Australia's ASRS climate reporting, explained

What ASRS is

The Australian Sustainability Reporting Standards are issued by the Australian Accounting Standards Board. There are two. AASB S2 — Climate-related Disclosures is the one that matters commercially: it is the standard behind Australia's mandatory climate reporting. AASB S1 covers general sustainability-related financial disclosures and is voluntary.

Both are built on the ISSB's IFRS S1 and S2, so the structure will be familiar if you have seen the ISSB baseline: governance, strategy, risk management, and metrics & targets. The legal obligation is not in the standard itself — it sits in the Corporations Act, which requires an in-scope entity to lodge a sustainability report alongside its financial report.

Who is in scope, and from when

Scope is phased across three groups. Within each, the size test is two of the three thresholds below, measured on a consolidated basis.

Are you in scope? Probably not — but read on

If you are a small or mid-sized Australian business, the honest answer is almost certainly no. Group 3, the widest tier, still requires Chapter 2M lodgement plus two of A$50m revenue, A$25m gross assets, or 100 employees, and it does not begin until periods starting on or after 1 July 2027.

That is not why the topic reached you. It reached you because your customer is in scope. An in-scope entity must disclose Scope 3 emissions from its second reporting year, and for most organisations the dominant Scope 3 category is purchased goods and services — which is to say, its suppliers. The only way to move that figure off industry averages is to ask suppliers directly. How Scope 3 works, and what a supplier is actually being asked for, covers that in full.

What AASB S2 asks for

The four ISSB pillars, applied to climate: governance of climate-related risks and opportunities; strategy, including financial effects; risk management; and metrics & targets, which includes Scope 1, Scope 2 and Scope 3 greenhouse-gas emissions.

The regime includes first-year reliefs that are worth knowing about even as a supplier, because they explain your customer's timeline: comparative information is not required for the first reporting period, Scope 3 disclosure is deferred to the second year, and there is relief around detailed scenario analysis in year one. In practice that means a customer entering scope this year will come asking for your data in earnest next year — which is the window in which to get your numbers in order.

NGER is a different scheme

These two get conflated constantly. NGER — National Greenhouse and Energy Reporting — is an emissions and energy reporting obligation administered by the Clean Energy Regulator, and it is triggered by activity, not by financial size:

• Corporate group: 50 kilotonnes CO₂-e or more, or 200 terajoules of energy produced or consumed.
• Single facility: 25 kilotonnes CO₂-e or 100 terajoules.

NGER registration is one of the routes into ASRS scope, which is why the two are linked. But an SME sitting well below these thresholds — which is virtually every SME — has no NGER obligation and will still receive ASRS-driven requests from customers. Being below NGER is not an answer to a customer asking for your footprint.

The one thing an Australian supplier should get right

Your Scope 2 factor. Australia does not have a single grid, and the spread is extraordinary — from hydro-dominated Tasmania to brown-coal Victoria is a difference of nearly four times. A national-average figure is defensible as a fallback, but using your actual grid is the largest single accuracy gain available to you, and increasingly buyers ask which you used.

One honest methodology note while you are here: our Australian calculations use AR5 global-warming potentials to stay aligned with NGER. ASRS moves to AR6. The difference is negligible for CO₂ and modest for methane, but if a customer specifies AR6 it is worth flagging which basis your figure uses rather than letting them assume.

What to do about it

If you are a supplier, the task is smaller than the acronyms suggest. Produce a defensible Scope 1 and Scope 2 figure for a stated twelve-month period, using your state factor, and keep the method on the record. That single artefact answers the great majority of ASRS-driven supplier requests, and it is built from bills you already have.

To be explicit about the boundary: this supports a supplier's response to a customer request. It is not a sustainability report, and an entity that is genuinely in ASRS scope needs its own AASB S2 reporting process with appropriate professional support. If you are unsure which side of that line you are on, the vendor questionnaire guide shows what a proportionate request looks like, and the Regulations Hub covers the frameworks your other customers may name.

Frequently asked questions

Thresholds, commencement dates and reliefs summarised here were reviewed on July 30, 2026 against ASIC guidance and the Corporations Act as reported at that date. They are set by legislation and can change; this page is orientation, not legal or accounting advice, and scope should be confirmed with ASIC guidance or a qualified adviser. AASB, ASIC, the Clean Energy Regulator and DCCEEW are independent of EcoDiligence.

EcoDiligence ESG Passports are self-reported summaries structured for ESG disclosure workflows. Content is not independently assured. Information aligned with EFRAG VSME and IFRS S2 (ISSB) frameworks does not constitute formal compliance or certification.