Bursa Malaysia Sustainability Disclosure: The Waste Management Section Explained
~130 companies must report waste data under NSRF. Learn exactly what waste metrics Bursa requires, IFRS S1/S2 compliance timelines, and how to collect audit-ready data.
GarGeon Team
March 14, 2026
13 min read
Around 130 companies are now required to report under the National Sustainability Reporting Framework (NSRF) Group 1 — and waste management data is one of the sections most companies are least prepared for.
The requirements are clear. The deadlines are fixed. But the gap between what Bursa expects and what most companies can actually produce is enormous. Spreadsheets, WhatsApp messages, and paper-based landfill tickets do not meet the standard that external assurance providers will accept starting 2027.
This article explains exactly what waste data Bursa requires in sustainability disclosures, how waste disposal feeds into your Scope 3 carbon footprint, and what steps your company needs to take to produce audit-ready waste figures.
What Is the National Sustainability Reporting Framework (NSRF)?
The NSRF is Malaysia's mandatory sustainability reporting framework for listed companies. Developed by the Securities Commission Malaysia in collaboration with Bursa Malaysia, it is based on two international standards:
- IFRS S1 — General Requirements for Disclosure of Sustainability-related Financial Information
- IFRS S2 — Climate-related Disclosures
All Bursa-listed companies must report through Bursa Malaysia's Centralised Sustainability Intelligence (CSI) platform. The framework replaces the previous voluntary sustainability reporting guidelines with mandatory, standardised disclosures that will require external assurance.
NSRF Implementation Timeline
The rollout is phased by company size:
| Group | Companies | Reporting From | Assurance From |
|---|---|---|---|
| Group 1 | Main Market, market cap > RM2 billion (~130 companies) | January 2025 | 2027 (limited), then reasonable |
| Group 2 | Remaining Main Market companies | January 2026 | 2028 |
| Group 3 | ACE Market + Non-Listed Companies with revenue > RM2 billion | January 2027 | 2029 |
Transition relief: For the first two reporting periods, companies may limit disclosures to climate-related information only. But waste data — as a material topic under IFRS S1 and as part of Scope 3 emissions under IFRS S2 — falls squarely within these requirements.
Where Waste Management Fits in Sustainability Disclosures
Waste management appears in two distinct places within the NSRF framework:
1. IFRS S1 — Material Topic Disclosure
Under IFRS S1, companies must identify and disclose sustainability-related risks and opportunities that could reasonably be expected to affect their financial position. For most manufacturing, retail, hospitality, and property companies, waste is a material topic that requires dedicated disclosure.
2. IFRS S2 — Scope 3 Emissions (Category 5)
Under IFRS S2, companies must disclose greenhouse gas emissions across all three scopes. Scope 3 Category 5 — "Waste generated in operations" — captures the carbon emissions from how your company disposes of waste. Every tonne sent to landfill generates methane emissions that must be calculated and reported.
This means waste data is no longer optional for listed companies. It is a mandatory reporting requirement with assurance obligations.
Waste Metrics Bursa Expects
The specific waste metrics required in sustainability disclosures include:
| Metric | Detail Required |
|---|---|
| Total waste generated | Measured in tonnes, covering all waste streams |
| Waste diverted from disposal | Recycling, composting, reuse — broken down by type and destination |
| Waste directed to disposal | Landfill, incineration — broken down by type and destination |
| Hazardous vs non-hazardous | Separate breakdown for each category |
| Waste intensity ratios | Per revenue, per employee, or per unit produced |
| Year-over-year comparison | Trend data showing improvement or deterioration |
These are not aspirational targets. They are disclosure requirements that auditors will verify.
Scope 3 Category 5 — How Waste Disposal Affects Your Carbon Footprint
This is where waste management directly impacts your company's reported carbon emissions — and potentially your carbon tax exposure.
The Methane Problem
When waste decomposes in landfills, it produces methane (CH4). Methane is 25 times more potent than CO2 as a greenhouse gas over a 100-year period. Malaysia's landfill infrastructure makes this particularly problematic:
- 82.5% of collected waste is still sent to landfills
- Only 15% (21 of 135) of Malaysia's landfills are sanitary — meaning they have methane capture systems
- 126 non-sanitary landfills are releasing methane directly into the atmosphere
- Malaysia generates 39,078 tonnes of solid waste daily
How Waste Disposal Method Affects Reported Emissions
The GHG Protocol provides the calculation methodology for Scope 3 Category 5 emissions. The disposal method you choose directly determines your reported carbon footprint:
| Disposal Method | Emission Impact |
|---|---|
| Landfill (no methane capture) | Highest emissions — methane released directly |
| Landfill (with methane capture) | Moderate emissions — partial methane recovery |
| Waste-to-energy | Lower emissions — energy offset credits apply |
| Recycling | Lowest / negative emissions — avoids virgin material production |
| Composting | Very low emissions compared to landfilling organic waste |
The equation is simple: More waste to landfill = more methane = higher reported Scope 3 emissions = higher carbon footprint.
Connection to Malaysia's Carbon Tax
Malaysia's carbon tax, confirmed at RM35-45 per tonne of CO2 equivalent from 2026, initially targets iron, steel, and energy sectors. But as ESG reporting requirements expand and carbon pricing evolves, companies with high Scope 3 waste emissions face growing financial exposure.
Companies that reduce waste-to-landfill volumes today will report lower Scope 3 emissions — positioning themselves favourably for both investor scrutiny and future carbon pricing mechanisms.
The Data Collection Challenge for Malaysian Enterprises
The NSRF requires data. Auditors require verified data. And most Malaysian enterprises do not have the systems to produce either.
Current State at Most Companies
- Spreadsheets and WhatsApp: Waste collection data tracked informally, if at all
- No composition data: Companies know they generate waste but not what kind or how much
- No end-destination verification: Recyclables are handed to collectors, but nobody confirms they actually reach recycling facilities
- No weight-based measurement: Volumes estimated rather than weighed
- Paper-based records: Landfill tickets filed in folders, not digitised
What Auditors Will Require
Starting 2027 for Group 1 companies, sustainability disclosures must undergo external assurance — first limited assurance, progressing to reasonable assurance. This means auditors will need:
- Verified weight data for all waste streams with clear audit trails
- Documentation of disposal destinations showing where each waste type ended up
- Calculation methodology for Scope 3 waste emissions aligned with GHG Protocol
- Year-over-year trend data demonstrating reporting consistency
- Evidence of data completeness covering all sites and all waste streams
Companies that rely on estimates, informal records, or unverified collector claims will not pass assurance.
Common Data Gaps
| Gap | Risk |
|---|---|
| No waste composition data | Cannot report waste by type or calculate accurate Scope 3 emissions |
| No diversion rate tracking | Cannot demonstrate waste management improvement |
| No end-destination verification | Assurance providers will flag unverified claims |
| Inconsistent measurement across sites | Multi-site companies report incomplete or contradictory data |
| No digital records | Paper trails do not meet assurance documentation standards |
Five Steps to Prepare Your Waste Data for Bursa Disclosure
Step 1: Establish Your Waste Baseline
You cannot report what you have not measured. Start with a comprehensive assessment of your current waste generation:
- What types of waste does your business generate? (General waste, recyclables, food waste, hazardous waste)
- How much of each type? (Weight-based measurement, not volume estimates)
- Where does it go? (Landfill, recycling facility, composting, waste-to-energy)
- What is your current diversion rate? (Percentage diverted from landfill)
This baseline becomes the foundation for all future reporting. Without it, you have no starting point and no way to demonstrate improvement.
Step 2: Implement Waste Tracking Systems
Move from estimates to verified data. Every waste collection should be recorded with:
- Weight (not volume)
- Waste type (material composition)
- Collection date and time
- Destination (specific facility, not just "recycler")
- Supporting documentation (weight tickets, receipts, certificates)
Digital tracking eliminates the spreadsheet chaos and creates the audit trail that assurance providers demand. Every pickup logged with weight, type, and destination creates records that auditors can verify.
Step 3: Verify End-Destinations
One of the most common compliance failures is claiming waste was recycled without verifying it actually reached a licensed recycling facility.
- Confirm your recycling partners are licensed and registered
- Request processing certificates or receipts showing material was actually recycled
- Cross-reference collected volumes against facility receipts
- Conduct periodic site visits to recycling partners
Under the Environmental Quality (Amendment) Act 2024, waste generators face penalties up to RM10 million. You are responsible for your waste even after it leaves your premises.
Step 4: Calculate Scope 3 Waste Emissions
Apply the GHG Protocol Scope 3 Category 5 methodology to your waste data:
- Categorise waste by type and disposal method
- Apply emission factors specific to each waste type and disposal method
- Calculate total emissions in tonnes of CO2 equivalent
- Document your methodology so auditors can replicate the calculation
The key variables: waste type (organic waste generates far more methane than inert materials), disposal method (landfill vs recycling), and whether the landfill has methane capture technology.
Step 5: Generate Audit-Ready Reports
Your sustainability disclosure needs documentation that withstands external assurance:
- Consistent reporting periods aligned with financial reporting
- Complete data coverage across all sites and waste streams
- Clear calculation methodology documented and repeatable
- Trend data showing year-over-year comparison
- Supporting evidence for all material claims
This is not a one-time exercise. Companies subject to NSRF must report annually, with improving data quality expected over successive reporting periods.
Supply Chain Impact — Non-Listed Companies Are Affected Too
You do not need to be listed on Bursa to be affected by the NSRF.
Scope 3 Data Flows Downstream
Listed companies are required to report Scope 3 emissions, which include emissions from their supply chain. That means they need waste management data from their suppliers, vendors, and service providers.
If you supply goods or services to a Bursa-listed company, expect to receive requests for:
- Your waste generation data
- Your waste disposal methods and destinations
- Your diversion rate
- Your Scope 3 waste emissions calculations
Procurement Requirements Are Changing
Companies unable to provide waste management documentation are increasingly excluded from tender processes. Major buyers now include sustainability data requirements in procurement evaluations. This is not limited to large contracts — even mid-sized suppliers are being asked for ESG credentials.
The Competitive Advantage
Companies that already have waste tracking systems and verified data in place will:
- Respond to tender requirements faster than competitors
- Demonstrate compliance readiness to listed customers
- Avoid last-minute scrambles when data requests arrive
- Build long-term relationships with customers who value supply chain transparency
Frequently Asked Questions
What is the NSRF and which companies must comply?
The National Sustainability Reporting Framework (NSRF) is Malaysia's mandatory sustainability reporting framework based on IFRS S1 and S2 standards. Group 1 (Main Market, market cap above RM2 billion — approximately 130 companies) reports from January 2025. Group 2 (remaining Main Market) reports from January 2026. Group 3 (ACE Market and large non-listed companies with revenue above RM2 billion) reports from January 2027. External assurance is required starting two years after each group's reporting commencement.
What waste data does Bursa require in sustainability disclosures?
Bursa requires total waste generated in tonnes, waste diverted from disposal (recycling, composting, reuse) broken down by type and destination, waste directed to disposal (landfill, incineration) by type and destination, hazardous versus non-hazardous waste classification, waste intensity ratios, and year-over-year trend data. All data must be weight-based and verifiable for external assurance.
How does waste disposal affect Scope 3 emissions reporting?
Waste disposal is classified under GHG Protocol Scope 3 Category 5 — waste generated in operations. When waste decomposes in landfills, it produces methane, which is 25 times more potent than CO2. Companies must calculate emissions using waste-type-specific emission factors multiplied by tonnes disposed, broken down by disposal method. Recycling and composting generate significantly lower emissions than landfill disposal.
When do assurance requirements start for sustainability reporting?
Assurance requirements are phased: Group 1 companies require limited assurance from 2027, progressing to reasonable assurance. Group 2 from 2028, and Group 3 from 2029. This means auditors will verify your waste data, methodology, and supporting documentation. Companies relying on estimates or informal records will not meet assurance standards.
Do non-listed companies need to comply with NSRF waste reporting?
Non-listed companies with revenue above RM2 billion fall under Group 3 (reporting from January 2027). Additionally, any company supplying goods or services to Bursa-listed firms may be asked to provide waste management data for Scope 3 emissions calculations. Companies that cannot provide verified waste data risk being excluded from supply chains and tender processes.
The Bottom Line
The NSRF is not just a compliance exercise. Companies that build proper waste tracking and reporting infrastructure gain three advantages: they meet regulatory requirements without last-minute scrambles, they reduce waste disposal costs through better diversion, and they strengthen their position in supply chains that increasingly demand sustainability data.
The timeline is fixed. Group 1 companies are already reporting. Group 2 starts January 2026. Assurance requirements begin 2027. Every month without proper waste data systems is a month closer to a compliance gap that gets harder to close.
The companies that treat waste data as operational infrastructure — not a reporting afterthought — will have the audit-ready documentation, the verified partnerships, and the competitive edge that compliance-driven competitors will scramble to build under deadline pressure.
Ready to Get Audit-Ready Waste Data?
GarGeon provides waste collection, disposal, and recycling services for Malaysian enterprises — with the data infrastructure needed for Bursa-ready sustainability reporting.
References
Regulatory Sources:
- Securities Commission Malaysia — NSRF — National Sustainability Reporting Framework
- Bursa Malaysia Sustainability — CSI platform and reporting requirements
- MIDA — Turning Waste into Wealth — Circular Economy Blueprint data
Standards:
- IFRS S1 — General Sustainability Disclosures — IFRS Foundation
- GHG Protocol — Scope 3 Category 5 — Waste generated in operations methodology
Related Reading:
Need help managing your business waste compliance?
GarGeon provides reliable, eco-friendly waste management solutions across Malaysia to help you avoid penalties and meet ESG goals.
Get a Free Compliance ConsultationGarGeon Team
Waste Management Specialists
Team of waste management and sustainability professionals serving Malaysian enterprises.
