AASB S2 climate reporting in Australia
AASB S2 sets out what goes into Australia's mandatory climate reporting. Here is who reports when, what it asks of your emissions data, and the part Emitt prepares.
What is AASB S2?
AASB S2 Climate-related Disclosures is the Australian standard for the climate statements in an annual sustainability report, which the Corporations Act 2001 requires from entities that meet a threshold in section 292A. The Australian Accounting Standards Board issued it in September 2024, based on the ISSB's IFRS S2, for annual reporting periods beginning on or after 1 January 2025.
Its companion, AASB S1, is voluntary, and for now climate is the only part of the sustainability report. It covers governance, strategy, risk management, and metrics and targets, where your emissions sit. It is lodged with ASIC within three months of year end for disclosing entities, registered schemes and super funds, and four months for everyone else.
Who has to report under AASB S2, and when?
You report if you prepare an annual financial report under Chapter 2M of the Corporations Act and meet one of three tests: a size test, registration under the NGER Act, or a $5 billion asset test for super funds and managed investment schemes. Reporting phases in by the date your financial year starts.
| Group | Financial years starting | Size test: at least two of | Or |
|---|---|---|---|
| Group 1 | 1 Jan 2025 to 30 Jun 2026 | $500m revenue, $1b gross assets, 500 employees | NGER registered (or required to apply), in a group that meets the NGER corporate emissions threshold of 50,000 t CO₂e |
| Group 2 | 1 Jul 2026 to 30 Jun 2027 | $200m revenue, $500m gross assets, 250 employees | Any other NGER registered corporation. Super funds, registered schemes and retail CCIVs with $5b or more in assets. |
| Group 3 | On or after 1 Jul 2027 | $50m revenue, $25m gross assets, 100 employees | No other test |
Each size figure means that amount or more, counts the entities you control, and takes assets and employees at year end. The obligation crystallises at year end, so an acquisition during the year can bring you in.
Group 3 has one extra option: an entity with no material climate-related financial risks or opportunities lodges a statement saying so, and how it decided, as its climate statements (section 296B).
The first Group 1 reports, for 31 December 2025 year ends, are in: ASIC counted 312 and reviewed a sample of 40 in REP 839 in September 2026. Group 2 began with financial years starting on 1 July 2026.
What does AASB S2 ask for on emissions?
AASB S2 asks for your absolute gross Scope 1, Scope 2 and Scope 3 emissions in tonnes of CO₂e, measured with the GHG Protocol Corporate Standard unless a jurisdictional authority or your exchange requires another method (paragraph 29(a)).
- Scope 2, location-based, plus information on any contractual instruments for the energy you bought, where it helps readers.
- Your method: approach, inputs and assumptions, and any changes, with reasons. Scope 1 and 2 are also split between your consolidated group and other investees.
- Scope 3 by category: which of the GHG Protocol's 15 categories you include. Estimates are allowed, and data from suppliers counts as primary data.
- First-year relief: no Scope 3 (paragraph C4(b)), no comparatives (C3), and you may keep last year's measurement method (C4(a)).
Where NGER methods fit
The AASB made the GHG Protocol the default, not NGER, but an entity required by Australian law to use NGER methods may use them. AASB S2025-1 (December 2025, for periods from 1 January 2027) clarifies that this applies only to the part of the entity the requirement covers, and lets NGER's IPCC AR5 global warming potentials stand without recalculating to AR6.
How does assurance phase in?
Under the AUASB's ASSA 5010 (amended December 2025), year one brings a review, or limited assurance, of Scope 1 and 2 emissions, governance, and climate risks and opportunities. Years two and three bring a review of everything, and year four an audit, or reasonable assurance, of everything. For financial years starting on or after 1 July 2030 the Corporations Act requires an audit.
Year one is your group's first reporting year, as in the table above.
| What is assured | Year 1 | Years 2 and 3 | Year 4 on |
|---|---|---|---|
| Governance, and climate risks and opportunities | Limited | Limited | Reasonable |
| Scope 1 and Scope 2 emissions | Limited | Limited | Reasonable |
| Scope 3 emissions | Not applicable | Limited | Reasonable |
| Rest of strategy (including scenario analysis and transition plans), risk management, other metrics and targets | None | Limited | Reasonable |
Is there a safe harbour for Scope 3?
Yes, for financial years starting between 1 January 2025 and 31 December 2027. In those reports, statements about Scope 3, scenario analysis and transition plans can only be acted on by ASIC or in a criminal prosecution, not by private litigants. Other forward-looking climate statements had that protection for years starting in 2025 only.
It covers statements made to comply with a sustainability standard, not voluntary extras, or the same words repeated voluntarily in, say, an investor presentation. For the same years, directors declare that the entity took reasonable steps to comply, rather than that it complies.
What Emitt prepares for AASB S2
Emitt prepares the Scope 1 and 2 figures behind your AASB S2 metrics, with the evidence for each, and shows how ready you are.
- Year 1 readiness checklist. Each AASB S2 requirement as a plain question, answered Met, Partial, Missing or Not applicable. Scope 1, Scope 2 and the factors used are answered from your data.
- AASB S2 metrics extract. Scope 1 and location-based Scope 2, each figure with its quantity, factor, NGA edition and source document. Its label: "Metrics and evidence lineage only. No governance, strategy or risk narrative, and no statement about your disclosure. The narrative stays yours."
- Audit readiness. Month by month, whether every stream is complete, nothing is excluded, every record has its source file and the period is locked. It prints as a report, and shows readiness, not assurance.
- Completeness and an audit log. Every total says how many records it includes and leaves out, and every correction is logged with who, when, before and after.
- Scope 3 when it's due, from supplier links and waste dockets, kept apart from your Scope 1 and 2 headline.
Electricity is priced location-based against its state grid, the basis AASB S2 asks for: 0.74 kg CO₂e per kWh in Victoria in the NGA Factors 2026.
What Emitt doesn't do
These stay with you, your advisers and your auditor:
- Governance, strategy and risk management narrative.
- Scenario analysis. The Corporations Act requires at least two scenarios: a 1.5°C rise and one well above 2°C.
- Transition plans and the financial effects of climate risks.
- The report itself, the directors' declaration and lodgement with ASIC.
- Assurance. Emitt is not an assurance provider.
- Deciding your group, or whether climate risks are material to you.
- Market-based Scope 2. Emitt reports location-based only.
AASB S2 questions
Does AASB S2 apply to my company?
It does if your company prepares an annual financial report under Chapter 2M of the Corporations Act and meets a section 292A threshold. The smallest, Group 3 from 1 July 2027, is two of $50 million revenue, $25 million gross assets and 100 employees.
When do we have to report Scope 3 emissions?
From your second reporting year. AASB S2 lets you leave Scope 3 out of your first annual reporting period, so a Group 2 company with a 30 June year end first reports Scope 3 for 2027–28.
Do we have to use NGER methods for AASB S2?
No. The GHG Protocol Corporate Standard is the default. If a jurisdictional authority requires a different method, as the NGER scheme does for NGER reporters, you can use it for the part of the entity the requirement covers.
Does Emitt write our AASB S2 report?
No. Emitt prepares the Scope 1 and 2 metrics with the evidence behind each figure, and tracks your readiness. The narrative, scenario analysis and the report itself stay with you and your advisers, and Emitt is not an assurance provider.
Last reviewed: 9 October 2026. General information, not legal or accounting advice. Sources: ASIC RG 280, AASB S2, AASB S2025-1, ASSA 5010, Treasury.
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