One of the most common questions we hear from Australian businesses is: when exactly do we need to be compliant with ASRS mandatory climate reporting? The answer depends on the size of your organisation and which ‘group’ you fall into under the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024.

This article sets out the key ASRS reporting timelines, explains the transition relief provisions that apply in the early years, and helps you understand what you need to have in place — and by when.

The Three-Group Rollout

Australia’s ASRS mandatory climate reporting framework rolls out across three groups of entities, based on size thresholds:

Group 1: Australia’s Largest Entities

Group 1 entities must meet at least two of the following criteria:

• 500 or more employees
• $1 billion or more in consolidated gross assets
• $1 billion or more in consolidated annual revenue

Reporting commencement: Financial years commencing on or after 1 January 2025. For most Group 1 entities with a 30 June financial year end, this means the first ASRS report is due for FY2025 (the year ending 30 June 2025), to be lodged as part of annual reporting typically in late 2025.

Group 1 entities should already be in an advanced state of preparation. First-year disclosures are subject to limited assurance.

Group 2: Mid-to-Large Entities

Group 2 entities must meet at least two of the following criteria:

• 250 or more employees
• $500 million or more in consolidated gross assets
• $500 million or more in consolidated annual revenue

Reporting commencement: Financial years commencing on or after 1 July 2026. For a standard 30 June year-end organisation, the first ASRS-compliant report will be for FY2027, lodged in late 2027.

Group 2 entities have approximately 12–18 months to build their compliance infrastructure. This sounds adequate but is tight given the complexity of Scope 3 measurement and governance documentation. Early action is strongly recommended.

Group 3: Smaller Listed Entities and Others

Group 3 covers smaller listed entities and other organisations captured by the legislation that don’t fall into Groups 1 or 2.

Reporting commencement: Financial years commencing on or after 1 July 2027. This provides additional runway, but the complexity of building quality Scope 3 data from scratch means that preparation should still begin well in advance.

Transition Relief Provisions

The AASB has introduced transition relief provisions to ease the burden of early compliance years. Key provisions include:

• Scope 3 deferral: In the first year of reporting, entities are not required to disclose Scope 3 emissions if they are not yet in a position to do so, provided they disclose the reasons and their plan to achieve Scope 3 reporting in subsequent years.
• Scenario analysis phasing: The requirement to disclose the financial impacts of climate scenario analysis is phased in progressively across the first three years of reporting.
• Comparative information: Entities are not required to provide comparative period information in their first year of ASRS reporting.

While these provisions provide some relief, they should not be used as a reason to delay Scope 3 measurement — the clock is ticking, and investors and auditors will expect progressive improvement in data quality.

What You Need to Have in Place by Your Reporting Date

Regardless of which group you fall into, you need the following in place before you can produce a compliant AASB S2 disclosure:

• Board governance structure for climate oversight, with documented evidence
• Completed climate risk and opportunity assessment
• At least one year of Scope 1 and 2 emissions data, calculated using GHG Protocol-compliant methods
• An assessment of material Scope 3 categories and an initial measurement approach
• Emissions reduction targets (or a credible process for setting them)
• A climate scenario analysis (even if in early stages, with a roadmap for maturation)
• A disclosure document aligned with AASB S2’s four-pillar structure
• External assurance engagement (limited assurance for early reporting years)

Planning Your Preparation Timeline

Working backwards from your reporting deadline, a 12-month preparation timeline for a Group 2 entity might look like:

• Months 1–3: Readiness assessment and gap analysis
• Months 3–6: Governance formalisation and data infrastructure setup
• Months 6–9: First emissions data collection and calculation
• Months 9–11: Scenario analysis and risk/opportunity documentation
• Month 12: Draft disclosure preparation and assurance engagement

💡 Enviro Capture‘s platform is designed to compress this timeline significantly through automation. Most clients achieve their first audit-ready emissions baseline within weeks of onboarding, rather than months. Visit envirocapture.au to discuss your reporting timeline and how we can help.