
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 DaviesReadiness Assessment
AASB S2 requires organisations to assess the resilience of their strategy using climate scenario analysis, and the Corporations Act specifies at least two scenarios: one consistent with 1.5°C of warming and one well exceeding 2°C. ReGen designs and conducts scenario analysis matched to each organisation’s exposure and capability, drawing on recognised scenario sets from the IPCC, IEA and NGFS, and translates the results into clear findings for the board and the report.
- Select and tailor scenarios, time horizons and key assumptions
- Assess how physical and transition drivers affect operations, assets and markets under each scenario
- Assess the resilience of strategy and business model
- Draft Strategy pillar disclosures on climate resilience
Climate Materiality Assessment
A climate materiality assessment establishes which climate-related matters are material to the organisation and its investors, and sets the scope for everything that follows. For Group 3 entities, it also determines whether the organisation has material climate-related risks or opportunities to report.
- Assess the materiality of climate-related matters to the organisation
- Identify which Scope 3 categories are material across the value chain
- Document the basis for Group 3 materiality conclusions
Climate Governance
The Governance pillar requires organisations to disclose how the board and management oversee climate-related risks and opportunities. ReGen designs governance arrangements that stand up to disclosure and assurance, and gives directors the understanding they need to make the directors’ declaration with confidence.
- Review board and committee charters, delegations and reporting lines for climate oversight
- Define management roles, controls and procedures for climate-related risks and opportunities
- Assess board skills and competencies relating to climate
- Draft Governance pillar disclosures
Climate Change Risk Assessment
ReGen identifies the physical risks, transition risks and opportunities that climate change presents across an organisation’s operations and value chain, then assesses and prioritises them through a structured climate change risk assessment. Results are integrated into the existing enterprise risk framework so climate risk is managed alongside every other business risk.
- Identify acute and chronic physical risks across sites, assets and supply chains
- Identify transition risks and opportunities across policy, legal, technology, market and reputation
- Assess likelihood, consequence and time horizon using the organisation’s enterprise risk matrix
- Integrate climate risk into risk registers, management processes and board reporting
- Draft Risk Management pillar disclosures
Climate Scenario Analysis
AASB S2 requires organisations to assess the resilience of their strategy using climate scenario analysis, and the Corporations Act specifies at least two scenarios: one consistent with 1.5°C of warming and one well exceeding 2°C. ReGen designs and conducts scenario analysis matched to each organisation’s exposure and capability, drawing on recognised scenario sets from the IPCC, IEA and NGFS, and translates the results into clear findings for the board and the report.
- Select and tailor scenarios, time horizons and key assumptions
- Assess how physical and transition drivers affect operations, assets and markets under each scenario
- Assess the resilience of strategy and business model
- Draft Strategy pillar disclosures on climate resilience
Carbon Inventory
An accurate, defensible carbon inventory is the bedrock of any AASB S2 report. ReGen calculates Scope 1, 2 and 3 greenhouse gas emissions in line with the GHG Protocol and NGER methods, using Australian emission factors and location-based Scope 2 reporting as required under AASB S2.
- Set organisational and operational boundaries
- Calculate Scope 1 and Scope 2 emissions from the first reporting year
- Build out material Scope 3 categories across the value chain ahead of year two obligations
- Track emissions monthly or quarterly against targets
Partner offering with eco-shaper for automated carbon calculation
Scope 3 emissions are the most significant data challenge for most Australian organisations preparing their first AASB S2 report. ReGen partners with eco-shaper, an AI-powered sustainability reporting platform, to automate the collection and calculation of emissions data. eco-shaper is GHG Protocol compliant, applies audited algorithms and regionalised Australian emission factors, and uses zero-touch data automation and supply chain engagement tools to capture Scope 3 data at scale. ReGen oversees the inventory, reviews the outputs and carries the results through to disclosure.
Data Management and Basis of Preparation
Assurance applies from the first reporting year, so the data behind every disclosure needs to be complete, traceable and controlled. ReGen designs the data management systems and documentation that auditors will test.
- Design data collection processes, ownership and internal controls
- Prepare the basis of preparation documenting boundaries, methods, assumptions and estimates
- Build an evidence file that supports limited and reasonable assurance
Emissions Reduction, Transition Planning and Net Zero
With a clear emissions baseline and risk picture in place, ReGen turns the analysis into practical plans grounded in how an organisation operates and what is achievable within its context. This work supports the Strategy and Metrics and Targets pillars of AASB S2.
- Emissions reduction strategies and decarbonisation plans inclusive of quantitative / qualitative goals / targets
- Net zero plans with interim and long-term targets
- Climate transition plans that set out how the organisation will adapt its strategy and business model
- Emissions projections and pathway modelling
Sustainability Report Preparation
AASB S2 reports must integrate with the financial reporting cycle, meet specific disclosure requirements under the standard, and be accompanied by a directors’ declaration. ReGen prepares the sustainability report itself, bringing the governance, risk, scenario, emissions and transition work together into one report structured across all four pillars, and supports the organisation through assurance review.


