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Understanding Australia's Sustainability Reporting Standards (ASRS)
Australia's new national framework for climate and sustainability reporting, developed by the Australian Accounting Standards Board (AASB) and finalized in September 2024. These standards align closely with international IFRS Sustainability Disclosure Standards to create a consistent global approach to sustainability reporting.
Who Must Report Under the ASRS?
Australia's Sustainability Reporting Standards (ASRS) establish mandatory reporting requirements for a wide range of organizations. The reporting obligations are designed to capture entities with significant environmental impact or substantial resources to implement reporting systems. Understanding whether your organization falls under these requirements is the first critical step in your compliance journey.
Large Corporations
Public companies meeting specific revenue and asset thresholds
Financial Institutions
Banks, insurers, and asset managers with significant portfolios
Major Emitters
Companies already reporting under the National Greenhouse and Energy Reporting (NGER) scheme
Workforce Size
Organizations exceeding employee number thresholds
Detailed Reporting Requirements
In practice, the ASRS will generally apply to:
  • ASX-listed companies with market capitalization exceeding $50 million or annual consolidated revenue above $25 million
  • Unlisted entities with consolidated annual revenue or assets exceeding $500 million
  • Financial institutions managing over $5 billion in assets or with significant exposure to climate-sensitive sectors
  • NGER reporters emitting more than 50,000 tonnes of CO2 equivalent annually
  • Large employers with more than 500 full-time equivalent staff members across Australia
Smaller organizations are currently exempt from mandatory reporting but may choose to voluntarily adopt the standards to demonstrate climate leadership and prepare for future regulatory expansion. Organizations should note that these thresholds may be adjusted as the ASRS framework matures in coming years.
If your organization falls into any of these categories, you should begin preparing your compliance strategy immediately, as the first reporting periods commence in 2025.
Timeline: When Does ASRS Reporting Start?
Group 1: January 1, 2025
  • Revenue exceeding $500M
  • Assets exceeding $1B
  • More than 500 employees
  • Large GHG emitters
Group 2: July 1, 2026
  • Revenue exceeding $200M
  • Assets exceeding $500M
  • More than 250 employees
  • NGER reporters
  • Assets under management exceeding $5B
Group 3: July 1, 2027
  • Revenue exceeding $50M
  • Assets exceeding $25M
  • More than 100 employees
The Mandatory AASB S2 Explained
AASB S2 is Australia's mandatory climate-related disclosures standard, focusing on how businesses identify, manage, and report climate-related financial risks and opportunities. Based on the internationally recognized Task Force on Climate-related Financial Disclosures (TCFD) framework, S2 requires organizations to report across four essential pillars:
Governance
Board oversight and management's role in assessing and managing climate-related risks and opportunities.
Organizations must disclose how the board considers climate issues when reviewing strategy, policies, and risk management processes.
They must also detail management's responsibilities and the reporting structures that keep leadership informed.
Strategy
Identification of climate risks and opportunities and their impact on business model, strategy, and financial planning.
Companies must analyze and report climate impacts across short, medium, and long-term time horizons.
This includes scenario analysis demonstrating business resilience under different climate futures, particularly a 2°C or lower warming scenario.
Risk Management
Processes for identifying, assessing, and managing climate-related risks and how they integrate with overall risk management.
Organizations must disclose their climate risk identification methodologies, assessment criteria for determining materiality of risks, and mitigation strategies.
Reporting must show how these processes connect with enterprise-wide risk management frameworks.
Metrics & Targets
Specific metrics and targets used to assess and manage relevant climate-related risks and opportunities.
Mandatory disclosure includes Scope 1 and Scope 2 greenhouse gas emissions, with Scope 3 emissions required where material.
Organizations must also report climate-related performance metrics and targets related to their specific industry and business strategy.
Compliance with AASB S2 requires significant data collection, analysis, and reporting capabilities. Organizations must integrate climate considerations into their core business strategy and risk management processes, while ensuring they have robust systems for tracking and reporting emissions and other climate-related metrics. Unlike voluntary frameworks, S2 creates legal reporting obligations with potential regulatory consequences for non-compliance.
Greenhouse Gas Emissions Under AASB S2: Understanding Scopes 1, 2, and 3
AASB S2 requires organizations to report on their greenhouse gas (GHG) emissions as part of climate-related disclosures. Understanding the three emission scopes is essential for accurate reporting and compliance.
Scope 1:
Direct Emissions

Emissions from sources owned or controlled by the reporting organization. These include:
  • On-site fuel combustion in boilers, furnaces, or vehicles
  • Chemical production processes
  • Fugitive emissions from equipment leaks
AASB S2 mandates full disclosure of all Scope 1 emissions regardless of materiality thresholds.
Scope 2:
Indirect Energy Emissions

Emissions from purchased electricity, steam, heating, and cooling consumed by the reporting organization. These represent:
  • Grid electricity usage
  • Purchased heat or steam
  • Energy consumed in leased assets
Under AASB S2, organizations must disclose all Scope 2 emissions, with requirements to use location-based or market-based accounting methods.
Scope 3:
Value Chain Emissions

All other indirect emissions occurring in a company's value chain, including:
  • Purchased goods and services
  • Business travel + commuting
  • Use and end-of-life treatment of sold products
  • Investments and financed emissions
AASB S2 requires Scope 3 reporting when material to the organization, with phased implementation timelines depending on company size.
AASB S2 builds upon the Greenhouse Gas Protocol's established framework but transforms these voluntary guidelines into mandatory reporting requirements. Organizations must disclose their emissions calculation methodologies, assumptions, and uncertainties, while implementing rigorous data collection systems to ensure accuracy and completeness of emissions data across all applicable scopes.
The Greenhouse gas (GHG) Protocol
The GHG Protocol is the leading global framework for measuring and managing greenhouse gas emissions.
It helps organizations identify, calculate, and report their scope 1, 2 and 3 emissions to drive efficiency and sustainability.
Voluntary Standard: AASB S1 Overview
AASB S1 provides a comprehensive framework for disclosure of general sustainability-related financial information to help organizations communicate their broader environmental and social impacts to stakeholders and investors.
Biodiversity
Impacts and dependencies on natural ecosystems and species preservation efforts.
  • Assessment of operations affecting natural habitats
  • Mitigation strategies for biodiversity loss
  • Reporting on conservation initiatives and outcomes
Water Management
Usage, conservation, and quality impacts on water resources.
  • Water consumption metrics across operations
  • Wastewater treatment and recycling practices
  • Strategies to address water scarcity in vulnerable regions
Circular Economy
Waste reduction, reuse of materials, and product lifecycle considerations.
  • Product design for longevity and repairability
  • Resource efficiency in manufacturing processes
  • End-of-life product management and recycling programs
Social Responsibility
Labor practices, human rights, community engagement, and diversity initiatives.
  • Fair work policies and employee wellbeing programs
  • Community investment and local economic development
  • Supply chain monitoring for human rights compliance
Unlike AASB S2 which focuses specifically on climate, S1 covers a broader spectrum of sustainability matters that could reasonably be expected to affect an entity's enterprise value. Organizations adopting this voluntary standard demonstrate leadership in sustainability transparency and gain valuable experience for future mandatory reporting requirements.
Step-by-Step: How Companies Should Prepare
Gap Analysis
Conduct a comprehensive assessment of existing sustainability reporting practices against AASB S2 requirements. Large companies can leverage existing resources, while smaller companies may need external expertise.
Governance Structure
Engage Board and senior management in establishing oversight mechanisms. Large organizations should create dedicated sustainability committees, while smaller entities may integrate responsibilities into existing roles.
Data Systems
Implement climate data collection processes. Large companies should invest in specialized software solutions; smaller companies can begin with structured spreadsheets and basic tracking methods.
Staff Training & Integration
Develop capacity through staff training and integrate climate considerations into broader business processes, with scale appropriate to organization size.
Strategic Risks in ASRS Compliance
Reputational Risk
Disclosures that reveal weak climate response may damage corporate image and stakeholder trust. Companies with poor performance will face greater public scrutiny and potential consumer backlash.
Legal & Regulatory Risk
Increased liability for misleading statements or greenwashing. ASIC has signaled strong enforcement of accurate climate disclosures, with potential penalties for non-compliance or inaccurate reporting.
Operational Challenges
Difficulties in obtaining reliable climate data and forecasts. Many organizations lack established systems for measuring and monitoring climate impacts across complex supply chains.
Financial Implications
Potential capital flight or increased cost of capital if investors perceive inadequate climate risk management. This may affect valuation and access to funding.
Strategic Opportunities for Early ASRS Reporters
86%
Investor Confidence
Percentage of investors who consider ESG disclosures critical in investment decisions
$2.4T
Green Finance
Size of global sustainable investment market accessible to transparent reporters
Global Sustainable Investment Alliance 2022 Review GSIA Report
3.6x
Brand Value
Higher brand value multiple for companies demonstrating climate leadership
Based on Interbrand Report 2023 of Best Global Brands in sustainability
40%
Future-Readiness
Reduced compliance costs through early voluntary adoption of comprehensive reporting
Our Strategic Partnership with NetNada
We've partnered with NetNada to offer businesses comprehensive sustainability solutions.
NetNada provides advanced carbon accounting software that simplifies emissions tracking across your operations.
Our expertise complements their technology by delivering:
  • Strategic implementation of NetNada's tools
  • Expert interpretation of carbon data
  • Custom emission reduction roadmaps
  • ASRS-compliant reporting frameworks
Contact Pragmagaia
Based in Brisbane and serving clients across Queensland and NSW, Pragmagaia offers free initial consultations for businesses preparing for 2025-2027 reporting requirements. Book a discovery call with Dirk today or subscribe to our periodic sustainability updates.