How can two identical Malaysian firms report vastly different carbon figures yet comply?

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Two identical Malaysian firms can report vastly different carbon figures while remaining compliant because the NSRF requires sustainability disclosure but does not standardise how construction carbon is calculated.

Malaysia’s National Sustainability Reporting Framework (NSRF) mandates disclosure of sustainability reports, but it does not specify which emission factors, on-site activities, or carbon accounting methodology must be used to derive the carbon number shown in those reports. With no structured and standardised carbon reporting mechanism for Malaysian construction, firms can follow different approaches and still meet the disclosure requirement.
The NSRF requires disclosure without fixing the calculation rules
The NSRF requires sustainability reporting, yet it does not set the emission factors that must be used for carbon figures, nor does it define which construction on-site activities need to be included. It also does not prescribe the methodology governing how the final number is produced. As a result, the framework tells firms what to disclose, but not what the disclosed carbon figure must mean in a consistent, comparable way.
Malaysia lacks a localised carbon accounting framework for construction
Malaysia’s construction sector has no localised carbon accounting framework, and there is no standardised protocol for on-site emissions quantification. The Illustrative Sustainability Report aligned to the NSRF, released as a model for October 2025 disclosure, can show what to publish, but it cannot supply the data or standardised basis needed to populate the reports. This creates room for different carbon calculations across firms even when they are similar in size and activity.
Scope 3 disclosure can differ because it is often modelled rather than measured
In Malaysia’s 2023 reporting cycle, only 11 per cent of publicly listed companies disclosed any Scope 3 emissions, compared with 39 per cent across Asia-Pacific. Scope 3 is described as where construction’s real carbon footprint sits, including embodied carbon in steel, concrete, and glass, as well as emissions from subcontractors and logistics. Where Scope 3 figures are included, they are described as largely modelled and possibly limitedly measured, which can produce very different reported totals depending on assumptions and data quality.
Even sector tools still leave firms with estimates unless data is audited
Bursa Malaysia’s CSI platform is used by more than 130 companies and provides Scope 3 emissions estimates through modelled supplier engagement tools. Its FAQ states that the Scope 3 data generated is an estimate and does not absolve organisations from their duty to get the data audited. Because the NSRF does not standardise the underlying carbon calculation basis, firms can end up using different data inputs—modelled estimates versus audited or primary data—and still remain compliant with the disclosure requirement.

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How can two identical Malaysian firms report vastly different carbon figures yet comply?

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