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Climate related disclosures in effect

21 April 2026
by Jon Houghton
5-minute read

AASB S2 Climate Related Disclosures is now in effect, and requires large Australian companies to report on climate related disclosures alongside their financial performance.

Designed to bring greater transparency to stakeholders and encourage stronger sustainability strategies, the framework covers four key areas, covering everything from governance and risk management through to measurable emissions data across your supply chain. Here’s what the framework requires and what it means in practice – and for many businesses, the compliance timeline is closer than expected.

If your business hasn’t yet considered its obligations under Australia’s new climate disclosure framework, now is the time.

Effective dates

The effective date for various sizes of company is below:

	2 out of 3 of:	Effective date
Group 1	Consolidated revenue ≥ $500m Consolidated gross assets ≥ $1b Employees ≥ 500	From 1 Jan 2025
Group 2	Consolidated revenue ≥ $200m Consolidated gross assets ≥ $500m Employees ≥ 250	From 1 Jul 2026
Group 3	Consolidated revenue ≥ $50m Consolidated gross assets ≥ $25m Employees ≥ 100	From 1 Jul 2027

Most BG clients don’t need to take action right now, but even if you are below the threshold, some of your suppliers or customers may start asking you for information to assist with their own downstream reporting.

Overview of the disclosures

When you fall into a reporting group, you will need to prepare a sustainability report each year which includes the following disclosures:

Governance – Board approach to implementing processes to monitor climate risks and opportunities
Strategy – How climate risks and opportunities impact the company’s decision-making processes
Risk management – Company’s process for identifying and managing climate risks
Climate resilience analysis – Analysis of consequences under potential increases in average global temperatures
Climate-related metrics – C02 equivalent emissions for the financial year from each of:
- Scope 1 (Direct Emissions) – Emissions from owned sources, such as vehicles and generators
- Scope 2 (Indirect – Energy) – Emissions from purchased electricity and gas
- Scope 3 (Upstream) – Emissions from upstream supply chain, including transportation, suppliers and employees
- Scope 3 (Downstream) – Emissions from downstream supply chain, including customers and product disposal

Certain Scope 3 disclosures are not mandatory during the first year of reporting.

These disclosures are subject to external assurance. Given climate disclosure is a new and evolving space, getting it right matters. Understanding what’s required across each of the four reporting pillars is an important first step – and the earlier you act, the better positioned your business will be.

Like to know more?

If you’re unsure where your obligations sit or how to approach your first disclosure, BG Private can help you navigate the framework with clarity and confidence. Contact our team today to find out what AASB S2 means for your business specifically, and together we can build an approach that works for you.

About the authors

Andrew Fisher

Partner | Audit & Assurance

Andrew Fisher has led BG Private's Audit & Assurance division since establishing it in 2002, growing it into a team of over 20 highly specialised practitioners. Known equally for his technical rigour and his belief that audit should be collaborative and approachable, Andrew brings analytical thinking and deep expertise across corporate audit, not-for-profit and other engagements, remaining directly accessible to clients at every stage.

Jon Houghton

Manager | Audit & Assurance

Jon Houghton is a Manager in BG Private's Audit & Assurance division, bringing a rare combination of technical accounting expertise and real-world commercial insight. Highly regarded for his ability to communicate complex standards in plain English, Jon brings a practical, commercial mindset to every engagement and specialises in audits for entities including not-for-profits, insurance brokers, importers, trusts and others.