Home / Insights / Environment & Sustainability
Environment & Sustainability

AASB S2 after year one: what the first climate reports tell us

312 entities have lodged. ASIC has reviewed 40. Almost all named material climate risks, but more than a third described the financial effects in words only. Here is what the first wave of mandatory climate reports tells us, and what to address before your next report.

7 min read Equilibrium Business Solutions

Mandatory climate reporting under AASB S2 started for the largest Australian entities with financial years beginning on or after 1 January 2025. The first reports, for 31 December 2025 year-ends, have now been lodged, assured and reviewed by the regulator. On 21 September 2026 ASIC released Report 839, its review of 40 of those reports.

The verdict is positive. ASIC found a marked improvement in the quality, quantity and consistency of climate information compared with the voluntary era. The detail is where the lessons are, and they apply to every entity still preparing its first report.

Where things stand

The regime phases in over three years. Each group's first reporting period starts on or after the date below, and an entity is in a group if it meets two of the three size tests.

Reporting groups and start dates

Group 1From 1 January 2025. 500 or more employees, $1 billion or more in consolidated gross assets, or $500 million or more in consolidated revenue. NGER reporters above the publication threshold are also in Group 1.
Group 2From 1 July 2026. 250 or more employees, $500 million or more in assets, or $200 million or more in revenue. Other NGER reporters, and asset owners with $5 billion or more in assets, are also in Group 2.
Group 3From 1 July 2027. 100 or more employees, $25 million or more in assets, or $50 million or more in revenue. Group 3 entities with no material climate risks or opportunities can disclose a statement to that effect instead of full climate disclosures.

Group 2 is now inside its first reporting year. Those reports land for 30 June 2027 year-ends.

What ASIC found in the first reports

The numbers that matter

ASIC also called out a specific disconnect. Some entities had recorded weather-related impacts in their financial statements or ASX announcements, but did not identify the same physical risk in their sustainability report. ASIC reads both documents side by side. So will your assurer.

Eight things ASIC wants to see next

Report 839 closes with eight action items. They work well as a pre-lodgement checklist.

  1. Connect the reports. Explain how the sustainability report connects with the financial report, including assumptions used in impairment, useful lives and provisions.
  2. Quantify where you can. Where financial effects are material, consider whether you can disclose amounts or ranges, not just narrative.
  3. Look back as well as forward. Use past events, current conditions and forecasts when identifying climate risks and opportunities.
  4. Show your working. Disclose judgements, assumptions and areas of measurement uncertainty clearly and close to the figures they relate to.
  5. Count legal targets. Climate-related targets include targets you must meet by law, such as Safeguard Mechanism baselines.
  6. Keep material information visible. Do not bury required disclosures under voluntary content.
  7. Cross-reference properly. Cross-referenced material must be available on the same terms and at the same time as the sustainability report.
  8. Drop conflicting disclaimers. Wording such as "readers should not rely on this report" conflicts with the statutory framework and may mislead users.

Assurance and liability: the safe harbour has an end date

Assurance phases in under ASSA 5010. Year one requires limited assurance over Scope 1 and 2 emissions, governance and parts of strategy. The scope widens each year, building to reasonable assurance over the full report for periods from 1 July 2030. In PwC's review of 22 first-wave reports, every one received an unqualified limited assurance opinion.

Liability protection is also temporary. For the first three years, for financial years starting before 1 January 2028, only ASIC can take action over statements about Scope 3 emissions, scenario analysis and transition plans, and directors declare whether the entity has taken reasonable steps to comply. Misleading conduct provisions still apply to everything else.

The enforcement record shows what ASIC expects behind a climate claim. It has secured greenwashing penalties against Vanguard ($12.9 million), Mercer ($11.3 million), Active Super ($10.5 million) and, in August 2026, Fiducian ($7.3 million), the last for failing to monitor holdings against its ESG claims. In contrast, the Federal Court dismissed the greenwashing claims in ACCR v Santos (February 2026, under appeal) because Santos could show reasonable grounds for its targets. The defence is evidence and controls, not disclaimers.

What might change, and what won't

Proposed, not yet law. The 2026-27 Budget proposed raising the large proprietary company thresholds to $100 million revenue and $50 million gross assets, which would take around 1,500 private companies out of Group 3. Treasury has also consulted on assurance (including deferring reasonable assurance to 2035), proportionality guidance and limits on supplier data requests. That consultation closed on 2 October 2026. Government has also announced that Climate Active certification is ending, with a proposed end date of 30 June 2027; consultation on the transition closed on 18 September 2026.

Already final. AASB S2025-1 gives relief on financed emissions and industry classification from 1 January 2027, with early adoption allowed. Government has released voluntary transition planning guidance.

Unchanged. Group 2 and Group 3 start dates have not moved, and ASIC will keep administering the regime as it stands until any law changes.

What to address before your next report

Priorities by reporting group

Group 1Build the Scope 3 inventory, quantify financial effects where they are material, and prepare data and controls for the widening scope of assurance.
Group 2Your first reporting year is already running. Confirm data owners, scenario analysis and board governance now, and run a dry-run report against ASIC's eight action items.
Group 3Re-test your position under both the current and proposed thresholds. Either way, start the no-regret work: governance, a Scope 1 and 2 baseline and a climate risk register.
SuppliersExpect Scope 3 data requests from customers. A credible emissions estimate is becoming a commercial requirement, whatever the thresholds end up being.

The first reports are a baseline, not a benchmark. ASIC has said it expects improvement as entities gain experience, and its next review covers 30 June 2026 year-ends. The gaps it has named are the ones it will look for next.

Need support with AASB S2 climate reporting?

We work with organisations on climate risk and materiality assessments, scenario analysis, GHG inventories and AASB S2 disclosure preparation, from first-year readiness through to assurance.

Start a conversation

Sources: ASIC Report 839 and media release 26-222MR (21 September 2026); ASIC early observations on sustainability reporting (18 May 2026); PwC, AASB S2 unpacked (March 2026); ASIC media release 25-042MR; Federal Court, ACCR v Santos (February 2026); Treasury, Improving the efficiency of climate-related financial disclosures (2026); AASB S2025-1. Information current at 7 October 2026. This article is general information, not advice.

Start a conversation →