Mandatory Sustainability Reporting 2025

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Meet Australia’s AASB S1 & S2 climate‑risk disclosure standards with Claritas ESG – the AI chatbot that cuts research time, clarifies requirements and helps you report with confidence.

0%

of ASX 200 companies have a Net‑Zero target

0%

disclose some Scope 3 emissions

0%

have undertaken & disclose scenario analysis

Defining ESG & Its Importance

ESG (Environmental, Social, Governance) is a framework for assessing non‑financial factors that influence a company’s long‑term value. ESG initiatives enhance resilience, strengthen stakeholder trust and drive operational efficiency.

Ask our ESG Chatbot:

“What Environmental & Social factors are most material for an ASX‑listed mining company?”

Environmental
  • Climate mitigation & GHG emissions
  • Energy & resource efficiency
  • Biodiversity & natural capital
Social
  • Diversity, equity & inclusion
  • Human rights & modern slavery
  • Workplace health & safety
Governance
  • Board oversight & diversity
  • Anti‑corruption & tax transparency
  • ESG‑linked remuneration

Australia’s Mandatory Sustainability Reporting

The Australian Sustainability Reporting Standards (ASRS), aligned to IFRS S1/S2, apply from 1 Jan 2025 for Group 1 entities.

AASB S1

General Sustainability‑related Financial Disclosure

Requires entities to disclose material sustainability risks & opportunities across short, medium & long‑term horizons.

AASB S2

Climate‑related Disclosures

Focuses on governance, strategy, risk management, metrics & targets – including GHG emissions.

Effective 1 Jan 2025

Who Needs to Report & When?

Group 1

From 1 Jan 2025

500+ employees, $1bn+ assets or $500m+ revenue; NGER reporters.

Limited assurance initially.

Group 2

Est. 1 Jul 2026

250‑500 employees, $500m‑$1bn assets or $200m‑$500m revenue.

Follows Group 1 path.

Group 3

Est. 1 Jul 2027

100‑250 employees, $25m‑$500m assets or $50m‑$200m revenue.

Assurance phases in.

Thresholds for Groups 2 & 3 are indicative pending legislation.

Ask our ESG Chatbot:

Based on our company size (employees, assets, revenue) which reporting group applies and when is our first ASRS deadline?

Deep‑dive – AASB S2 Climate Disclosure Pillars

Understand the four key areas required under AASB S2.

Governance

Key disclosure elements:

  • Board & committee oversight of climate risks
  • Management competencies & roles
  • Integration into strategic decisions

Practical Tips

  • Update governance frameworks & charters
  • Link executive remuneration to climate KPIs

Ask our ESG Chatbot:

How should we structure ESG governance to satisfy AASB S2?

Director Duties & AASB S2 Liability Framework

Understanding the comprehensive governance requirements and liability protections for boards navigating mandatory sustainability reporting in Australia.

Board & Director Responsibilities

ASIC guidance (RG 280.55) emphasizes that directors must apply an inquiring mind to sustainability reports while making independent assessments even when relying on expert information.

Key Director Obligations:

  • Understand climate-related risks (physical & transition) that could affect the entity's prospects
  • Establish systems to identify, assess and monitor material financial risks and opportunities
  • Implement controls, policies and procedures for sustainability reporting and record-keeping
  • Apply critical lens to methodologies, inputs, assumptions and potential material omissions
  • APRA-regulated entities: additionally refer to CPG 229 Climate change financial risks

Directors' Declaration Requirements

The declaration requirements follow a phased implementation approach:

Before 1 January 2028

Directors must declare that, in their opinion, the entity has taken reasonable steps to ensure the sustainability report complies with the Corporations Act and AASB S2.

From 1 January 2028

Directors must declare whether, in their opinion, the sustainability report is in accordance with the Corporations Act and AASB S2.

Companies should develop clear policies defining what constitutes "reasonable steps" for director due diligence, similar to prospectus verification processes but adapted to AASB S2 requirements.

Ask our ESG Chatbot:

What specific documentation should our board maintain to demonstrate "reasonable steps" for AASB S2 compliance?

Modified Liability Regime

Australia's transitional framework provides temporary civil liability protection for specific "protected statements" during the implementation phase:

Protected Statement Types & Timeframes
Statement TypeProtection Period
Forward-looking climate statements1-Jan to 31-Dec 2025 only
Scope 3 emissions disclosures1-Jan 2025 to 31-Dec 2027
Scenario analysis1-Jan 2025 to 31-Dec 2027
Transition plan disclosures1-Jan 2025 to 31-Dec 2027

Important Liability Limitations

  • Protection applies only to statements made for the purpose of complying with sustainability standards
  • Statements outside sustainability reports are protected only when required by Commonwealth law
  • Voluntary disclosures, summarized statements, and expanded content are not protected
  • Cross-referenced statements in sustainability reports do not receive liability protection

Governance Best Practices

  • Create clear protocols for creating, identifying, and updating protected statements
  • Establish board committee oversight of sustainability reporting
  • Document board challenge processes for climate-related disclosures
  • Implement verification processes similar to prospectus due diligence
  • Maintain decision records regarding voluntary vs. mandatory disclosures

Ask our ESG Chatbot:

What board committee structure is most effective for climate risk governance under AASB S2?

Frequently Asked Questions: Director Duties

How often should boards review climate-related risks?

Most ASX 200 companies now conduct board-level reviews of climate risks quarterly, with in-depth reviews annually. Learn more from our ESG chatbot.

What constitutes "reasonable steps" for a sustainability report?

While not explicitly defined by ASIC, appropriate verification processes typically include board approval of methodologies, external review of data, and documented challenge sessions. Consult our chatbot for industry-specific guidance.

Indirect Impact Through the Value Chain

Even non‑reporters will face data requests from customers, financiers & insurers preparing their own ASRS reports.

Typical Information Requests
  • GHG emissions inventory & assurance (Scopes 1‑3)
  • Emission‑reduction strategies & targets
  • Climate resilience & transition plans
  • Energy consumption & intensity metrics
  • Internal climate governance policies

Ask our ESG Chatbot:

As a supplier, which Scope 3 data will ASX customers request and how can we prepare?

Sustainable Supply Chain

Optimizing operations for environmental efficiency

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