ASRS Compliance: The Plain-English Guide for Australian Companies

ASRS (the Australian Sustainability Reporting Standards) is Australia's mandatory climate reporting regime. It puts climate disclosure inside the annual report, assured like the financial statements, under a standard called AASB S2. It's being phased in by size across three groups from 2025. This is the plain-English overview: who's caught, what you have to disclose, and the timeline that decides how long you've got.

What ASRS actually is

ASRS is the Australian implementation of the global ISSB baseline (IFRS S2), legislated through the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024. In practice it means three things. Your climate disclosures sit in the annual report, not a glossy standalone PDF. They must follow AASB S2, which is built on the same four pillars as the international standard. And they are assured: an external provider tests the numbers, starting with a limited-assurance review and moving to a full audit over time. For how the whole regime fits together, including the penalties, see Australia's sustainability reporting legislation.

Who has to comply: the three groups

You're caught if you already lodge financial reports under Chapter 2M of the Corporations Act and you meet the thresholds for one of three groups. Test all three criteria at the consolidated group level, not the parent entity alone. You fall into a group if you meet at least two of its three size tests:

The size tests aren't the only way in. If your corporate group is a registered NGER reporter, you're caught regardless of size. This pulls in energy-intensive businesses with modest revenue and headcount. Large asset owners (a registered scheme, superannuation fund or retail CCIV with $5bn+ in assets) are drawn in as Group 2 regardless of the size tests. If you're not sure which group you're in, find your group with the size tests side by side, or see how ASIC's Regulatory Guide 280 determines your obligation. Once you know your cohort, we've written a preparation guide for Group 2 and Group 3.

What you have to disclose: the four pillars

The single most common misconception is that AASB S2 is only an emissions number. Your report has to address four pillars.

Governance: documented board oversight of climate risk, not a single mention in the November minutes.

Strategy: the climate risks and opportunities you face over short, medium and long horizons, scenario analysis against at least two scenarios (one aligned to 1.5°C, one well exceeding 2°C), and your transition plan if you have one.

Risk management: how you identify, assess, prioritise and integrate climate risk into the business.

Metrics and targets: your Scope 1 and 2 emissions from day one, Scope 3 from year two, plus any targets you've set. A calculator that only produces the emissions number leaves three of the four pillars unanswered.

The scopes, and the Scope 3 relief

Every group discloses Scope 1 (direct emissions) and Scope 2 (purchased electricity) from its first reporting year. Scope 3 (the value chain, usually the biggest part of a footprint, often 70–90% or more) is deferred for your first year and becomes mandatory in year two. Scope 1 and 2 carry no transitional liability protection, so that's where first-year effort should concentrate. Scope 2 must be reported location-based as a minimum; a market-based figure (GreenPower, PPAs) is a supplementary disclosure, and you'll need the contractual evidence if you claim it.

Assurance: limited now, reasonable later

From your first year you need limited assurance (a review) over governance, your strategy risks and opportunities, and Scope 1 and 2 emissions, broadening over time. For financial years commencing on or after 1 July 2030, this steps up to reasonable assurance (a full audit) over all disclosures. Don't let the word "limited" relax you: even in a review, the assurer picks a number and works backwards: "show me the electricity bill behind this Scope 2 figure, and walk me through how it became the number in the report." If you can't trace it, you can't assure it.

Where first-time reporters get the numbers wrong

Three mistakes surface again and again in early engagements:

The wrong state factor. Scope 2 emission factors differ sharply by grid. A coal-heavy state's factor is several times a hydro-heavy state's. A single national factor, or the wrong state's, makes your numbers materially wrong before the assurer opens the workbook. Use the current-year NGA Factors, matched to each site's state.

Unit mismatches. Gas billed in megajoules on one invoice and gigajoules on another is a factor-of-1,000 error waiting to sit quietly in a cell. A source-linked trail catches it; an eyeballed reference doesn't.

No trail back to source. If a number can't be traced to the bill, the activity data and the factor behind it, it won't survive assurance, however right it looks.