Who must comply with Climate scenario analysis (AASB S2)?
The applicability test for Climate scenario analysis (AASB S2) (ASIC), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Some businesses
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.
What the obligation is
S2 mandates climate scenario analysis at least 1.5°C-aligned + an additional scenario.
AASB S2 requires entities to conduct climate-related scenario analysis at least once per year (or when material change). Methodology consistent with TCFD framework.
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 1/2/3 entities phasing per AASB S2.
What triggers it: Annual AASB S2 reporting cycle.
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
- Annually within climate disclosure cycle.
- Frequency
- Annual
- Evidence to keep
- Scenario analysis methodology + outputs + governance review.
- Status
- Current
- Priority
- High
Penalty for not complying
No maximum penalty is recorded for this obligation in the Rules Mate corpus; check the regulator source below.
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.
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.
ASIC: Corporate regulator administering the Corporations Act, financial services and credit licensing (AFSL/ACL), markets supervision, insolvency, and registries (ASIC and ABRS).
Corporations Act: The foundational federal Act for Australian corporate law.
Free tools that help with this obligation:
Questions
- Who must comply with Climate scenario analysis (AASB S2)?
- 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 Climate scenario analysis (AASB S2) apply to sole traders?
- No. Across every industry and every size band, the engine's answer for a sole trader is: no.
- Does Climate scenario analysis (AASB S2) apply to businesses with 1–5 employees?
- No (1–5 employees, turnover $100K–$1M).
- When is "Climate scenario analysis (AASB S2)" due?
- Annually within climate disclosure cycle.
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.