Insights · Banking

Three Climate Reporting Duties for Malaysian Banks, and Why They Aren't Unique to Malaysia

Published 11 October 2026 · First published by ESG Disclose on LinkedIn, 9 October 2026

Malaysia's banks have three climate reporting duties. Each one is a major data collection exercise in its own right, and all three run on the same data: their borrowers'.

Duty 1: Manage Climate Risk

Bank Negara Malaysia's Climate Risk Management and Scenario Analysis policy covers banks, Islamic banks, insurers and takaful operators, and has applied in full since 31 December 2024. It expects climate risk to be built into governance, scenario analysis, metrics and targets, and disclosure.

The data behind it: exposures by sector and location, borrower emissions and transition plans, hazard data and scenario assumptions, refreshed every year.

Duty 2: Classify the Loan Book

Under BNM's Climate Change and Principle-based Taxonomy (CCPT), every non-retail exposure is classified and reported to BNM, from C1 (climate supporting) through C2 and C3 (transitioning) to C4 and C5 (watchlist).

The data behind it: evidence against each guiding principle, for every non-retail borrower, at origination and in every reporting cycle.

Duty 3: Disclose to Investors

The National Sustainability Reporting Framework (NSRF) uses IFRS S1 and S2 as its baseline, phased in by group: Main Market issuers with a market capitalisation of RM2 billion or more from FY2025, other Main Market issuers from FY2026, and ACE Market and large non-listed companies from FY2027. Assurance of Scope 1 and 2 emissions under ISSA 5000 follows from 2028 for the largest issuers, after a one-year deferral announced in September 2026.

The data behind it: financed emissions across the loan book, with every figure traceable for assurance.

Three duties, one massive data collection job. Most of that data doesn't sit inside the bank. It sits with borrowers, and it has to be requested, checked and evidenced again every year.

Malaysia Is Not Alone

These duties aren't unique to Malaysia. Different regulators have written different rulebooks, but the challenge is the same: credible evidence from borrowers, every year.

MarketStatusWhat applies to banks
UAEIn forceCBUAE Circular C 8/2025 on climate-related financial risk, for banks and insurers, in force since 8 July 2025
KuwaitIn forceBanks asked by the Central Bank of Kuwait since 2022 to publish a sustainability report and to build climate risk into capital planning (ICAAP)
SingaporeIn forceMAS environmental risk management guidelines, with a transition-planning addendum in March 2026
United KingdomIn forcePRA SS5/25 on managing climate-related risks
European UnionIn forcePillar 3 ESG risk disclosures for all banks from 2025
PakistanPhasing inState Bank of Pakistan climate risk framework: board-approved plans due by 30 September 2026, full compliance by 30 June 2029, and a first climate stress test by the end of Q3 2026
QatarFrom FY2026QCB sustainability reporting framework for financial institutions
GlobalVoluntaryBasel Committee climate disclosure framework for banks (June 2025)

Status as at October 2026; confirm applicability with your advisers.

Why One Governed Data Set Wins

For a bank operating across several of these markets, the same borrower may be asked for the same evidence by different teams, for different regulators, in different formats. That is expensive for the bank and frustrating for the borrower, and it produces numbers that do not reconcile.

The alternative is to collect each borrower's data once, govern it once, and map it to every framework that needs it: one owner per figure, one approved method, evidence attached at source, and a full trail from the loan to the disclosure. That is how ESG Disclose approaches banking clients, and it is what turns three duties from three separate exercises into one.

How is your bank collecting borrower data today, and how many times is it asking for the same thing?

Sources: Bank Negara Malaysia, Climate Risk Management and Scenario Analysis policy and CCPT; Securities Commission Malaysia (NSRF and the September 2026 assurance deferral); CBUAE; Central Bank of Kuwait; MAS; PRA; EBA; State Bank of Pakistan (SH&SFD Circular No. 07 of 2025; FSD Circular No. 01 of 2025); QCB; Basel Committee.

Author & ESG / AI Governance Advisor

Across genres and disciplines, the same instrument recurs: a record that survives suppression, a silence that finally speaks, a ledger made to answer for itself. Nadeem Shakoor writes and advises from the conviction that these are not separate practices: they are one discipline, applied at different registers.

— N. Shakoor