How to Prepare for ASRS: Group 3 Reporters

A practical guide for Group 3 entities on meeting Australian Sustainability Reporting Standards requirements.

If your organisation meets at least two of the Group 3 thresholds — $50 million revenue, $25 million gross assets, or 100 employees — you will need to lodge your first sustainability report for financial years starting on or after 1 July 2027. Here is a practical guide to getting ready.

When does reporting begin?

Group 3 entities begin reporting for financial years starting on or after 1 July 2027. For a standard 30 June year-end, this means your first sustainability report will cover FY2027–28 and be published alongside your annual financial report in late 2028.

While this may seem distant, the preparation required — data systems, governance structures, and assurance readiness — takes time. Starting now gives you the advantage of learning from the experiences of Group 1 (reporting from January 2025) and Group 2 (from July 2026).

What transition reliefs are available?

Group 3 receives the most generous transition reliefs under the Treasury Laws Amendment Act 2024:

Scope 3 emissions — relief from reporting Scope 3 for the first two reporting years. You must report Scope 1 and 2 from day one, but Scope 3 is deferred until your third year of reporting
Scenario analysis — qualitative scenario analysis is permitted for an extended initial period, giving you more time before quantitative analysis is required
Comparative information — not required in your first reporting year
Safe harbour (modified liability) — Scope 3 disclosures and forward-looking statements (transition plans, scenario analysis) are protected from civil liability, provided they are made in good faith and on reasonable grounds. Only ASIC can take non-criminal enforcement action during the transition period

What you need to disclose

Your sustainability report must comply with AASB S2 and cover:

Governance — how your board and management oversee climate-related risks
Strategy — climate risks and opportunities, their impact on your business model, and your transition plan
Risk management — how you identify, assess, and manage climate risks
Metrics and targets — Scope 1 and 2 emissions (Scope 3 deferred), plus any climate-related targets

Assurance requirements

From your first reporting year, you will need limited assurance on your Scope 1 and Scope 2 emissions. The pathway to reasonable assurance is phased in over subsequent years. The AUASB has published guidance on what assurance providers will expect.

A practical preparation timeline

Now – mid 2026: Build foundations

Determine your group — confirm you meet at least two of the three thresholds at the consolidated level
Assign responsibility — designate a sustainability lead or team, even if initially part-time
Audit your data — identify what emissions data you already have (energy bills, fuel records, fleet data) and where the gaps are
Learn from Group 1 — review published Group 1 sustainability reports for examples of how to structure your disclosures

Mid 2026 – mid 2027: Develop capabilities

Implement data collection — set up systems to capture Scope 1 and 2 emissions data on an ongoing basis. Consider carbon accounting software to automate this
Engage your board — establish governance structures for climate risk oversight. Your board will need to demonstrate understanding and oversight
Conduct a climate risk assessment — identify material climate-related risks and opportunities relevant to your business
Begin scenario analysis — start with qualitative scenarios to understand how different climate pathways could affect your organisation

Mid 2027 – first report: Execute

Calculate Scope 1 and 2 emissions using NGA Factors
Prepare your sustainability report aligned with AASB S1 and S2
Engage an assurance provider — do this early, as demand will be high
Start collecting Scope 3 data — even though it is not required in year one, beginning early will smooth the transition

Common pitfalls to avoid

Waiting too long — data collection and governance structures take 12–18 months to establish properly
Underestimating Scope 3 — even with two years of relief, Scope 3 typically requires significant supplier engagement and data collection
Treating it as a compliance exercise only — climate reporting can surface genuine business risks and cost-saving opportunities