Climate-related disclosures

Climate reporting, explained.

Is climate reporting mandatory in Australia?

In September 2024, mandatory climate reporting was introduced in Australia. This requires companies to publish and lodge a sustainability report as part of their annual report.

The sustainability report shall include a climate statement prepared in accordance with AASB S2 Climate-related disclosures and audited annually. The Auditing and Assurance Standards Board (AUASB) is in charge of specifying the phasing of assurance requirements for all parts of the climate statement.

Mandatory climate reporting applies to companies meeting the criteria set in the below table. If not falling under these criteria, the business is exempt from mandatory reporting.

Figure 1

Climate reporting table Australia

What are the Australian Sustainability Reporting Standards (ASRS)?

In October 2023, the Australian Accounting Standards Board (AASB) issued the draft ASRS on disclosures of climate-related financial information. This draft builds upon the IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB). It adopts the four-pillar structure (Governance, Strategy, Risk Management, Metrics and Targets) from the Task Force on Climate-related Financial Disclosures.

The ASRS include two standards:

  • AASB S1 General Requirements for Disclosure of Sustainability-related Financial Information builds upon IFRS S1 and is a voluntary standard in Australia.
  • AASB S2 Climate-related Disclosures builds upon IFRS S2 with a few adaptations for Australia and is mandatory for companies meeting the criteria. Our Climate reporting readiness tool and our ad hoc research report provide further information on the AASB S2 requirements. Figure 2 highlights a few requirements of IFRS S2 / AASB S2.

Figure 2

Climate-related disclosure requirements - table

What is the TCFD Framework?

The Task Force on Climate-related Financial Disclosures was initiated by the Financial Stability Board in 2015 to help companies provide climate related risks information that meet the needs of investors.

The Task Force published in 2017 a set of 11 recommendations categorized along 4 main pillars: Governance, Strategy, Risk Management and Metrics and Targets.

Many companies around the world have voluntarily reported their climate-related risks in accordance with the TCFD recommendations. In Australia, the recommendation 7.4 of the ASX. Principles and Recommendations issued in 2019 encourages companies to consider disclosing their climate-related risks according to the TCFD recommendations.

Figure 3

TCFD recommendations table

FAQs:

1. Which companies must prepare mandatory climate reporting?

Australian companies meeting two of these criteria will have to prepare climate-related disclosures:

- A$ 50+ million consolidated turnovers

- A$25+ million consolidated gross assets

- 100+ employees

Further details on the criteria and timeline are provided in Figure 1.

2. If the parent company overseas has prepared a climate report, does the Australian subsidiary need to prepare a climate-reporting?

Australian subsidiaries won’t be allowed to lodge the consolidated group sustainability report. They will have to prepare and lodge their own sustainability report and climate statement in accordance with AASB S2 if they meet the thresholds detailed in Figure 1.

3. What is AASB S2?

AASB S2 Climate-related Disclosures builds upon IFRS S2 with a few adaptations for Australia.

- As per the Bill introducing mandatory climate reporting, two climate scenarios shall be considered, including a high global warming scenario (2.5°C or higher) and a low global warming scenario (1.5°C above pre-industrial levels).

- Incorporates parts of AASB S1 in Appendix D to make AASB S2 a standalone mandatory standard.

4. What are IFRS SDS?

Building upon the TCFD framework, the ISSB issued the IFRS Sustainability Disclosure Standards (SDS).

- IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. It requires a company to disclose information about its governance, strategy and risk management, as well as metrics and targets, in relation to its sustainability‑related risks and opportunities.

- IFRS S2 Climate-related Disclosures. It extends the TFCD recommendations and requires companies to provide more granular information on their climate-related risks and opportunities.

5. What are the differences between TCFD to IFRS S2 (TCFD Vs IFRS S2)?

For companies already disclosing in accordance with the TFCD recommendations, complying with AASB S2 requirements will require to provide more granular information. The IFRS website outlines that “the requirements in IFRS S2 integrate, and are consistent with, the TCFD’s four core recommendations and 11 recommended disclosures, with minor differences.”

The ISSB has prepared a detailed comparison table that highlights the differences.

6.  What are the differences between TCFD to AASB S2 (TCFD vs AASB S2)

Given the strong alignment between IFRS S2 and AASB S2, most of the differences highlighted by the ISSB apply (see detailed comparison table) and most relate to the need to provide more granular and detailed information. Then, there are also area of differences between IFRS S2 and AASB S2 that would need to be considered to transition from TCFD to AASB S2. For instance, AASB S2, in line with the Australian climate regulation, requires using two climate scenarios, including a high global warming scenario (2.5°C or higher) and a low global warming scenario (1.5°C above pre-industrial levels).

7. What are the benefits of climate reporting?

Beyond meeting compliance requirements, preparing a climate-related reporting may help:

- Directors ensure that they fulfill their fiduciary obligations regarding climate-related risks

- Seize business opportunities offered by the Green transition

- Enhance the climate resilience of the operations and supply chain

- Develop credible decarbonisation pathway

- Enhance brand reputation

8. Do I have to climate report if my company isn’t meeting the criteria?

No, legally you do not have to. However, your shareholders, customers and other stakeholders may expect your company to report (some) climate related disclosures. It is possible to prepare a voluntary climate report.

9. What is SASB?

The Sustainability Accounting Standards Board (SASB) has developed 77 sector specific standards. These standards help companies identify sustainability-related risks and opportunities that are likely to be financially material for them and their peers working in the same industry. Following the merger between SASB and the IFRS Foundation, these standards are currently being revised.

How can Forvis Mazars help:

  • AASB S2 gap analysis and detailed implementation action plan / roadmap
  • Carbon footprint calculations and analysis
  • Decarbonisation pathways and target setting
  • Review of governance arrangements around climate risks and opportunities
  • Physical and transition risks and opportunities analysis
  • Climate scenario analysis
  • Risk management and internal control development and implementation
  • Reporting assistance

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