Climate & ESG in New South Wales
Mandatory climate disclosures under AASB S2 (ASRS), NGER reporting, Safeguard Mechanism, Modern Slavery reporting, and greenwashing enforcement by ASIC and ACCC.
1
NSW-specific obligations
17
Federal obligations
NSW-specific
Federal
AASB S2 Scope 3 emissions + assurance phase-in
Group 1 entities must report Scope 3 from year 2 + escalating assurance through to FY30.
ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026
Group 2 (mid-tier entities) start climate disclosure FY27.
NGER reporting (Clean Energy Regulator)
Threshold-triggered annual emissions, energy production + consumption reporting.
Safeguard Mechanism baseline decline 4.9% pa
Australia's 215 largest emitters face declining baselines under Safeguard Mechanism reform.
Determine NGER reporting thresholds annually
Test corporate group and facility thresholds at end of each FY — if met, register and report under NGER.
AASB S1 General Sustainability disclosures (likely)
AASB likely to mandate S1 (general sustainability) following S2 climate phasing.
ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027
Group 3 (smaller entities) start climate disclosure FY28.
Scope 3 emissions disclosure (AASB S2 + voluntary)
Scope 3 emissions become mandatory year 2 of ASRS reporting (varies by Group).
Commonwealth Procurement-Connected Policy — modern slavery
Federal procurement requires modern slavery risk consideration in supply chain.
Modern Slavery Statement (Cwlth)
Entities with consolidated revenue ≥$100M must publish a Modern Slavery Statement annually.
Lodge mandatory climate-related financial disclosures (ASRS S2)
Group 1/2/3 entities must publish ASRS-aligned climate disclosures with their annual financial reports.
Report greenhouse and energy data under NGER
Corporations meeting NGER thresholds must report Scope 1, Scope 2 emissions and energy data by 31 October.
Comply with Safeguard Mechanism baseline (covered facilities)
Facilities >100,000 tCO2-e/year must keep emissions below an annually declining baseline.
Publish an annual Modern Slavery Statement
Entities with consolidated revenue ≥$100M must publish an annual Modern Slavery Statement.
Australian Carbon Credit Units (ACCUs)
ACCUs issued under ERF; tradeable; surrender under Safeguard Mechanism.
Climate scenario analysis (AASB S2)
S2 mandates climate scenario analysis at least 1.5°C-aligned + an additional scenario.
Electric Cars FBT Exemption (Cwlth)
Eligible zero/low-emission cars FBT-exempt under car limits (until 2025 for PHEVs).