On 6 November 2025, the ASEAN Capital Markets Forum (“ACMF“) released the ASEAN Simplified ESG Disclosure Guide (ASEDG) for SMEs in Supply Chains Version 2 (“ASEDG Version 2“), a voluntary tool which sets out a simple and standard set of 38 Environmental, Social, and Governance (“ESG“) disclosures to track and report.
The ASEDG is targeted to help:
- Small-medium enterprises (“SMEs”) in supply chains who need to report on ESG disclosures. Such disclosures may be voluntary; by request from customers, investors and financiers; for the SME’s inclusion in indices; or to qualify for incentives.
- Stakeholders, such as large companies with supply chains or financial institutions, who wish to set ESG disclosure requirements for their SME suppliers or customers.
Version 1 of the ASEDG was published in April 2025, followed by a five-month stakeholder consultation. Key changes made in ASEDG Version 2 are set out in its Annex 2. For more information on Version 1, please refer to our April 2025 Legal Update titled “ACMF Publishes ASEAN Simplified Guidance to Help ASEAN SMEs in Supply Chains with ESG Disclosures“.
Key Features of the ASEDG
The ASEDG Version 2 covers 15 topics across the three ESG pillars. Under each topic, it provides different levels of recommended disclosure, categorised into Basic, Intermediate or Advanced. These categories cater to different levels of sustainability maturity (not company size).
Environmental
- Emissions: Report Scope 1 (direct), Scope 2 (indirect), and relevant Scope 3 (other indirect) greenhouse gas emissions, as well as reduction initiatives and intensity metrics.
- Energy: Disclose total energy consumption (renewable and non-renewable), including from purchased electricity, heating, cooling and steam, and reductions from efficiency initiatives.
- Water: Report total water withdrawn by source and reductions achieved.
- Waste: Disclose total waste generated, diverted, and disposed, as well as breakdown by hazardous/non-hazardous categories and by disposal or recovery streams.
- Materials: List materials used (by weight) for production and packaging, and percentage of recycled input materials for production.
Social
- Human Rights & Labour: Report incidents of child/forced labour and risk assessments of operations and suppliers.
- Employee Management: Disclose training hours, turnover rates, and compliance with minimum wage laws.
- Diversity, Equity & Inclusion: Report workforce and board diversity by gender and age.
- Occupational Health & Safety: Disclose fatalities, injuries, and health/safety training.
- Community Engagement: Report community investments and operations with negative impact on local communities.
Governance
- Governance Structure: Report board composition and governance committees.
- Policy Commitments: List key policies (e.g. Code of Conduct, Anti-Corruption, Whistleblowing, Health & Safety).
- Risk Management and Reporting: Disclose the latest audited financial report, as well as risks assessment (e.g. regulatory compliance risk, business continuity risk, and climate-related risks) across business strategy, operations and finance.
- Anti-Corruption: Report incidents, training, and risk assessments.
- Customer Privacy: Disclose substantiated complaints about privacy/data breaches.
While useful, the ASEDG is not comprehensive – for instance, it does not cover the strategic adoption of sustainability, assessment and mitigation of risks, and identification of business opportunities. SMEs are expected to exercise discernment and diligence in relying on the ASEDG to the extent that it aligns with their respective business operations and activities as well as ESG risk profiles.
Singapore enterprises embarking on sustainability governance and ESG implementation in their supply chain can tap on our ESG legal fee subsidy for sustainability related legal advisory under the Sustainability Legal Catalyst Programme with Enterprise Singapore. Terms and conditions apply. You can reach out to us at [email protected].
Click on the following link for more information:
- ACMF webpage titled “ASEAN Simplified ESG Disclosure Guide (ASEDG) for SMEs in Supply Chains” (available on the ACMF website at www.theacmf.org)
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