ASRS Group 1: what you must disclose in your first sustainability report

If you're Group 1 (FY commencing on/after 1 Jan 2025), your first AASB S2-aligned climate disclosures are due. Here's exactly what goes in.

Published 18 May 2026

Who is Group 1

You're Group 1 if any of: revenue ≥$500M, assets ≥$1B, ≥500 employees, NGER high emitter (≥50K tCO2-e), or asset owner with ≥$5B AUM. FY commencing on/after 1 January 2025.

The four AASB S2 pillars

  1. Governance — body / individual(s) overseeing climate; monitoring; management role + reporting cadence.
  2. Strategy — short/medium/long-term risks + opportunities; strategy impact; scenario analysis; resilience.
  3. Risk management — identification + assessment + prioritisation processes; integration with overall risk management; transition plan (if any).
  4. Metrics + targets — Scope 1 + 2 (year 1), Scope 3 (year 2+), other metrics, targets with base years.

Scope 1 and Scope 2 in year 1

Scope 1: direct emissions (combustion, fugitive, process). Scope 2: indirect from purchased energy (location + market based). Calculate per GHG Protocol; use NGER methods where applicable.

Scope 3 — relief in year 1, mandatory year 2

Group 1 has Scope 3 reporting relief in year 1; mandatory from year 2. Start data collection NOW. Categories: purchased goods + services, capital goods, fuel + energy related, upstream + downstream transport, waste, business travel + commuting, use of sold products, investments (financial services).

Scenario analysis

At least one well-below-2°C scenario (IEA NZE or equivalent) + one higher-emissions scenario. Year 1 can be qualitative; year 2+ quantitative.

Assurance pathway

Year 1 — limited assurance on Scope 1+2 + governance + risk management. Year 3 — reasonable assurance on all in-scope. Year 5 — reasonable assurance on Scope 3 + scenario analysis + financial impact. Engage your financial auditor early.

Frequently asked

What if I don't meet any single threshold but cross 2 of 3?

Group 1 applies if you meet ANY of: revenue/assets/employees/NGER/asset owner. The Ch 2M financial-reporting 'any 2 of 3' analog does NOT apply here.

Is the sustainability report public?

Yes — published alongside the annual financial report. Lodged with ASIC; auditor's assurance report attached.

What if I'm in scope but don't have Scope 3 data?

Year-1 relief; develop Scope 3 mapping during FY25 for year-2 reporting.

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Obligations covered

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