regulator already asks for a category. In those years you may report on climate matters only.
- Assurance is an aim, not yet a rule. The dates are subject to consultation. They cover Scope 1 and Scope 2 emissions only. The framework sets no date for anyone to assure your waste figures.
The waste figures to keep are three totals by weight
The GRI (Global Reporting Initiative) standards are a common rulebook for sustainability reports. Their waste standard, GRI 306, asks for waste generated, waste diverted from disposal and waste directed to disposal. Each is a total weight in tonnes. It lists incineration with energy recovery under disposal.
Bursa Malaysia's Sustainability Reporting Guide (3rd edition, 2022) uses the same split. Its waste indicator, C10(a), is total waste generated, broken down into waste diverted from disposal and waste directed to disposal, in metric tonnes. The guide is guidance. The rule behind it changed in December 2024, as a later section explains.
| Figure | What it counts | Where it is asked for |
|---|---|---|
| Waste generated | Total weight, broken down by what the waste is | GRI 306-3 |
| Diverted from disposal | Reused, recycled or recovered another way | GRI 306-4 |
| Directed to disposal | Landfilled, or incinerated with or without energy recovery | GRI 306-5 |
| Hazardous and non-hazardous | Each totalled on its own | GRI 306-4 and 306-5 |
| Earlier years | This year, then one and two years back as you build them | Bursa Practice Note 9, part of its Main Market rules |
Your Scope 3 figure is worked out from the same tonnes. So one set of weighed records serves both.
Does your group run many sites? One contract across every site puts every site's weights in one report.
One real quarter shows the split with a weight on every line
These figures are real. They come from a GarGeon report for a retail mall client for Q2 2026, April to June. It is published with the client's permission. Our homepage shows the same quarter's tonnes, recycling rate and carbon estimate.
| Line | Q2 2026 |
|---|---|
| Generated: all that we collected | 111.51 t + 5.33 t = 116.84 t |
| Diverted from disposal: recycled | 5.33 t |
| Directed to disposal: landfilled | 111.51 t |
That is a recycling rate of 4.6% for the quarter. Every collection was weighed and photographed.
Bursa moved its rules onto IFRS S1 and S2 in December 2024
IFRS S1 and IFRS S2 are two international reporting standards. S1 covers sustainability in general, and S2 covers climate. On 23 December 2024 Bursa Malaysia amended its Listing Requirements to match the framework. The IFRS Foundation's profile of Malaysia records the change. Practice Note 9 of the Main Market rules now says the Sustainability Statement must be prepared under IFRS S1 and IFRS S2. Guidance Note 11 says the same for the ACE Market.
That changed the standing of the waste indicator. Bursa had scheduled it for Main Market annual reports for financial years ending on or after 31 December 2024. Practice Note 9, as at 31 December 2024, marks the annexure that listed the common indicators as deleted. That annexure, an attachment to the rules, was Bursa's list of standard figures, waste among them.
Practice Note 9A holds the transition rules. Ask your company secretary which of them apply to your financial year. Whatever the answer, keep the split. GRI uses it, Bursa's guide uses it, and Scope 3 needs the tonnes.
Once the climate-only years end, IFRS S1 asks for material information on your other sustainability risks and opportunities. Material means it matters enough to change an investor's view of your business. Waste counts if it is material to your business.
Were you working towards TCFD-aligned disclosures? TCFD is an international set of recommendations for reporting climate risks. That work carries over. The Securities Commission says the TCFD recommendations are fully embedded in the IFRS climate standard.
A reviewer will ask for six things
Practice Note 9 asks you to state whether the statement had an internal review by your internal auditor, or independent assurance. Whoever checks your waste figures will look for these:
No weights yet? Start with a waste audit. For the record to keep on every pickup, read waste data for ESG reports.
A supplier may be asked for the same figures
A listed company's Scope 3 covers its value chain, and you are part of it. So a listed customer may ask for your waste weights and where the waste went. The framework itself puts no duty on you.
The site rules are a separate matter. For the collector's licence or approval, and separation at source, use the 2026 waste compliance checklist.
GarGeon supplies the weighed record behind each figure
GarGeon works through licensed collectors across KL, Selangor & Johor. Each pickup record carries a photo, a timestamp and the weight. You get a monthly or quarterly report, and waste data exported in a form you can use in GRI, SASB or TCFD reports. All three are international frameworks for sustainability reporting.
See what our sustainability data service covers. Or follow the six steps to build a waste system for ESG.
