ESG + climate disclosure in New South Wales

NSW Modern Slavery Act reporting (≥$50M)

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

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.

ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026

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

AASB S2 Scope 3 emissions + assurance phase-in

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

Hold AER authorisation as energy retailer

Selling electricity or gas to small customers requires AER retailer authorisation.

AASB S1 General Sustainability disclosures (likely)

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

CDR Energy sector — phased

Energy retailers + distributors must share data via CDR.

Register with AEMO for National Electricity Market participation

Generators + retailers + market participants must register with AEMO and meet NER obligations.

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.

Determine NGER reporting thresholds annually

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

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).

Energy Bill Relief Fund + state cost-of-living payments compliance

Retailers + suppliers administering federal/state energy bill relief must apply correctly + report.

GEMS (Greenhouse + Energy Minimum Standards)

Regulated products must meet energy efficiency MEPS + display label.