Mandatory Australia

AASB S2: Mandatory Climate-related Financial Disclosures

Under Australia's new sustainability framework, large businesses and financial institutions must prepare a sustainability report each year. AASB S2, adapted from international IFRS S2 standards, applies to annual reporting periods starting 1 January 2025.

Effective from: 1 January 2025

Overview

AASB S2 establishes mandatory requirements for climate-related financial disclosures in Australia. The sustainability report is positioned as the fourth component of annual reporting, alongside financial, directors', and auditor's reports. Parliament prioritized mandatory climate disclosures, making climate the initial focus of sustainability reports. These reports cover how organisations manage climate risks and their financial impacts. Future sustainability topics may be added. The Australian Securities and Investments Commission (ASIC) administers compliance under the Corporations Act, emphasising investor confidence, market integrity, and stakeholder decision-making.

Key Points

  • Mandatory for large businesses and financial institutions from 1 January 2025
  • Adapted from international IFRS S2 standards with Australian-specific modifications
  • Covers climate-related risks, opportunities, and their financial impacts
  • Directors must personally sign off on climate disclosures
  • Phased implementation based on company size

Disclosure Pillars

Key areas of disclosure required under AASB S2

1

Governance

Disclosure of processes, controls, and procedures for monitoring climate-related risks and opportunities. Focuses on governing body responsibilities and management roles enabling stakeholder understanding.

  • Board oversight of climate-related matters
  • Management's role in assessing and managing climate risks
  • Integration into corporate governance structure
  • Skills and competencies for climate governance
2

Strategy

Disclosure enabling understanding of organisational strategy for managing climate risks and opportunities, including effects on business model, decision-making, and financial position.

  • Identified climate-related risks and opportunities
  • Effects on business model and value chain
  • Financial position, performance, and cash flow impacts
  • Climate resilience assessment through scenario analysis
3

Risk Management

Information about identifying, assessing, prioritising, and monitoring climate-related risks and opportunities, including integration into overall risk management.

  • Processes for identifying climate risks
  • Assessment of nature, likelihood, and magnitude
  • Integration with enterprise risk management
  • Monitoring and review processes
4

Metrics and Targets

Performance disclosure against climate-related risks and opportunities including progress toward targets and greenhouse gas emissions.

  • Scope 1, 2, and 3 greenhouse gas emissions
  • Climate-related transition and physical risks metrics
  • Climate opportunities and capital deployment
  • Internal carbon pricing and executive remuneration linkage

Implementation Timeline

Key dates and milestones for AASB S2 compliance

1
1 January 2025 Group 1

Group 1 Reporting Begins

Large entities begin mandatory reporting: Revenue >$500M, assets >$1B, or >500 employees

2
2025-2026 All Groups

Limited Assurance Phase 1

Limited assurance required on Scope 1 & 2 emissions, governance, and risk disclosures

3
1 July 2026 Group 2

Group 2 Reporting Begins

Mid-size entities begin reporting: Revenue >$200M, assets >$500M, or >250 employees

4
1 July 2027 Group 3

Group 3 Reporting Begins

Smaller entities begin reporting: Revenue >$50M, assets >$25M, or >100 employees

5
2027-2029 All Groups

Limited Assurance Phase 2

Limited assurance on full climate report including Scope 1-3 emissions

6
1 July 2030 All Groups

Reasonable Assurance

Full audit-level reasonable assurance required on all climate disclosures

Who Must Report

AASB S2 applies to a phased rollout based on entity size. The thresholds use a 'meet any two of three' criteria approach.

Group 1

1 January 2025
  • Revenue exceeding $500 million
  • Gross assets exceeding $1 billion
  • More than 500 employees

Group 2

1 July 2026
  • Revenue exceeding $200 million
  • Gross assets exceeding $500 million
  • More than 250 employees

Group 3

1 July 2027
  • Revenue exceeding $50 million
  • Gross assets exceeding $25 million
  • More than 100 employees

Entities Included

  • Large proprietary companies
  • Listed companies
  • NGER reporters
  • Responsible superannuation entities (>$5B AUM)
  • Commonwealth public sector entities

Key Benefits

Why organisations choose to comply with AASB S2

Investor Confidence

Standardised disclosures help investors make informed decisions about climate-related risks and opportunities.

Risk Management

Systematic identification and management of climate risks protects long-term business value.

Global Alignment

AASB S2 aligns with international standards, facilitating cross-border investment and comparison.

Regulatory Compliance

Meeting mandatory requirements avoids penalties and demonstrates corporate responsibility.

Competitive Advantage

Early compliance positions organisations as sustainability leaders in their industry.

Stakeholder Trust

Transparent reporting builds trust with customers, employees, and communities.

Key Stakeholders & Institutions

AASB

Issues Australian Sustainability Reporting Standards

ISSB

Developed baseline IFRS sustainability standards

ASIC

Regulatory enforcement and compliance monitoring

GHG Protocol

International greenhouse gas measurement standards

IPCC

Climate science assessments and projections

APRA

Remuneration disclosure oversight

Frequently Asked Questions

Common questions about AASB S2 compliance

What is the objective of AASB S2 governance disclosures?
The governance disclosures enable understanding of the processes, controls and procedures an entity uses to monitor, manage and oversee climate-related risks and opportunities.
What is the difference between physical and transition risks?
Physical risks relate to the physical impacts of climate change (extreme weather, sea-level rise). Transition risks relate to the societal and economic shifts toward a lower-carbon economy (policy changes, technology shifts, market changes).
What are the three categories of greenhouse gas emissions?
Scope 1 covers direct emissions from owned or controlled sources. Scope 2 covers indirect emissions from purchased electricity, steam, heat, and cooling. Scope 3 covers all other indirect emissions in the value chain.
What measurement standard should be used for emissions?
Entities should measure emissions according to the 'Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004)' unless a jurisdictional authority requires an alternative.
When does reasonable assurance begin?
From 1 July 2030, reasonable assurance (equivalent to a full audit) is required on all climate disclosures, replacing the earlier limited assurance requirements.
Do directors have personal accountability?
Yes, company directors must personally sign off on climate disclosures, increasing their legal and reputational responsibility for the accuracy of these reports.
What is the difference between location-based and market-based Scope 2 emissions?
Location-based emissions reflect the average emissions intensity of the local electricity grid. Market-based emissions reflect the emissions from the energy sources an entity has contractually chosen (e.g., renewable energy certificates).
What are financed emissions?
Financed emissions are the portion of an investee's or counterparty's greenhouse gas emissions that are attributed to an entity's loans and investments. These are classified as Scope 3 Category 15 emissions.

Key Terminology

Scope 1 Emissions

Direct greenhouse gas emissions from sources owned or controlled by the reporting entity.

Scope 2 Emissions

Indirect emissions from the generation of purchased electricity, steam, heat, or cooling consumed by the entity.

Scope 3 Emissions

All other indirect emissions that occur in the entity's value chain, both upstream and downstream.

Climate Resilience

The capacity of an entity to adjust to climate-related changes, developments, or uncertainties.

Scenario Analysis

A process for identifying and assessing a potential range of outcomes of future events under conditions of uncertainty.

Transition Risk

The risk of financial loss from policy, legal, technology, market, and reputational changes associated with the transition to a lower-carbon economy.

Physical Risk

The risk of financial loss from the physical effects of climate change, including acute events and chronic shifts.

Financed Emissions

The portion of greenhouse gas emissions of investees or counterparties attributed to an entity's investments and lending activities.

Ready to Meet Your AASB S2 Obligations?

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