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Regulatory Framework · Australia

Australia's ASRS climate reporting, explained

AASB S1 and AASB S2 are Australia's ISSB-aligned sustainability standards, and AASB S2 sits behind a mandatory climate-disclosure regime that is phasing in through 2027. Here are the groups and dates, how NGER differs, and — if you are a supplier rather than an in-scope entity — what you actually need to produce.

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Build your Scope 1–2 dataSee the ISSB baseline it builds on

Summary for orientation only, current at the review date above. Thresholds and phase-in dates are set by legislation and can change — confirm scope with ASIC guidance or a qualified adviser. Not legal or accounting advice.

The short version
  • AASB S2 (climate) is mandatory for in-scope entities; AASB S1 (general sustainability) is voluntary. Both are built on the ISSB baseline.
  • Scope phases in three groups — Jan 2025, Jul 2026, Jul 2027 — by size, plus NGER registration and large asset owners.
  • It only reaches entities that already lodge financial reports under Chapter 2M. Most small proprietary companies do not, so most SMEs are out of scope.
  • What reaches an SME is a customer request — and those have been rising since Group 2 commenced in July 2026.
  • NGER is a different scheme with activity thresholds. Being below them does not stop the requests.

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.

ASRS scope groups, commencement dates and size thresholds
GroupApplies fromRevenueGross assetsEmployees
Group 1Periods starting on or after 1 Jan 2025A$500m+A$1bn+500+
Group 2Periods starting on or after 1 Jul 2026A$200m+A$500m+250+
Group 3Periods starting on or after 1 Jul 2027A$50m+A$25m+100+
  • Group 1 also catches: NGER-registered corporations above the publication threshold.
  • Group 2 also catches: Remaining NGER-registered corporations; large asset owners.

The precondition everyone skips

Meeting the size thresholds is not enough on its own. The obligation applies only to entities that are already required to prepare annual financial reports under Chapter 2M of the Corporations Act. Entities outside Chapter 2M — including most small proprietary companies, and foreign companies without local lodgement duties — are not required to prepare a sustainability report regardless of the numbers. This is the actual reason most SME readers of this page are out of scope, and it is worth confirming before anyone commits to a reporting project.

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.

Why the requests picked up this year

Group 1 was a relatively small population of very large entities. Group 2, live for periods starting from 1 July 2026, is far broader — down to A$200m revenue or 250 employees, plus the remaining NGER-registered corporations. A large tranche of Australian mid-market buyers entered scope at once, and each of them now needs supplier data. If your customers started asking recently and you could not work out why, this is why.

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.

ASRS (AASB S2) inputs

IFRS S2 is written for listed companies. What your customers need from you for their IFRS S2 or ASRS reports — Scope 1–2 emissions, GHG targets with a baseline, and how climate is governed and managed — is in your Passport.

Governance
Inputs provided
Paragraphs 5–7 · Pro · IFRS S2 moduleWhether a board or owner oversees climate issues, with a note on how, and who is responsible for sustainability.
Strategy
Inputs provided
Paragraphs 8–23 · Pro · IFRS S2 moduleClimate risks and opportunities identified, a climate strategy with its timeline and resources, and any scenario analysis.
Risk management
Readiness indicator
Paragraphs 24–26 · Pro · IFRS S2 moduleWhether a process exists to identify and manage climate risks — a yes/no answer, without a description.
Metrics and targets
Core metrics provided
Paragraphs 27–37 · Partly on every Passport; the rest with Pro · IFRS S2 moduleScope 1 and Scope 2 emissions estimated from energy and fuel use, and GHG reduction targets with a baseline year.
One answerHeating and vehicle fuelsAsked once in the Passport, turned into Scope 1 emissions.
VSME B3
SEDG E1.1SEDG and ASEDG
IFRS S2 §29(a)
AASB S2 (ASRS)based on IFRS S2
The same Scope 1 figure serves each of these requirements; you answer the fuel questions once.

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.

Scope 2 location-based factors, kgCO₂e/kWh

  • Tasmania0.20
  • South Australia0.22
  • Western Australia0.50
  • Northern Territory0.56
  • NSW & ACT0.64
  • Queensland0.67
  • Victoria0.78
  • National average0.62

Source: NGA Factors 2025 (DCCEEW), applying to the 2025–26 NGER reporting year. Location-based Scope 2 only. WA is represented by the SWIS grid; NT by DKIS. Full provenance on the Methodology page.

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.

AU Smart Pack

Scope 1 and 2 calculated on DCCEEW National Greenhouse Accounts Factors, with optional state and territory grids.

ASRS-flavoured questions

Pro adds an ISSB Transition Readiness layer extended for ASRS: climate governance, risk process, scenario analysis, value-chain engagement.

One profile, many buyers

Scope 1 and 2 on DCCEEW factors alongside the VSME structure, and a shareable link and PDF you reuse for every customer that asks.

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. Some buyers pair a regulatory request like this with a third-party rating requirement such as EcoVadis — see how that compares to a self-service Passport.

Frequently asked questions

ASRS stands for the Australian Sustainability Reporting Standards, issued by the Australian Accounting Standards Board. There are two: AASB S2 Climate-related Disclosures, which underpins Australia's mandatory climate reporting, and AASB S1, which covers general sustainability-related financial disclosures and is voluntary. Both are built on the ISSB's IFRS S1 and S2, so an entity familiar with the ISSB baseline will recognise the structure. The legal obligation itself sits in the Corporations Act, which requires in-scope entities to lodge a sustainability report.

Entities that are already required to lodge financial reports under Chapter 2M of the Corporations Act and that meet at least two of three size thresholds, phased in three groups. Group 1 applies to periods starting on or after 1 January 2025 at A$500m revenue, A$1bn gross assets or 500 employees. Group 2 applies from 1 July 2026 at A$200m, A$500m or 250 employees. Group 3 applies from 1 July 2027 at A$50m, A$25m or 100 employees. NGER-registered corporations are also caught, as are large asset owners. Entities outside Chapter 2M — including most small proprietary companies — are not required to prepare a sustainability report.

Generally not directly. The obligation only reaches entities that already lodge financial reports under Chapter 2M of the Corporations Act, and most small proprietary companies do not. What reaches a small Australian business is the downstream effect: its in-scope customers need supplier data to complete their own disclosures, so they ask. That request is commercial rather than legal, but it is real, and it has been increasing since Group 2 commenced.

Most likely because they entered scope. Group 1 entities began reporting for periods starting from January 2025, and Group 2 — a much larger population, down to A$200m revenue or 250 employees — came in from 1 July 2026. In-scope entities must report Scope 3 emissions from their second reporting year, and the largest Scope 3 category for most businesses is purchased goods and services. That is you. Supplier requests are the mechanism by which they replace industry-average estimates with real numbers.

The same four pillars as the ISSB baseline: governance of climate-related risks and opportunities, strategy and its financial effects, risk management, and metrics and targets including Scope 1, Scope 2 and Scope 3 greenhouse-gas emissions. There are first-year reliefs designed to make the transition workable — 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.

No — they are separate schemes that happen to overlap. NGER, the National Greenhouse and Energy Reporting scheme, is an emissions and energy reporting obligation administered by the Clean Energy Regulator, triggered by activity thresholds: 50 kilotonnes CO₂-e or 200 terajoules of energy for a corporate group, and 25 kilotonnes or 100 terajoules for a single facility. ASRS is financial-report-style climate disclosure under the Corporations Act. NGER registration is one of the routes into ASRS scope, but an SME below the NGER thresholds has no NGER obligation and may still receive ASRS-driven data requests from customers.

The National Greenhouse Accounts Factors published by DCCEEW. The national average is a reasonable fallback, but Australia's grid varies enormously by region — from roughly 0.20 kgCO₂e/kWh in hydro-dominated Tasmania to about 0.78 in brown-coal-heavy Victoria, a spread of nearly four times. Using your state or grid factor rather than the national average is the single largest accuracy improvement available to an Australian business calculating Scope 2, and buyers increasingly ask which you used.

Australia is a dedicated Smart Pack. Profiles calculate Scope 1 and Scope 2 using the DCCEEW National Greenhouse Accounts Factors, with optional state and territory factors across the NEM, SWIS and DKIS grids, and sit alongside the VSME structure. Pro adds an ISSB Transition Readiness layer extended with ASRS-flavoured questions covering climate governance, risk process, scenario analysis and value-chain engagement. Everything is self-reported and clearly marked as not independently assured — it supports a response to a customer request, and is not a substitute for an in-scope entity's own sustainability report.

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, built on the EFRAG VSME Basic Module with optional IFRS S2 climate inputs. Content is not independently assured and does not constitute compliance, certification or an audit.

Answer your Australian customers with a real number

Scope 1 and Scope 2 on the DCCEEW factors, with your state grid and the method on the record. Free to start.

Create free PassportSee the factor sources