05 November 2026
ASIC’s recent verdict on the first sustainability reports lodged under Australia’s mandatory climate-related financial disclosures regime (CRFD) sets the standard for entities’ reporting going forward.
Australia’s Group 1 reporting entities are among the first in the world to prepare mandatory climate-related financial disclosures under AASB S2 Climate-related Disclosures (S2), which is closely aligned with the International Sustainability Standards Board’s IFRS S2. ASIC, Australia’s corporate, markets and financial services regulator, has now released a report on these first sustainability reports for the financial year ending 31 December 2025, giving guidance across each of the core reporting pillars and specific observations for wholly owned subsidiaries of multinational groups. The findings offer an early benchmark for entities in Australia and in other jurisdictions that will soon follow.
For now, ASIC is taking a facilitative approach, but its expectations are clear. As ASIC now plans to review a sample of the reports of Group 1 entities with a financial year ending 30 June 2026, entities should expect closer scrutiny, including of the records that support their sustainability judgements. Nor should entities expect significant relief: although Treasury has consulted on making the regime more efficient, and ASIC supports reducing regulatory burden, ASIC has signalled that the core reporting requirements should remain.
The message for reporting entities, including Australian subsidiaries of multinational groups, is to use ASIC’s feedback now to strengthen governance, data and processes ahead of the next reporting cycle.
This Insight outlines ASIC’s approach, its eight key action items, its guidance on each core disclosure area and additional considerations for subsidiaries of multinational groups.
ASIC’s methodology gives context to its findings and signals how it may approach future compliance reviews as it moves from market-wide reviews towards closer supervision and ultimately, enforcement.
ASIC reviewed the sustainability reports of 20 listed and 20 unlisted entities, prioritising sectors with higher greenhouse gas emissions or greater exposure to climate-related risks and opportunities (CRROs), such as mining, utilities, manufacturing, banking and insurance. Its desktop review involved:
ASIC did not review the sustainability records held by reporting entities or their auditors, or otherwise seek evidence to substantiate disclosures. Entities should not assume this will continue. Future reviews are likely to test the records and judgements behind disclosures, so entities should maintain those records now on the basis that ASIC may ask to see them.
ASIC’s eight ‘key action items’ for reporting entities to consider are summarised below:
In practice, sustainability and financial reporting teams must work together to ensure consistent data and assumptions across both reports, and clearly explain any significant differences.
A significant portion of entities described, but did not quantify, the current and anticipated financial effects of CRROs. S2’s proportionality mechanisms permit this where the effects are not separately identifiable or where measurement uncertainty is so high that quantitative information would not be useful, and, for anticipated effects, where the entity lacks the skills, capabilities or resources. However, the relief is not a complete exemption. An entity relying on it must still:
ASIC expects quantitative disclosures to increase as methodologies and processes mature, and Group 1 entities should expect the relief to become harder to rely on. Entities should plan now for how they will produce reliable quantitative information, whether as a single amount or a range. ASIC suggests a starting point: the anticipated financial effects of board-approved mitigation or adaptation plans may be measurable with more certainty in the early years.
When identifying CRROs, entities should consider past events, current conditions and forecast future conditions, and how they may be affected, directly or indirectly, across their value chain – for example, risks to international suppliers or to roads, railways and other infrastructure on which the business relies.
ASIC compared climate disclosures with entities’ earlier financial reports, ASX announcements and voluntary disclosures, and found extreme weather events that had previously affected and been disclosed by an entity but were not reflected in its sustainability report. Entities should expect ASIC to keep testing disclosures against other public materials, and should identify and remedy or explain any inconsistencies before lodging.
Judgements, assumptions and sources of measurement uncertainty should be disclosed clearly and close to the information they relate to. A bare statement that information is ‘not material’ or of ‘low financial materiality’ is not sufficient. Entities should already have this reasoning in their sustainability records, so the task is largely to bring it into the report.
To avoid obscuring material information and meet paragraph 22(b)(ii) of S2, ASIC highlighted as better practice an appendix setting out the key scenario analysis assumptions, such as carbon prices, emissions targets, Safeguard Mechanism assumptions and expected physical impacts like heat and flooding.
Cross-industry metrics, including greenhouse gas emissions: ASIC regards cross-industry metrics as central to one of the regime’s core policy objectives - making disclosures comparable across entities.
Disclosures were generally consistent where S2 prescribes a measurement methodology (such as for scope 1 and 2 emissions, which were also more reliable because they were subject to limited assurance) or a specific variable (such as an internal carbon price). Elsewhere, comparability was limited, with inconsistent approaches to, and in some cases no disclosure of, the other required cross-industry metrics, including:
S2 gives entities flexibility in how they approach these metrics, so some variation is inevitable. To make their figures useful, entities should explain the methodologies and judgements behind any disclosed cross-industry metrics, and be able to support those judgements with their records.
More than 80% of entities in ASIC’s sample relied on the first-year transitional relief for scope 3 emissions. Entities using this relief should clearly say so and should prepare now to report scope 3 emissions from year 2.
Information about CRROs is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of primary users of general purpose financial reports. ASIC observed that information may be material even if it does not meet a specific financial materiality threshold, and that some entities excluded information as immaterial without explaining the judgements behind that view. It highlighted as better practice an entity that disclosed qualitative information about CRROs that fell below its financial materiality threshold. Entities should clearly disclose, close to the relevant information, the judgements made in identifying material information.
S2’s one-size-fits-all approach creates challenges for Australian subsidiaries of multinational groups, whose climate strategy, governance, risk management and data are typically considered and managed at the group level.
Continuing uncertainty for multinationals – primary users: S2 disclosures must be useful to primary users – an entity’s existing and potential investors, lenders and other creditors. Information is material if it could reasonably be expected to influence their decisions about providing resources to the entity. ASIC’s report does not resolve how an Australian subsidiary whose sole shareholder is its foreign parent, and which has no reasonably foreseeable need for external capital, should identify its primary users. Too broad a view risks disclosures detached from the entity’s actual circumstances; too narrow a view risks omitting information material to the investors, lenders and creditors who do rely on its reports.
In the meantime, entities should ensure they maintain appropriate records to substantiate their approach to identifying their primary users.
Governance and risk management: explain whether and how the parent’s strategy, targets, risk assessments and governance processes apply to the local reporting entity.
Group climate targets: clearly explain how group and entity-level climate targets apply to the reporting entity and how they are being implemented.
Reporting entities should keep this feedback from ASIC in mind as they prepare their sustainability reports.
Authors
Partner
Partner
Senior Associate
Law Graduate
Tags