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AASB S2 Mandatory Climate Reporting

Australia’s mandatory climate disclosure regime is now in effect. We help organisations build the emissions foundation, prepare the sustainability report, and meet assurance requirements from year one.

Mandatory from 2025. We make it manageable.

About Climate Reporting

Under the Corporations Act 2001, large listed and private companies and financial institutions are required to prepare an annual sustainability report disclosing their climate-related risks and opportunities. The governing standard is AASB S2 Climate-related Disclosures, issed by the Australian Accounting Standards Board in September 2024.

Reporting is structured around four pillars. Each one calls for its own body of work.

  • Governance. How the board and management oversee climate-related risks and opportunities, including the skills and competencies available to do so.
  • Strategy. The climate-related risks and opportunities facing the organisation, their effect on its business model, strategy and financial position, and the resilience of its strategy tested through climate scenario analysis. The Corporations Act requires at least two scenarios: one consistent with 1.5°C of warming and one well exceeding 2°C.
  • Risk Management. The processes used to identify, assess, prioritise and monitor climate-related risks and opportunities, and how these integrate with overall risk management.
  • Metrics and Targets. Scope 1 and Scope 2 greenhouse gas emissions from the first reporting year, material Scope 3 emissions across the value chain from the second year, and climate-related targets.

Who needs to report and when

Reporting under AASB S2 is phased across three groups. A company is captured if it meets at least two of the three size criteria for its group, or through the NGER and asset owner entry routes. Group 1 entities are reporting now, and Group 2 entities began their first reporting year on 1 July 2026. 

    • Group 1
      • Financial years commencing on or after 1 January 2025
      • Two of three: 500+ employees, $500M+ consolidated revenue, or $1B+ consolidated gross assets
      • NGER reporters above the publication threshold
    • Group 2
      • Financial years commencing on or after 1 July 2026
      • Two of three: 250+ employees, $200M+ consolidated revenue, or $500M+ consolidated gross assets
      • All other registered NGER reporters or asset owners with %5B+ in assets
    • Group 3
      • Financial years commencing on or after 1 July 2027
      • Two of three: 100+ employees, $50M+ consolidated revenue, or $25M+ consolidated gross assets

    Group 3 entities with no material climate-related risks or opportunities may disclose that position in place of full climate statements, with an explanation of how they reached that conclusion.

    Organisations below the thresholds are also feeling the effect. In-scope entities must report material Scope 3 emissions from their second reporting year, so suppliers are already receiving data requests from larger customers building their value chain inventories.

    AASB S2 climate disclosures require independent assurance from the first reporting year, phasing to reasonable assurance of all disclosures for financial years commencing on or after 1 July 2030.

    Services

    Where ReGen  
    can help

    ReGen delivers the full AASB S2 program in-house, in the order the work needs to happen. Each step builds on the one before it, so the evidence gathered early flows through to the disclosures, the report and the assurance file. Organisations can engage ReGen for the full program or for individual steps.

    Contact Colin Davies, Partner / Sustainability and ESGContact Colin Davies

    Contact us

    Early preparation matters. Assurance applies from the first reporting year, and building robust governance, risk and data systems takes time. 

    Contact Colin Davies, Partner, to discuss where your organisation sits in the reporting timeline and the steps that make sense now. 

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