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IFRS S2 for Thai Listed Companies: How SET50 and SET100 Firms Can Get Scope 1 and 2 Data Ready for Assurance

Thailand’s SEC has kept its ISSB approach in news release 298/2568. The first phase is climate-first reporting, with Scope 1 and Scope 2 greenhouse gas emissions that must be verified. This guide sets out what is confirmed, which index lists define each group, who may verify, and a data-readiness checklist covering ERP activity data, TGO emission factors, evidence and internal controls.

12 Oct 20268 minSEC Thailand
IFRS S2ISSBScope 1 Scope 2GHG Verification56-1 One ReportESG

Thailand's SEC has confirmed that listed companies will disclose sustainability information under IFRS S1 and S2. The first phase is climate-first: companies disclose Scope 1 and Scope 2 greenhouse gas emissions, and those figures must be verified. The first group is companies in the SET50 at the December 2026 index review, followed by the SET100 at the December 2027 review.

This guide is for sustainability managers, CFOs, company secretaries, IR teams and internal auditors. On 12 October 2026 we read SEC news release 298/2568, the SEC One Report page, and two pages from Thailand's Greenhouse Gas Management Organization (TGO): its corporate carbon footprint (CFO) emission factors and its list of verification bodies. Below we separate what is confirmed from what is still pending, and what you can prepare now.

Thai dates in SEC documents use the Buddhist Era. 2568 is 2025, 2569 is 2026 and 2570 is 2027.

What has the SEC confirmed?

The principles are confirmed, while the detailed notifications are still being updated. News release 298/2568, dated 28 November 2025, says that after its public consultation the SEC kept the ISSB approach and revised only the start dates, which the Capital Market Supervisory Board approved in November 2025.

Item Status under release 298/2568
Standards IFRS S1 and IFRS S2 from the ISSB
First-phase scope Climate-related reporting first, which the SEC calls "Climate-first reporting"
Greenhouse gases Scope 1 and Scope 2 disclosure
Verification Data must be verified to a credible standard
Start Phased-in, with transition reliefs
Where it goes Form 56-1 One Report-S or related documents
Still pending Notifications and documents the SEC is updating, to be announced when done

The ISSB issued IFRS S1 and S2 on 26 June 2023. S1 sets general requirements for sustainability disclosure, and S2 sets specific climate-related disclosures used together with S1. If you want a refresher on how ISSB relates to other frameworks, read the difference between sustainability and ESG.

Which companies are covered, and which index list applies?

The SEC groups companies by SET index membership. The SET50 group is companies in the SET50 at the December 2026 review, and the SET100 group is companies in the SET100 at the December 2027 review.

A note in the release lists who is covered: Thai companies and foreign companies with shares traded on the SET, companies making an IPO, REITs, infrastructure trusts, property funds and infrastructure funds. Non-listed companies and companies on the LiVE Exchange are not covered.

The release shows the reporting and filing year for each group as an image table, so we do not restate the years here. Check the table in SEC news release 298/2568 directly and watch for the updated notification. As of this writing (12 Oct 2026), the December 2026 index review has not happened yet, so companies near the SET50 cut-off should prepare as if they are already in scope.

Who can verify?

The SEC allows two routes: a corporate carbon footprint verifier registered with TGO, or another verifier, provided the verification follows international standards.

TGO's list of organisation-level verification bodies showed 24 legal entities on 12 Oct 2026. Each entry gives a registration date, an expiry date and the sectors it may verify, such as general manufacturing, transport or mining. Before you choose a verifier, check three things.

  1. Its registered sectors match your business.
  2. Its registration does not expire during your verification period.
  3. If the verifier is not on the TGO list, ask which international standard it verifies against.

The SEC also publishes a greenhouse gas reporting guide for listed companies on its One Report page. Part one covers disclosure in Form 56-1 One Report. Part two covers preparing, verifying and certifying a corporate carbon footprint. Your team should read it before talking to verifiers.

How should you use the January 2026 TGO emission factors?

Use them as the multiplier for activity data, and record every time which file and which item number you used. TGO's Emission Factor (CFO) page currently shows a file called Emission Factor CFO (January 2026, มกราคม 2569) with 153 items, covering stationary combustion, fuels, electricity and refrigerants.

For electricity, which is the largest part of Scope 2 for many companies, the file has several factors that look alike.

Item Description Factor (kgCO₂e per kWh)
137 Grid mix 2016 to 2018, CFO Scope 2 0.4999
140 Grid mix 2022 to 2024, CFO Scope 2 0.475
141 Fuel supply for power generation, 2022 to 2024, Scope 3 0.0812
142 Grid mix 2022 to 2024, product carbon footprint (CFP) 0.5562

Factors labelled CFP or Scope 3 are not corporate Scope 2 factors. Pick the wrong row and the whole year is off. Picture a company that uses 1,000,000 kWh a year. Item 140 gives about 475 tonnes CO₂e, while item 137 gives about 500 tonnes. That 25-tonne gap comes only from the factor choice; the activity data has not changed.

Agree with your verifier which factor set applies to which reporting year, and write it down as a policy. Never overwrite old factors in the same file. When TGO publishes a new version, you need to show which set last year's figures used.

Data-readiness checklist before assurance

The goal is that a verifier can trace every reported figure back to a source document. Work through these steps in order.

  1. Define the organisational boundary: which subsidiaries, plants, branches and offices are in, and which control approach you use.
  2. List emission sources at each site, such as boilers, generators, company vehicles, air conditioners and electricity meters.
  3. Pull activity data from the ERP instead of typing year-end totals, for example electricity bills by meter, fuel and gas purchases, and refrigerant top-ups.
  4. Version your emission factors. Record the file name, item number, value, unit and start date for every factor.
  5. Attach evidence to each figure. Keep invoices, receipts or meter readings on the record itself, not in a separate folder.
  6. Set internal controls. Separate who enters, who reviews and who approves, close data monthly and keep a history of every change.
  7. Run an internal dry run. Have internal audit sample a few figures and trace them back to source documents before the real verifier arrives.

This table shows where each type of data usually sits.

Data Scope Common ERP source Evidence to attach
Diesel for generators and boilers 1 Purchase orders and goods receipts Tax invoices, fuelling logs
Fuel for company vehicles 1 Vehicle expenses or fuel cards Receipts, licence plate
Refrigerant top-ups 1 Maintenance work orders Technician job sheet, type and amount
Purchased grid electricity 2 Electricity bills in accounts payable Bills showing meter number and kWh

Why pull data from the ERP instead of a year-end spreadsheet?

Most activity data already passes through accounting and purchasing. If you take it from the same place, your greenhouse gas figures match the financial records your auditor sees, and you can trace them back to source documents.

Year-end spreadsheets run into the same problems every time: several teams fill in separate files, formulas change without anyone noticing, and the evidence sits in email. When a verifier asks where one plant's March figure came from, the team spends days digging.

If you already use Odoo, read what the Odoo ESG app does. It explains how the app calculates from accounting entries and what you need to add when you use TGO factors.

The same Scope 1 and 2 figures also end up in your One Report, which feeds FTSE Russell's assessment. From 2026 the SET uses FTSE Russell ESG Scores, which are based on what companies disclose publicly. Read more in preparing data now that SET ESG Ratings has become FTSE Russell ESG Scores.

Frequently asked questions

We are in the SET100 but not the SET50. When do we have to report under IFRS S2?

Under SEC news release 298/2568, the SET100 group is based on the December 2027 index review. For the first reporting year, check the table in the release and the updated notification the SEC will issue.

Do we have to report Scope 3?

The release covers only Scope 1 and Scope 2 for the first phase. It does not set Scope 3 requirements, so watch the updated notification.

Does the verifier have to be registered with TGO?

No. The SEC allows a corporate carbon footprint verifier registered with TGO or another verifier, as long as the verification follows international standards.

What is the current TGO electricity factor for Scope 2?

The January 2026 Emission Factor CFO file gives 0.475 kgCO₂e per kWh for grid mix 2022 to 2024 for CFO Scope 2. The 2016 to 2018 factor of 0.4999 is still in the file.

What should we prepare first?

Start with electricity. The evidence is clear and it already sits in accounts payable. Cover every meter, attach the bills, record the factor you used, and then move on to fuels and refrigerants.

What Enersys does

Enersys is a Bangkok software house that has built business software since 2012 and is an Official Odoo Silver Partner. This is our second year working with Odoo, and we won the Odoo Awards 2026 Best Starter APAC.

For ESG, we build custom ESG modules on Odoo for Thai listed companies, scoped to each company's indicators, source systems, approvals and report format, and we work with the standard Odoo ESG app (Enterprise) for Scope 1, 2 and 3 carbon footprints. We run monthly ESG data cycles on PrivacyHub's governance base of role-based access, workflow status, evidence and audit history, and add ESG-specific functions per project. KPI dashboards map indicators to 56-1 One Report or GRI with links back to source documents, and Genesis AI drafts report text with human review. Employee data is handled under PDPA.

See the Enersys ESG page for details. If you want to walk through your electricity data with us and see how ready it is for verification, contact the Enersys team.

Sources

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