Who must comply with Scope 3 emissions disclosure (AASB S2 + voluntary)?
The applicability test for Scope 3 emissions disclosure (AASB S2 + voluntary) (ASIC and CER), 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
Scope 3 emissions become mandatory year 2 of ASRS reporting (varies by Group).
AASB S2 mandates Scope 3 disclosure from year 2 of reporting per Group. Categories per GHG Protocol. Supply chain pressure from Group 1 + 2 reporters creates de facto Scope 3 reporting obligation on SMB suppliers.
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: ASRS Group 1+2+3 reporters + suppliers under pressure to disclose.
What triggers it: Group reporting onset + supply chain Scope 3 mapping.
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
- Per ASRS phase-in.
- Frequency
- Annual
- Evidence to keep
- Scope 3 inventory; supplier data + survey results; calculation methodology.
- Status
- Upcoming (not yet in force)
- Priority
- High
Penalty for not complying
Maximum penalty: Same regime as broader ASRS climate disclosure obligations.
Audit or assurance level
Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.
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 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 Scope 3 emissions disclosure (AASB S2 + voluntary)?
- 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 Scope 3 emissions disclosure (AASB S2 + voluntary) apply to sole traders?
- No. Across every industry and every size band, the engine's answer for a sole trader is: no.
- Does Scope 3 emissions disclosure (AASB S2 + voluntary) apply to businesses with 1–5 employees?
- No (1–5 employees, turnover $100K–$1M).
- When is "Scope 3 emissions disclosure (AASB S2 + voluntary)" due?
- Per ASRS phase-in.
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.