The Insider/
Why Your Sustainability Strategy Needs a Refresh 

For a lot of organisations, a sustainability strategy is a document prepared a few years ago, signed off, and quietly filed. It did its job at the time. But the ground it was built on has moved.  

A strategy should be reviewed every year, in the same way a materiality assessment is to confirm it’s still fit for purpose. But some events call for more than that.  

A significant acquisition or divestment, or entry into a new jurisdiction can change the ground the strategy was built on. A fatality, critical incident or material environmental incident tests whether it holds up in practice, not just on paper. A significant regulatory non-compliance, or a change in reporting requirements affecting what you disclose, can leave a strategy answering to a regime it was never written for: AASB S2 is a current example for reporting entities moving through Group 1,2 and 3 (More about that in my previous insider post). A target missed for two consecutive reporting periods, or a baseline materially restated, are two more.  

If any of this sounds familiar, the strategy sitting in a drawer needs more than its annual check-in. That’s not the only reason to open it.  

What a Sustainability Strategy Actually is? 

Strip away the jargon and a sustainability strategy is a working blueprint, not a values statement and not the annual report that describes it after the fact. It’s built from a few connected parts: materiality (what genuinely matters to the business and the people affected by it), goals set against those material issues, governance that makes clear who owns delivery and how it’s resourced, metrics that let progress be tracked honestly, and a roadmap that sequences the work over realistic timeframes. Done well, each part depends on the others. Change one and the rest should move too.  

That’s precisely why a strategy can’t be set-and-forget.  

Who’s Accountable and Where it Sits

A strategy needs an owner, not just a working group. Increasingly, that means clear board-level oversight, often through a sustainability committee or through an audit and risk committee, given climate-related disclosures under AASB S2 now sit within financial reporting rather than beside it. Day-to-day delivery typically sits with a senior executive, a Chief Sustainability Officer, Chief Risk Officer, or an equivalent role reporting directly to the CEO, with real authority to make trade-offs rather than just coordinate.  

Just as important is where the strategy sits relative to everything else the organisation already governs. It shouldn’t run as a side process managed out of communications or marketing. It needs to be threaded through existing governance: the enterprise risk management framework, the board reporting cycle, internal audit, and increasingly, executive remuneration. Without that connection, even a well-designed strategy stalls. It becomes everyone’s responsibility in principle and non-one’s in practice. 

Why Static Strategies Quietly Fail

Materiality shifts. What mattered most to a business three years ago often sits behind newer, sharper priorities today: climate risk disclosure, modern slavery exposure, biodiversity impacts. A strategy that hasn’t been re-tested is usually still optimised for yesterday’s priorities.  

Reporting expectations move faster than most internal review cycles. A strategy written before AASB S2 came into force may already understate what the organisation is now required to disclose, and in how much detail.  

And stakeholder expectations don’t sit still either. In sectors like resources and property, where social licence is closely tied to sustainability credibility, communities and investors are quicker than ever to notice when public claims and internal reality have drifted apart. That gap is where genuine goodwill turns into a greenwashing risk: not through dishonesty, usually, but through a strategy that simply hasn’t kept pace with the standards it’s now being measured against.  

What Updating Actually Looks Like 

The good news is that a refresh rarely means starting from scratch. Most organisations already have a solid foundation; what’s missing is a proper stress test of where those foundations still hold. Done well, this is weeks of focused work, not a year-long rebuild.  

Start by revisiting materiality, testing whether the issues that shaped the original strategy are still the ones that matter most to the business and the people it affects. Check current commitments against today’s regulatory and disclosure requirements, not the ones in force when the document was drafted. Go back to stakeholders directly, rather than leaning consultation that’s now years old. Confirm governance still holds, that accountability sits with the right people and that they have the authority to deliver. And reset targets and metrics so they reflect where the organisation stands now, not where it stood at the last review.  

The Point of Getting This Right  

A sustainability strategy that reflects reality does more than manage disclosure risk. It becomes something the organisation can stand behind (with its board, investors, community, and its own people) because it’s actually true. 

So, the question worth sitting with isn’t whether your strategy still exists. It’s when you last stress-tested it against where the business, and the standards around it, actually are today.  

This is the work ReGen does. We bring technical depth in policy and disclosure, established relationships across government, and a genuine understanding of community expectations, the combination that lets a strategy withstand real scrutiny, not just internal sign-off. If yours hasn’t been tested against today’s standards, we can help.