Key point: Singapore’s updated SS 673 (announced 27 October 2026) draws a bright line for market-based Scope 2 and renewable-electricity usage claims: RECs must link to renewable electricity supplied to Singapore’s power grid (domestic generation or approved cross-border electricity trade imports via physical interconnection). Offshore RECs that do not supply the Singapore grid may still support renewable-development narratives, but should not underwrite a claim that electricity consumed in Singapore is renewable. For HKEX-listed groups with Singapore operations, claim geography must match certificate geography.
On 27 October 2026, at the Asia Clean Energy Summit, Minister of State for Energy, Trade and Industry Gan Siow Huang announced that Singapore had updated SS 673, its Code of Practice for Renewable Energy Certificates (RECs). The same day, Enterprise Singapore (EnterpriseSG), through the Singapore Standards Council, together with the Ministry of Energy, Trade and Industry (METI) and the Energy Market Authority (EMA), issued a joint media release and fact sheet that set out how different REC types may be used for claims.
The practical board question for Hong Kong-listed groups is narrow and operational. If a Singapore subsidiary or Singapore-sited load still rests a “100% renewable electricity” or market-based Scope 2 story on certificates from projects that never supply the Singapore grid, that claim may no longer sit inside the claim integrity line drawn by the updated standard, even when the certificates themselves are real and retired.
Our view: A “100% renewable” or market-based Scope 2 claim for electricity used in Singapore that rests on offshore RECs not delivered into the Singapore grid can fail SS 673 claim integrity even if the certificates exist. For HKEX-listed groups with Singapore operations, boards should map (1) where power is consumed, (2) which RECs or PPAs support which claim geography, and (3) what the ESG report and IR wording still say about green power in Singapore. Claim geography ≠ certificate geography is the greenwashing fault line.
The problem: certificates that travel farther than the claim
RECs are contractual instruments. One REC typically evidences that one megawatt-hour of electricity was generated from a renewable source and delivered to a grid. Companies use them to substantiate renewable-electricity use for greenhouse-gas reporting and sustainability targets. SS 673 was first launched in 2021 as a framework to improve measurement, reporting and verification (MRV) for REC issuance and management, and to set good practice for REC transactions and claims.
What changed in the 2026 update is the claim geography. The joint EnterpriseSG / METI / EMA materials distinguish three buckets:
- Domestic RECs: renewable electricity generated in Singapore (for example solar) and supplied to the Singapore power grid.
- Cross-border electricity trade (CBET) RECs: RECs from approved low-carbon electricity import projects that contractually supply electricity to Singapore via a physical interconnection to the Singapore power grid.
- Other overseas RECs: renewable electricity produced overseas without physical electricity flows into the Singapore power grid.
Under the updated SS 673, market-based Scope 2 claims for renewable energy usage in Singapore should be supported by domestic RECs or CBET RECs. Other overseas RECs should not be used to support claims of renewable electricity use in Singapore. They may still be purchased to demonstrate support for renewable energy development and regional decarbonisation. The official materials note that companies wishing to do so may consider purchasing RECs from within the UN geoscheme for Southeast Asia. That is a different narrative from “the electricity we consume in Singapore is renewable.”
Minister of State Gan put the same point in plain language at ACES: RECs from overseas projects that do not supply electricity to Singapore can still show support for overseas renewable development, but they cannot be used to claim that electricity consumed in Singapore is renewable. The stated policy aims are clearer business guidance, stronger trust in sustainability reporting, lower greenwashing risk, and, for imports, better commercial confidence in RECs tied to power that actually arrives.
This article cites the joint media release, EMA fact sheet and the Minister’s delivered remarks. The full updated 2026 edition of SS 673, incorporating the amendments, is stated to be available for purchase from mid-November 2026; the list of amendments can be downloaded free from the Singapore Standards e-shop. We do not invent clause numbers beyond what those public materials state.
The practice: three maps before year-end wording freezes
For a Hong Kong-listed parent, the useful response is not a press-facing “we welcome clarity” sentence. It is an internal claim-boundary check owned jointly by sustainability, finance and the company secretary.
Map one: consumption geography. List Singapore legal entities and Singapore-sited loads that will appear in the group Scope 2 inventory or in any “renewable electricity in Singapore / ASEAN / regional operations” sentence. Separate Singapore consumption from regional or group-wide totals. If IR still rolls Singapore into an Asia renewable percentage without a geography footnote, flag it.
Map two: instrument geography. For each Singapore load that carries a market-based or “green power” claim, identify the supporting instruments: on-site or contracted Singapore solar, retail green products tied to domestic supply, approved import / CBET arrangements, or other overseas RECs. Ask only one binary question per instrument: does this REC link to renewable electricity supplied to the Singapore power grid under the domestic or CBET definitions above? If the answer is no, the instrument may still support a “we financed / we supported renewable development” story. It should not support a Singapore usage claim under the updated SS 673 framing.
Map three: published claim wording. Pull last year’s ESG report, interim sustainability updates, website energy pages, supplier codes and investor decks. Search for “100% renewable”, “green electricity”, “RE100”, “market-based Scope 2”, “Singapore” and “Southeast Asia”. Mark every sentence that attributes renewable attributes to Singapore consumption. Align those sentences to Map two. Where they do not align, rewrite before the next reporting freeze. Prefer precise verbs: “supported regional renewable development through purchase of overseas RECs” is a different claim from “Singapore operations used renewable electricity.”
A light governance note is enough. The disclosure committee or sustainability committee should see the three maps once, with owners and cut-off dates. Internal audit or second-line review can sample whether retired REC serials, registry evidence and claim sentences still match after procurement changes mid-year. This is claim-boundary control, not a new Singapore licence application and not a substitute for HKEX Part D measurement of Scope 1 and Scope 2.
What this means for HKEX issuers
Hong Kong listing rules still require Scope 1 and Scope 2 greenhouse-gas disclosure on the Part D timetable that applies to the issuer. Nothing in the Singapore SS 673 update rewrites that Hong Kong calendar. The interaction is claim quality, not a new Part D relief.
Three issuer patterns deserve board attention.
Singapore operating subsidiaries of H-share, red-chip or A+H groups. If the subsidiary’s market-based Scope 2 or renewable-electricity percentage was built on unbundled overseas RECs without Singapore grid delivery, that percentage may need restatement method notes, instrument switches, or quieter claim language for the Singapore perimeter.
Regional shared services and data-centre / logistics footprints. Groups that buy regional REC portfolios for “ASEAN renewable coverage” should stop treating the portfolio as automatically Singapore-eligible. Singapore loads need Singapore-eligible instruments (domestic or CBET). Regional development claims can sit beside that story; they should not silently replace it.
IR and marketing overclaim. A parent ESG report that says the group “uses 100% renewable electricity in Singapore” while the evidence trail is overseas RECs without physical supply into Singapore sits on the fault line the standard was updated to address. Greenwashing risk here is reputational and disclosure-control risk for the Hong Kong issuer, even though SS 673 is a Singapore standard rather than an HKEX rule text.
CBET RECs matter as opportunity as well as constraint. The official materials recognise RECs associated with approved import projects that contractually supply via physical interconnection. As Singapore expands low-carbon imports, credible Singapore usage claims may increasingly attach to those import pathways rather than to certificates from projects that never touch the Singapore grid. Boards should ask procurement whether any planned import or CBET product is actually on the approved pathway before IR pre-announces “Singapore green power” milestones.
Key dates
2021: SS 673 first launched as Singapore’s Code of Practice for RECs (MRV and claims good practice). 27 October 2026: EnterpriseSG / METI / EMA joint announcement of the SS 673 update; Minister of State Gan Siow Huang remarks at Asia Clean Energy Summit. From mid-November 2026: updated 2026 edition of SS 673 (incorporating amendments) stated as available for purchase from the Singapore Standards e-shop; amendments list downloadable free of charge.
Sources: EnterpriseSG joint media release MR049/26 (27 October 2026); EMA fact sheet on the updated Singapore Standard for RECs (27 October 2026); speech by Minister of State Gan Siow Huang at ACES 2026 (27 October 2026). Full SS 673:2026 text is a purchased standard; claim rules above follow the public fact sheet and joint release, not invented clause citations.
Conclusion
Singapore’s SS 673 update is a claim-integrity rule for renewable-electricity and market-based Scope 2 stories tied to Singapore consumption. Domestic and approved CBET RECs can support those usage claims. Other overseas RECs can still evidence support for renewable development; they should not be asked to prove that power used in Singapore is renewable. For HKEX-listed groups, the board artefact is a three-map pack: consumption geography, instrument geography, and published wording. Fix the mismatch before the next ESG report and IR deck freeze. Certificate existence is not claim geography.
FAQs
1. What did Singapore update on 27 October 2026? EnterpriseSG, through the Singapore Standards Council, together with METI and EMA, updated SS 673, the Code of Practice for Renewable Energy Certificates. The update clarifies which REC types can support claims of renewable electricity consumption in Singapore.
2. Which RECs can support market-based Scope 2 claims for Singapore usage under the updated SS 673? Per the official fact sheet: RECs linked to renewable electricity supplied to the Singapore power grid, namely domestic RECs and CBET RECs from approved low-carbon electricity import projects that contractually supply via a physical interconnection. Other overseas RECs without physical supply into Singapore should not support Singapore renewable-electricity usage claims.
3. Can companies still buy overseas RECs that do not supply the Singapore grid? Yes, according to the joint release and Minister’s remarks. Such RECs may still demonstrate support for renewable energy development and regional decarbonisation. They should not be used to claim that electricity consumed in Singapore is renewable.
4. Does this rewrite HKEX Part D Scope 1 and Scope 2 duties? No. Part D timelines for Hong Kong issuers remain governed by the ESG Reporting Code and related FAQs. The SS 673 update affects the integrity of Singapore-tied renewable and market-based claims that often appear inside those Scope 2 narratives. It is not a Hong Kong listing-rule amendment.
5. When is the full updated standard text available? The public materials state that the list of amendments can be downloaded free from the Singapore Standards e-shop, and that the updated 2026 edition incorporating the amendments can be purchased from mid-November 2026 onwards. Boards should align procurement and disclosure teams to that text when it is available, without waiting to start the three-map claim check.
Edited / written by: Amanda Cheung, Founder, AMMO Group
