ASRS Compliance Checklist: Is Your Business Ready for Mandatory Climate Reporting?

Australia's mandatory climate reporting regime is now in force, and the deadlines are closer than many businesses realise. Whether you're in Group 1 (reporting from FY2025), Group 2 (FY2026), or Group 3 (FY2027), the time to prepare is now. 

This checklist walks you through the key areas you need to address to achieve AASB S2 compliance. Use it to identify gaps and prioritise your workplan. 

How to Use This Checklist 

For each item, assess your current status: Ready (fully in place), In Progress (partially addressed), or Not Started. The more 'Not Started' items you have, the more urgently you need to begin your compliance program. If you are a Group 1 entity, many of these items should already be in place. 

Section 1: Governance 

  • Board oversight: Does your board have documented responsibility for overseeing climate-related risks and opportunities? 
  • Management roles: Are there named individuals in management who are responsible for climate risk management and reporting? 
  • Board skills: Has your board assessed its climate literacy and identified any gaps that need to be addressed? 
  • Reporting to board: Is there a regular cadence of climate risk reporting from management to the board? 
  • Integration with financial governance: Is climate risk integrated into your existing enterprise risk management and financial reporting governance structures? 

💡 Why it matters: AASB S2 governance disclosures require specific, verifiable evidence of board and management oversight   not general statements. Auditors will look for board minutes, committee charters, and documented processes. 

Section 2: Strategy and Scenario Analysis 

  • Climate risk identification: Have you formally identified the physical and transition climate risks that could affect your business? 
  • Climate opportunity identification: Have you assessed the opportunities that arise from the transition to a low-carbon economy? 
  • Scenario analysis: Have you conducted formal climate scenario analysis (e.g. 1.5°C, 2°C, and 4°C pathways) to test your business model's resilience? 
  • Financial impact assessment: Have you quantified the potential financial impacts of identified climate risks and opportunities? 
  • Strategy integration: Is your climate risk and opportunity assessment integrated into your overall strategic planning process? 

Section 3: Emissions Data (Metrics and Targets) 

  • Scope 1 measurement: Do you have a methodology and data collection process for all direct GHG emissions from owned or controlled sources? 
  • Scope 2 measurement: Are you collecting and calculating indirect emissions from purchased electricity and energy? 
  • Scope 3 assessment: Have you identified which of the 15 Scope 3 categories are material to your business? 
  • Scope 3 measurement: Are you collecting supplier and value chain data for material Scope 3 categories? 
  • GHG Protocol alignment: Are your emissions calculations using GHG Protocol-compliant methodologies and emission factors? 
  • Data quality: Is your emissions data sufficiently accurate and traceable to withstand external assurance? 
  • Historical baseline: Do you have at least one year of baseline emissions data to report against? 
  • Targets: Have you set credible, science-aligned emissions reduction targets? 

💡 Common gap: Scope 3 data is where most organisations are least prepared. Under AASB S2, material Scope 3 categories must be disclosed. Start by identifying your top categories by spend and engage suppliers early. 

Section 4: Reporting Infrastructure 

  • Carbon accounting system: Do you have a dedicated platform (not just spreadsheets) to collect, calculate, and store your emissions data? 
  • Audit trail: Is every emissions figure traceable back to source documentation with a clear, defensible evidence chain? 
  • Assurance readiness: Is your data and reporting process ready for third-party limited or reasonable assurance? 
  • Report format: Have you mapped your disclosures to the AASB S2 framework and confirmed all 149 required data points? 
  • Integration with financial report: Are you prepared to include climate disclosures in your annual report alongside financial statements? 

Section 5: Transition Planning 

  • Net zero target: Do you have a board-approved net zero target with a specific year and clear scope? 
  • Transition plan: Do you have a credible, detailed transition plan showing how you will achieve your net zero target? 
  • Capital allocation: Does your business plan reflect investment in emissions reduction aligned with your targets? 
  • Supply chain strategy: Do you have a plan to engage and support your supply chain in reducing Scope 3 emissions? 

Scoring Your Readiness 

Count the number of items in each category: if more than half are 'Not Started', that category needs immediate attention. If you are a Group 2 entity (reporting from FY2026), you have approximately 12–18 months to address these gaps. That sounds like a lot of time, but given the complexity of Scope 3 data collection and governance documentation, it passes quickly. 

💡 Enviro Capture: Enviro Capture's platform directly addresses Sections 3 and 4 of this checklist   automating Scope 1, 2 and 3 data collection, maintaining audit-ready evidence chains, and generating AASB S2-aligned reports. Book a free demo at envirocapture.au. 

By Published On: March 31, 2026
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