The introduction of the Australian Sustainability Reporting Standards (ASRS) represents one of the most significant changes to corporate and financial reporting in Australia in recent years.

While many businesses believe they are “not required to report yet,” ASRS expectations are already influencing your stakeholders including how banks, insurers, investors, customers and boards assess risk, resilience and long‑term value.

ASRS is not simply a compliance exercise only. It is about demonstrating that your business:

• Understands its risks
• Has appropriate governance in place
• Can explain how decisions are made
• Is prepared for foreseeable change

If you have all of this you may be surprised by how differently you are looked at by the banks, insurers, customers and other stakeholders.

Who Needs to Report and When

ASRS reporting is being phased in over three groups based on size and reporting obligations.

Group 1 – Reporting periods starting on or after 1 January 2025

Entities that meet two of the following:

• Revenue ≥ $500m
• Assets ≥ $1bn
• More than 500 employees

Or entities required to report under the National Greenhouse and Energy Reporting (NGER) scheme.

For a 30 June year‑end, the first sustainability report will typically be required for financial year ending 30 June 2026.

Group 2 – Reporting periods starting on or after 1 July 2026

Entities that meet two of the following:

• Revenue ≥ $200m
• Assets ≥ $500m
• More than 250 employees

Group 3 – Reporting periods starting on or after 1 July 2027

Entities that meet two of the following:

• Revenue ≥ $50m
• Assets ≥ $25m
• More than 100 employees

Due Dates and Lodgement

Sustainability disclosures are prepared for the same period as the financial report and form part of the annual report.

ASIC lodgement timeframes generally apply:

• Within 3 months after year‑end for disclosing entities
• Within 4 months after year‑end for other entities

Assurance requirements are being phased in over time, with transitional relief in the early years.

A Key Message for Group 2 and Group 3 Clients

Even if you do not believe your business has any material climate‑related risk, ASRS still requires you to demonstrate that:

• Climate‑related risks and opportunities were considered
• Materiality was assessed using appropriate judgement
• Governance and oversight are in place
• Conclusions are documented and defensible

“No material climate risk” is still a conclusion and the process used to reach that conclusion matters.

What Group 2 and Group 3 Businesses Need to Do — Even If Climate Risk Is Low

1. Establish Governance

Businesses must clearly document:

• Who is responsible for sustainability and climate oversight
• How these matters fit within existing risk management frameworks
• How often risks are reviewed and reported

This does not require new committees or complex structures but it does require clarity and evidence.

2. Perform a Proportionate Climate Risk Consideration or one of our materiality workshops.

This can be qualitative and high‑level initially:

• Consider physical and transition risks
• Assess short, medium and long‑term horizons
• Identify any potential impacts on operations, customers, supply chains, financing or insurance
• Document assumptions and judgement applied

If risks are assessed as immaterial, that conclusion should be clearly recorded.

3. Integrate With Existing Business Planning

ASRS should not sit in isolation:

• Link climate considerations to strategic planning
• Align with budgeting, capital expenditure and insurance reviews
• Embed within existing enterprise risk management processes

4. Prepare for Stakeholder Questions

Even before mandatory reporting:

• Banks increasingly ask how climate risk is considered
• Insurers assess exposure and resilience
• Customers may push ASRS expectations down the supply chain

Being able to explain your approach, even where risk is low, builds confidence and credibility.

Practical Timing Guidance

Group 2:

• First reporting periods commence from 1 July 2026
• First ASRS‑aligned disclosures expected for FY ending 2027
• Preparation should begin at least 12–24 months prior

Group 3:

• First reporting periods commence from 1 July 2027
• First ASRS‑aligned disclosures expected for FY ending 2028
• Early groundwork significantly reduces cost, disruption and advisory spend

How We Help Our Clients

As your accountants and advisors, our role is to provide proportionate, practical support, not unnecessary complexity.

We can assist with:

• ASRS readiness and gap assessments
• Climate risk materiality analysis (including where risk is low)
• Governance and oversight documentation
• Emissions baselining where required
• Scenario thinking and transition considerations
• Board‑ready narratives and disclosures
• Roadmaps aligned to your reporting group and financial reporting cycle
• Assurance readiness planning

The Bottom Line

ASRS is not about forcing every business to become a climate expert.

For most Group 2 and Group 3 clients, it is about being able to demonstrate:

• Good governance
• Informed judgement
• Preparedness

Starting early ensures ASRS becomes an extension of sound business management and not a last‑minute compliance exercise. We have workshops to fit all types of businesses so please reach out to have a discussion with us about your next steps.

Download: Introduction to Sustainable Business Strategy & Reporting Flyer here