What does NSRF leave undefined for builders?

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NSRF Mandates Disclosure Without Defining Calculation Methodologies

The NSRF requires publicly listed construction firms to disclose sustainability information but does not specify the methods for calculating carbon emissions. This leaves builders without clear guidelines on which emission factors to use, which on-site construction activities to include in their reports, or the specific methodology that should govern the final reported figures. Consequently, companies can produce compliant reports with vastly different carbon numbers, as the framework dictates what to report but not the precise meaning of the numbers themselves.
Lack of Standardised Carbon Accounting Framework

Malaysia's construction sector currently lacks a localised, standardised carbon accounting framework for on-site emissions. While the Illustrative Sustainability Report provided a model for disclosure in October 2025, it did not furnish the industry with the necessary data or protocols to populate these reports accurately. This absence of a structured system means that the carbon figures within these reports are often modelled rather than precisely measured, particularly for Scope 3 emissions which represent a significant portion of the industry's carbon footprint.
Ambiguity in Emission Factor and Activity Scope

The NSRF mandates disclosure but remains silent on critical details such as the specific emission factors construction firms should employ. Furthermore, it does not define which on-site activities, such as fuel combustion from machinery or waste disposal, need to be accounted for in these reports. This ambiguity means that two construction firms of similar size and operational scope could report substantially different carbon figures, yet both remain compliant with current NSRF requirements.
Reliance on Modelled Data and International Benchmarks

A significant issue identified is the heavy reliance on modelled data and international benchmarks due to a lack of comprehensive local data. CIDB’s Embodied Carbon Inventory, the sector’s primary reference, consolidates data from various sources but has limitations in its local applicability. When local data is unavailable, the inventory defaults to international figures, which may not accurately reflect Malaysian manufacturing conditions and energy mixes, leading to potential inaccuracies in reported emissions.

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What does NSRF leave undefined for builders?

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