Final steps in the legislative and standard-setting process implements new mandatory sustainability reporting from 1 January 2025
Steps in implementing the new sustainability reporting framework
Legislative arrangements
After final Parliamentary considerations, the enabling legislation received Royal Assent on 17 September 2024, introducing mandatory sustainability reporting into the Corporations Act 2001 and permitting the AASB to make sustainability standards under the Australian Securities and Investments Commission Act 2001. The legislation also requires high (2.5° or higher) and low (1.5°) scenario analyses and implements a three year modified liability framework for directors and auditors.
Australian Sustainability Reporting Standards (ASRSs)
Finalising deliberations on 20 September 2024, the AASB voted to issue AASB S1 General Requirements for Disclosure of Sustainability-related Financial Information (voluntary) and AASB S2 Climate-related Disclosures (mandatory for sustainability reports under the Corporations Act 2001). These ASRSs are closely aligned with the equivalent IFRS® Sustainability Disclosure Standards issued by the International Sustainability Standards Board but importantly the mandatory AASB S2 does not include consideration or disclosure of industry-based metrics.
Regulatory response
Following the legislative changes becoming law, ASIC called on entities to implement appropriate governance arrangements and sustainability record keeping processes to prepare for sustainability reporting and published guidance on its website on the new requirements. ASIC is expected to issue formal regulatory guidance in due course, including updating existing guidance on when relief may be granted. In an earlier report on greenwashing, ASIC recommended that entities voluntarily disclosing climate-related metrics and targets before the new regime becomes mandatory should consider the relevant disclosure requirements in the ASRSs.
Assurance requirements
Under legislative powers granted to the AUASB, assurance over the mandatory sustainability report will be phased in progressively, ultimately requiring reasonable assurance for all reporting entities from 2030. The AUASB released an exposure draft on the timetable for assurance on 17 September 2024, proposing limited assurance over governance, strategy (risks and opportunities) and scope 1 and 2 emissions in an entity’s first reporting year, moving to reasonable assurance for all mandatory disclosures from the fourth year of compliance.
Reporting timeline
Sustainability reporting for entities reporting under Chapter 2M will be phased in using three groups, summarised broadly as: