SSM Wants ESG Reporting in the Companies Act. The Line Is RM15 Million.
15 September 2026 · Ecotabi Team
You already read our piece on GRI versus IFRS versus SEDG. Now there's another acronym to worry about? Fair question.
Here's the honest answer: this one's different, and it's worth five minutes even if nothing changes for you tomorrow.
It's a proposal, not a law — say that plainly
Nothing here is confirmed. What exists is a consultative document, published by the Companies Commission of Malaysia (SSM) — not the Securities Commission (SC) that publishes SEDG, a different regulator entirely. Public comments closed on 2 June 2026. No bill has reached Parliament, and there's no confirmed date for when — or if — one will.
So if you were hoping this article tells you a new law just landed: it didn't. But something did happen on 3 August 2026 — SSM's CEO, Datuk Nor Azimah Abd Aziz, stood up at the National Climate Governance Summit and reaffirmed this is where the Commission is heading. That's a regulator repeating its own proposal in public, months after the consultation closed, not letting it quietly drop. Worth paying attention to, even at proposal stage.
Why this one's actually different from what we already covered
Our last article walked through GRI, IFRS S1/S2, TCFD, NSRF and SEDG — all of it either aimed at Bursa Malaysia-listed companies, or voluntary for everyone else.
This proposal targets something none of those reach: non-listed companies — SSM's own term for it is NLCos. Ordinary private Sdn Bhds, not stock-exchange issuers. If this becomes law, it would be the first time sustainability reporting gets written directly into company law for businesses that never had anything to do with Bursa Malaysia in the first place.
That's the part worth remembering, even more than the specific numbers below.
The actual thresholds
SSM's document proposes a phased rollout by revenue or employee count — whichever a company hits first:
| Revenue or headcount | Phase 1 | Phase 2 |
|---|---|---|
| RM1 billion–RM2 billion, or 500+ employees | 2028 | 2029 |
| RM100 million–RM1 billion, or 250–499 employees | 2030 | 2031 |
| RM15 million–RM100 million, or 100–249 employees | 2032 | 2033 |
| Below RM15 million and under 100 employees | Not required — voluntary opt-in only |
RM15 million revenue, or 100 employees, is where the proposal draws its line. Below that, SSM's own document says you'd stay voluntary — and if you choose to opt in anyway, you'd be expected to follow the requirements in full, not a lighter version of them.
Where that actually leaves most Ecotabi readers
If your revenue is under RM15 million and you're under 100 employees: this proposal, as written, doesn't put a mandatory obligation on you. We won't tell you otherwise to manufacture urgency — that's not what the document says.
Two things are still worth knowing, though.
First, if you're close to that line — growing toward RM15 million, or adding headcount — 2032 sounds distant, but building a reporting process from nothing takes longer than most owners expect. The SMEs who start early are rarely the ones scrambling later.
Second, we've written before about how large companies start collecting supplier data well ahead of their own compliance deadlines, because reaching hundreds of suppliers takes time. If a customer of yours crosses one of these thresholds — say, the RM1 billion band with a 2028 start — don't be surprised if a data request from them arrives years before 2028, regardless of what your own threshold says.
So — does this change anything today?
For most readers: no, not today, and not on any date anyone can currently confirm. This is a proposal that a regulator has chosen to keep talking about, not a law.
What it does change is this: for the first time, SSM has put real numbers and real years next to "non-listed companies will eventually need to report." That's a more concrete signal than "ESG is coming" has ever been in Malaysia. Worth knowing where you'd land if it firms up — and worth remembering that SEDG already gives you a way to start whenever you're ready, whether a law eventually requires it or not.
ESG-lah is a self-guided ESG reporting platform for Malaysian SMEs, built in accordance with the Simplified ESG Disclosure Guide (SEDG). If Companies Act reporting ever does reach your threshold, starting with SEDG now means you're not building a reporting process from zero later. Free to start — upgrade only if you need advanced features.
Sources: Companies Commission of Malaysia (SSM), Consultative Document on the Proposed Amendments to the Companies Act 2016 [Act 777] on Sustainability Reporting (30 April 2026, primary source, thresholds and phases per Table 3); SSM CEO Datuk Nor Azimah Abd Aziz remarks at the National Climate Governance Summit 2026 (The Sun, 3 August 2026).