From 1 January 2025, certain entities will need to prepare an annual sustainability report containing mandatory climate-related financial disclosures. Pitcher Partners can provide technical knowledge and expertise to guide you through the process of navigating the new requirements in a commercial and pragmatic manner.
The Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024 – Schedule 4) requires that all entities subject to mandatory climate-related financial disclosures are phased in three groups, over a four-year period, based on size or level of emissions.
| Scoping and timing | Required to lodge financial reports under Chapter 2M of the Corporations Act 2001 and falls within one (or more) of the following three categories | ||||
| First annual reporting periods beginning on or after | Meet two of three reporting thresholds: | National Greenhouse and Energy Reporting (NGER) Reporters | Asset owners (registered schemes, registrable superannuation entities, retail CCIVs) | ||
| Consolidated revenue (for year) | Consolidated assets (at year-end) | Employee numbers (at year end) | |||
| Group 1
1 January 2025 |
$500 million or more | $1 billion or more | > 500 | Above NGER publication threshold | Scoped out of Group 1 |
| Group 2
1 July 2026 |
$200 million or more | $500 million or more | > 250 | All other NGER reporters | $5 billion or more assets under management |
| Group 3
1 July 2027 |
$50 million or more | $25 million or more | > 100 | N/A | Refer to Group 3 thresholds |
Australian Sustainability Reporting Standards (ASRS)
AASB S2 Climate-related Disclosures is a mandatory standard on climate reporting applying to those entities specified in the climate reporting legislation. It contains four key content areas for organisations to disclose, which are summarised below:
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Governance
The governance body responsible within the entity and the delegated authority within management. Monitoring and oversight of climate-related issues |
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Risk management
Processes to identify, assess, prioritise and monitor risks and opportunities. Key data sources and information provided to monitor risk. |
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Strategy
Climate-related risks and opportunities. Potential impacts on business model, supply chain, strategy, financial positions, performance. |
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Metrics and targets
What targets are set. Actual data available to support the progress toward those targets, including Greenhouse Gas Emissions |
Assurance requirements
Under the new legislation, the mandatory climate reporting disclosures are subject to assurance phasing of limited and reasonable assurance over a four year period.
Timeline for assurance phasing
| Reporting year | 1st* | 2nd | 3rd | 4th | 5th | 6th** |
| Governance | L | L | L | R | R | R |
| Strategy – Risks and opportunities*** | L**** | L | L | R | R | R |
| Climate Resilience Assessments/Scenario Analysis | N | L | L | R | R | R |
| Transition plans | N | L | L | R | R | R |
| Risk management | N | L | L | R | R | R |
| Scope 1 and 2 emissions | L | L | L | L | R | R |
| Scope 3 emissions | N/A | L | L | R | R | R |
| Climate-related metrics and targets | N | L | L | R | R | R |
L – Limited assurance engagement means a review of information in a sustainability report.
R – Reasonable assurance engagements means an audit of information in a sustainability report.
N – None
N/A – Not applicable in year 1
* Group 1 – Years commencing 1/1/25, Group 2 – Years commencing 1/7/26, Group 3 – Years commencing 1/7/27.
** Group 3 is to be subject to reasonable assurance across all disclosures by years commencing 1/7/30.
*** Includes the phasing for assurance on Statements where there are no material climate-related risks and opportunities.
**** Assurance requirements will only apply to disclosures prepared for the purpose of complying with sub-paragraphs 9(a), 10(a) and 10(b) of AASB S2.
Need any assistance with the climate reporting legislation? We’re here to help.
