Top 5 Carbon Emission Reporting Errors Committed by Publicly Listed Companies in Malaysia and Singapore

The focus on ESG-related issues has increased in recent years, with a shifted focus towards the environment. Around the world, regulators, investors, and consumers are requesting companies to measure and disclose their carbon emissions. Companies are under increased scrutiny on their climate reports amid allegations of greenwashing. 

Starting in the year 2023, listed companies in Singapore will be obliged to report their carbon emissions in accordance with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations on a ‘comply or explain’ basis. In Malaysia, Bursa will require all listed companies to provide climate change-related disclosures that are aligned with the TCFD recommendations.

TCFD, along with the Greenhouse Gas (GHG) Protocol are the gold standard of frameworks used to measure, manage and disclose carbon emissions. However, due to the lack of climate-specific knowledge, expertise and relevant tools, many companies are unequipped to correctly measure, manage and report their carbon emissions. 

To test the accuracy and effectiveness of Pantas carbon management software, we utilize our software to analyze the publicly disclosed climate data and reports of publicly listed companies in Malaysia and Singapore. To our surprise, we were able to identify and verify multiple errors committed by these companies in their climate reporting. We shared our findings with The Business Times Singapore, which was able to verify these errors. Our goal in identifying and sharing these common errors is to help companies improve their climate disclosure and build trust and credibility through transparent and accurate reporting. As companies begin their decarbonisation journey, we want to ensure that they are able to respond to rising environmental concerns, take science-based environmental action and avoid greenwashing. 

A company’s GHG emissions are classified into three scopes. Scope 1 is direct emissions that come from resources that are owned and controlled by the company. Scope 2 emissions are indirect emissions mainly from electricity purchased and used by the company. Scope 3 emissions are all other indirect emissions from activities of the company, occurring from sources that it does not own or control (value chain emissions). 

Below are the top 5 common mistakes committed by publicly listed companies in Malaysia and Singapore as identified and verified by Pantas software.

Error #1 – Excluding emissions from company-owned vehicles

Mobile combustion from company-owned vehicles and automobiles such as cars, trucks, forklifts, ships and vessels have to be included in Scope 1 reporting. This is especially relevant for companies within the logistics and manufacturing industry.

Error #2 – Incorrect usage of market-based method when calculating and disclosing Scope 2 emissions

Facilities located in areas that use electricity from the national grid and do not have an option with regards to their sources of electricity should use the location-based method to calculate and disclose their Scope 2 emissions. The market-based method should be used only if the company is provided with the choice of differentiated electricity products in the form of renewable energy certificates, green tariffs, etc. In Malaysia, unless a company has renewable energy certificates, it should employ the location-based instead of market-based method.

Error #3 – Including combustion of biomass in Scopes 1, 2 and 3 reporting

Combustion of biomass should not be accounted for under Scopes 1, 2 and 3 when reporting GHG emissions. This is because “emissions” from the usage of biomass are accounted for when the trees are cut, not when they are burned. However, emissions from the combustion of biomass can be included separately in the reporting.

Error #4 – “Negative” emissions or deducting avoided emissions associated with recycling

Based on the GHG Protocol, any claims of avoided emissions from recycling should not be included in, or deducted from, the Scope 3 inventory, but may instead be reported separately. In fact, recycling does not result in negative emissions as the act of recycling releases emissions into the atmosphere.

Error #5 – Using incorrect emission factors in GHG calculations

Calculating emissions using incorrect emission factors leads to errors in reporting as final emission and intensity metrics may be over- or under-reported. Therefore, emission factors used should be accurate and up-to-date to accurately reflect the company's activities. This is especially important for companies looking to develop an emissions baseline. 

How to avoid these common errors?

  1. Have a clear and in-depth understanding of the GHG Protocol, TCFD guidelines and relevant reporting requirements. 
  2. Diligently track climate data within the company and update all relevant emission factors regularly to keep them up-to-date as new data becomes available.
  3. Utilize a carbon management software that automates the carbon accounting and disclosure process.

Pantas carbon management software automates companies’ carbon accounting and disclosure processes. We assist companies in measuring, managing and disclosing GHG emissions seamlessly and grant companies access to green investment and Climate Transition financing.

Please reach out to Pantas to schedule a free diagnostics and analysis to determine the accuracy of your company’s climate reporting and see how we can help!


  1. Singapore Exchange: Sustainability Reporting (
  2. Bursa Malaysia: Bursa Malaysia Seeks Public Feedback on Enhanced Sustainability Reporting Proposals and Climate Related Disclosures (
  3. The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, page 27-29 (
  4. The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, page 27 (
  5. Greenhouse Gas Protocol Scope 2 Guidance, page 45, figure 6. (
  6. The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, page 25 (
  7. Greenhouse Gas Protocol: Technical Guidance for Calculating Scope 3 Emissions, page 78-79 (
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