Who must lodge mandatory climate-related financial disclosures (ASRS S2)?

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

From financial years commencing 1 January 2025 (Group 1), 1 July 2026 (Group 2), and 1 July 2027 (Group 3), eligible entities must prepare and lodge sustainability reports applying the Australian Sustainability Reporting Standards (AASB S2 — climate-related disclosures). Scope 1, 2 and (from year 2) Scope 3 emissions must be disclosed alongside governance, strategy, and risk management. Auditor assurance phases in.

Applies when the business has the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3). Where the business has asrs maybe, check whether you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees) or report under NGER.

How the regulator frames it: Entities meeting size thresholds and consolidated reporting requirements under the Corporations Act sustainability reporting provisions (s 292A onwards). Group 1: turnover ≥$500M, assets ≥$1B, or NGER publication threshold.

What triggers it: Meeting size thresholds.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Outcome across the 35 industries Rules Mate maps (35 of 35: depends on size or structure).

The answer is the same in every industry: depends on size or structure. Industry does not change who must comply.

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

• Pty Ltd company in real estate agents with 500+ employees, turnover $100M–$1B: applies. Revenue ≥ $50M and 100+ employees — within the ASRS size tests (s 292A)
• Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
• Pty Ltd company in real estate agents with 100–499 employees, turnover $10M–$100M: check whether it applies. applies only if you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees) or report under NGER.
• Pty Ltd company in real estate agents with no employees, turnover $100K–$1M: does not apply. Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

• The business is regulated by APRA: it becomes worth checking, because it applies only if you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees) or report under NGER.

The engine shows this obligation as "check whether this applies" when a business has asrs maybe. It then applies only if you meet 2 of 3 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ employees) or report under NGER. That fact is not something Rules Mate can infer from industry, structure or size.

When due

First reports: FY commencing on or after 1 Jan 2025 (Group 1).

Frequency

Annual

Evidence to keep

Sustainability report with climate disclosures, emissions calculations, scenario analysis documentation.

In force from

1 January 2025

Status

Current

Priority

High

Maximum penalty: ACCC greenwashing actions up to $100M / 30% turnover; ASIC director-duty exposure for poor disclosures.

Independent review. Authority: Corporations Act 2001 ss296A, 301A, 1707E-1707F; ASSA 5000; ASSA 5010; ASIC 'FAQs: Review or audit of sustainability reports' (updated 18 May 2026).

Frequency: Annually. For financial years starting before 1 Jul 2030: review (limited assurance) or audit to the extent ASSA 5010 phases in. Financial years from 1 Jul 2030: full audit (reasonable assurance) of the sustainability report.

Who can perform it: An auditor under the Corporations Act, conducted under ASSA 5000. Lead and review auditors must be registered company auditors; they need not be the financial report auditor.

• AASB S2 first climate disclosures for Group 1 — FY26: 31 August 2026 (annual). First mandatory AASB S2 climate disclosures within annual financial report for years ending 30 June 2026.

If this obligation applies to you, so do these 4: the engine uses the same rule for each.

• ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027
• Scope 3 emissions disclosure (AASB S2 + voluntary)
• AASB S2 Scope 3 emissions + assurance phase-in
• Climate scenario analysis (AASB S2)

• 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.
• 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.

Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:

• Lodge Payment Times Reports (large business): applies to 100% of the same businesses (6.0× the overall rate)
• Publish an annual Modern Slavery Statement: applies to 100% of the same businesses (6.0× the overall rate)

Rules Mate tracks 14 published obligations tagged "climate", 4 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated high priority, and is a annual obligation.

Regulated by Australian Securities and Investments Commission and Clean Energy Regulator.

ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).

CER: Administers NGER (greenhouse and energy reporting), Safeguard Mechanism, ACCUs, and renewable energy targets.

• Australian Securities and Investments Commission
• Clean Energy Regulator

Corporations Act: The foundational federal Act for Australian corporate law.

• Corporations Act 2001

Free tools that help with this obligation:

• Modern Slavery threshold
• Modern Slavery statement scaffold
• Climate reporting tier