Accounting & Regulatory Update, March 2026 - ONLINE ONLY
Australia's largest companies are now lodging their first mandatory climate-related sustainability reports with ASIC in early 2026, exposing them to fresh scrutiny, assurance requirements, and potential market penalties for inadequate disclosures.
Key takeaways
- •Mandatory climate disclosures under AASB S2 began for Group 1 entities (largest listed and unlisted companies) for periods starting on or after 1 January 2025, with first reports due in early 2026, compelling detailed reporting on climate risks, opportunities, and emissions.
- •Non-compliance risks regulatory enforcement from ASIC, reputational damage, higher capital costs from investor demands, and operational disruptions as companies implement new data collection and assurance processes.
- •While aligned with global ISSB standards, Australian modifications and phased rollouts create tensions between international comparability and local reliefs, particularly around Scope 3 emissions and scenario analysis, amid ongoing global clarifications to ease burdens.
Mandatory Climate Disclosures Take Effect
Australia implemented mandatory climate-related financial disclosures through the Australian Sustainability Reporting Standards (ASRS), specifically AASB S2 Climate-related Disclosures, following legislation in 2024. These standards mirror the International Sustainability Standards Board's IFRS S2 but include targeted Australian modifications, such as reliefs for certain financed emissions calculations and industry classifications.
The requirements apply in phases: Group 1 entities—generally those with over A$1 billion in assets, A$500 million revenue, or 500+ employees and meeting specific thresholds—began reporting for financial years starting on or after 1 January 2025. Their first sustainability reports, integrated into annual financial filings, are lodged with ASIC from March 2026 onwards. Smaller groups follow in 2026-27 and 2027-28.
The stakes are high for affected entities. Companies must disclose material climate risks and opportunities, governance, strategy (including scenario analysis), and metrics like Scope 1, 2, and often Scope 3 greenhouse gas emissions. Assurance requirements apply, starting limited then moving to reasonable assurance, adding costs and complexity. Poor disclosures could trigger ASIC interventions, greenwashing penalties, or investor backlash in a market increasingly pricing climate resilience.
A key tension lies in balancing robust disclosure against implementation burdens. ASIC's reviews of voluntary reports highlighted issues like vague scenario analysis and obscured risk information, suggesting mandatory reports will face sharper scrutiny. Recent AASB amendments in late 2025 clarified GHG emissions rules, offering some relief, but companies still grapple with data gaps, especially Scope 3, and integrating disclosures into existing reporting cycles. This shift also pressures smaller suppliers and partners in value chains to provide consistent data, amplifying ripple effects beyond direct reporters.
Sources
- https://fsaa.com.au/event/65180/accounting-regulatory-update-march-2026-online-only
- https://aasb.gov.au/news
- https://aasb.gov.au/media/xpilzp2e/overviewofasrs_04-25.pdf
- https://asic.gov.au/about-asic/news-centre/news-items/reporting-and-audit-update-issue-1
- https://www.persefoni.com/blog/asrs-australia-issb
- https://kpmg.com/au/en/insights/financial-reporting/sustainability-climate-change/issb-sustainability-reporting-disclosures-guide.html
- https://www.pwc.com.au/assurance/sustainability-reporting-and-assurance/australian-sustainability-reporting-standards.html
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