Does ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027 apply to businesses with 1–5 employees?

No (1–5 employees, turnover $100K–$1M).

Who must comply with ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027?

What the obligation is

Group 3 (smaller entities) start climate disclosure FY28.

Group 3 thresholds (revenue ≥$50M, assets ≥$25M, ≥100 employees — any two of three under Ch 2M-equivalent test) start AASB S2 sustainability reporting for FYs commencing on/after 1 July 2027. Reduced Scope 3 obligations in year 1.

The applicability test

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: Group 3 entities meeting any two of three thresholds.

What triggers it: First FY commencing on/after 1 July 2027.

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: 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.

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 size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Partnership	No	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Trust	No	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Pty Ltd company	Depends on size or structure	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Public company	Depends on size or structure	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Not-for-profit (unregistered)	No	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Registered charity	No	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Super fund	Depends on size or structure	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)
Foreign company	Depends on size or structure	Requires the ASRS size tests (revenue ≥ $50M, assets ≥ $25M, 100+ employees — 2 of 3)

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)	Depends on size or structure

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 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)

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 ASRS size tests (revenue ≥ $50M, gross assets ≥ $25M, 100+ 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 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.

What you must do, and when

When due: First report alongside FY28 annual financial report.
Frequency: Annual
Evidence to keep: AASB S2 disclosures; auditor's limited assurance.
In force from: 1 July 2027
Status: Upcoming (not yet in force)
Priority: High

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.

Obligations with the same applicability test

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

Obligations that usually travel with it

What usually applies alongside it

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:

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 high 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.

Corporations Act 2001

Free tools that help with this obligation:

Run the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.

Questions

Who must comply with ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027?: 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.
Does ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027 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 3 climate disclosure — FY commencing on/after 1 July 2027 apply to businesses with 1–5 employees?: No (1–5 employees, turnover $100K–$1M).
When is "ASRS Group 3 climate disclosure — FY commencing on/after 1 July 2027" due?: First report alongside FY28 annual financial report.

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.