Climate & ESG

Group 1 entities must report Scope 3 from year 2 + escalating assurance through to FY30.

Group 2 (mid-tier entities) start climate disclosure FY27.

Australia's 215 largest emitters face declining baselines under Safeguard Mechanism reform.

Threshold-triggered annual emissions, energy production + consumption reporting.

Test corporate group and facility thresholds at end of each FY — if met, register and report under NGER.

AASB likely to mandate S1 (general sustainability) following S2 climate phasing.

Group 3 (smaller entities) start climate disclosure FY28.

Scope 3 emissions become mandatory year 2 of ASRS reporting (varies by Group).

Federal procurement requires modern slavery risk consideration in supply chain.

Entities with consolidated revenue ≥$100M must publish a Modern Slavery Statement annually.

S2 mandates climate scenario analysis at least 1.5°C-aligned + an additional scenario.

Corporations meeting NGER thresholds must report Scope 1, Scope 2 emissions and energy data by 31 October.

Facilities >100,000 tCO2-e/year must keep emissions below an annually declining baseline.

Entities with consolidated revenue ≥$100M must publish an annual Modern Slavery Statement.

ACCUs issued under ERF; tradeable; surrender under Safeguard Mechanism.

Group 1/2/3 entities must publish ASRS-aligned climate disclosures with their annual financial reports.

NSW entities with ≥$50M revenue may need to comply with NSW MSA (Anti-Slavery Commissioner oversight).

Eligible zero/low-emission cars FBT-exempt under car limits (until 2025 for PHEVs).

First AASB S2 climate disclosures by Group 1 entities for years ending 30 June 2025; ASIC + AASB review for compliance.

ACCC investigation into CBA ESG marketing in financial products.

ASIC progressed multiple greenwashing civil penalty proceedings into 2025 — including against listed entities + super funds.

ASIC published 2 reports + 35+ infringement notices on ASX greenwashing 2023-2024.

Joint APRA + ASIC reviews of sustainability-labelled super products throughout 2024-2025 identified misalignment between marketing + actual portfolio.

Class action filed against Mercer Super following ASIC greenwashing finding.

The federal Anti-Slavery Commissioner published lists of reporting entities late or non-compliant with their Modern Slavery Statement obligations.

Federal Anti-Slavery Commissioner published lists of reporting entities late or non-compliant.

Vanguard made misleading representations about ESG exclusionary screens applied to one of its funds, when the screens did not in fact exclude all the categories represented.

Class actions filed against multiple super funds alleging greenwashing in product marketing.

Mercer represented certain superannuation investment options as excluding investments in companies involved in fossil fuels, alcohol production and gambling, when in fact those exclusions were not implemented.

Active Super marketed itself as having eliminated exposure to tobacco, gambling, oil tar sands and other categories — Federal Court found this was misleading because investments in those categories existed within the fund.

Federal Court hearing of greenwashing claims around 'Go Neutral' carbon offset product — whether offsets actually delivered the climate benefit advertised.

ASIC concerns over the timeliness of Rio Tinto's continuous disclosure following the Juukan Gorge events and subsequent leadership review.

ASX-listed energy company made representations about clean energy outcomes that lacked reasonable basis.

REST infringement notice for misleading ESG product claim.

Future Super made representations about climate impact that ASIC found were not adequately substantiated.

ACCC alleged VW + VW Australia engaged in misleading conduct re: emissions of certain diesel vehicles.

FWO found systemic underpayment of trolley collectors engaged through subcontractors at Coles supermarkets across Australia.