Who must comply with ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026?
The applicability test for ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026 (ASIC and CER), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Only if
Applies when the business has the ASRS Group 2 size tests. Where the business has the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3) or asrs maybe, check whether you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
What the obligation is
Group 2 (mid-tier entities) start climate disclosure FY27.
Group 2 thresholds (revenue ≥$200M, assets ≥$500M, ≥250 employees, or NGER controlling corporation) start AASB S2 sustainability reporting for FYs commencing on/after 1 July 2026. Limited assurance year 1 + Scope 3 from year 2.
The applicability test
Applies when the business has the ASRS Group 2 size tests. Where the business has the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3) or asrs maybe, check whether you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
How the regulator frames it: Group 2 entities meeting any threshold.
What triggers it: First FY commencing on/after 1 July 2026.
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (35 of 35: only if a further fact applies).
The answer is the same in every industry: only if a further fact applies. Industry does not change who must comply.
Business structure and size
| Structure | Answer across all industries, any size | Engine's reason (real estate agents, 6–19 employees) |
|---|---|---|
| Sole trader | No | Requires the ASRS Group 2 size tests |
| Partnership | No | Requires the ASRS Group 2 size tests |
| Trust | No | Requires the ASRS Group 2 size tests |
| Pty Ltd company | Only if a further fact applies | Requires the ASRS Group 2 size tests |
| Public company | Only if a further fact applies | Requires the ASRS Group 2 size tests |
| Not-for-profit (unregistered) | No | Requires the ASRS Group 2 size tests |
| Registered charity | No | Requires the ASRS Group 2 size tests |
| Super fund | Only if a further fact applies | Requires the ASRS Group 2 size tests |
| Foreign company | Only if a further fact applies | Requires the ASRS Group 2 size tests |
| Size band | Answer across all industries, any structure |
|---|---|
| No employees (turnover $100K–$1M) | No |
| 1–5 employees (turnover $100K–$1M) | No |
| 6–19 employees (turnover $1M–$3M) | No |
| 20–99 employees (turnover $3M–$10M) | No |
| 100–499 employees (turnover $10M–$100M) | Only if a further fact applies |
| 500+ employees (turnover $100M–$1B) | Only if a further fact applies |
Worked examples
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 6–19 employees, turnover $1M–$3M: does not apply. Requires the ASRS Group 2 size tests.
- 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 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
- Pty Ltd company in real estate agents with 500+ employees, turnover $100M–$1B: check whether it applies. applies only if you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
Answers that bring it into scope
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 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
When you need to check further
The engine shows this obligation as "check whether this applies" when a business has the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3) or asrs maybe. It then applies only if you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER. That fact is not something Rules Mate can infer from industry, structure or size.
What you must do, and when
- When due
- First report alongside FY27 annual financial report.
- Frequency
- Annual
- Evidence to keep
- AASB S2 disclosures; auditor's limited assurance.
- In force from
- 1 July 2026
- Status
- Current
- Priority
- Critical
Penalty for not complying
Maximum penalty: Same penalty regime as ASRS Group 1.
Audit or assurance level
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.
Where it sits in the corpus
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 critical priority, and is a annual obligation.
Regulator, legislation and tools
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.
Corporations Act: The foundational federal Act for Australian corporate law.
Free tools that help with this obligation:
Questions
- Who must comply with ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026?
- Applies when the business has the ASRS Group 2 size tests. Where the business has the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3) or asrs maybe, check whether you meet 2 of 3 Group 2 tests (revenue ≥ $200M, gross assets ≥ $500M, 250+ employees) or report under NGER.
- Does ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026 apply to sole traders?
- No. Across every industry and every size band, the engine's answer for a sole trader is: no.
- Does ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026 apply to businesses with 1–5 employees?
- No (1–5 employees, turnover $100K–$1M).
- When is "ASRS Group 2 climate disclosure — FY commencing on/after 1 July 2026" due?
- First report alongside FY27 annual financial report.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.