ESG & Sustainability Advisory

Several regimes apply depending on your size and activities. The mandatory climate-related financial disclosure regime (ASRS, under AASB S2) is phasing in from 2025 by entity size, aligned with the ISSB and TCFD, and covers climate risks, governance, strategy, and Scope 1, 2, and 3 emissions. National Greenhouse and Energy Reporting (NGER) has applied since 2007 for entities exceeding set emissions or energy thresholds, administered by the Clean Energy Regulator. Modern Slavery Act reporting has applied since 2019 for entities with consolidated annual revenue of AUD $100 million or more. AASB S1 is available for broader voluntary sustainability disclosures.

The mandatory climate disclosure regime applies in three phases by entity size. Group 1 (revenue $500M+, assets $1B+, or 500+ employees) reports from 1 January 2025. Group 2 (revenue $200M+, assets $500M+, or 250+ employees) from 1 July 2026. Group 3 (revenue $50M+, assets $25M+, or 100+ employees) from 1 July 2027. An entity generally needs to meet at least two of the three criteria for its group, so confirm your group and timeline with an adviser. 

Alongside the mandatory requirements, companies commonly align with internationally recognised frameworks, including the ISSB standards, the Task Force on Climate-related Financial Disclosures (TCFD), the Global Reporting Initiative (GRI), the Sustainability Accounting Standards Board (SASB), and the United Nations Sustainable Development Goals (UN SDGs).

Not unless they meet the relevant revenue, asset, emissions, or employee thresholds. Many smaller businesses still report ESG voluntarily, to meet the supply-chain requirements of large corporate clients, improve access to sustainable financing, and enhance brand reputation and stakeholder trust. 

ASX-listed companies are encouraged to make TCFD-aligned climate disclosures and to report ESG risks under the ASX Corporate Governance Principles. Those meeting the ASRS thresholds also fall under the mandatory AASB S2 climate disclosure regime as it phases in. 

Assess which regimes apply based on the ASRS, NGER, and Modern Slavery Act thresholds; develop a reporting framework aligned with AASB S1 and S2, TCFD, or GRI; implement data collection systems for emissions, energy, and climate risk; engage your board, investors, and stakeholders; and seek professional ESG advisory to ensure accuracy and compliance.