Climate reporting for large business
Who must report, what has to be lodged, the key deadlines, and where the official guidance lives.
- Large companies now prepare an annual sustainability report using AASB S2, phased in through Groups 1–3 from 2025 to 2027.
- Separately, high emitters report under NGER, and the largest facilities must keep emissions under a Safeguard Mechanism baseline.
- Pollutant (NPI) and state licence reporting can apply on top.
Who is covered
A company that lodges financial reports under Chapter 2M of the Corporations Act enters a group if it meets at least two of three tests:
| Group | First financial year starting | Revenue | Gross assets | Employees |
|---|---|---|---|---|
| Group 1 | on or after 1 Jan 2025 | > $500m | > $1bn | > 500 |
| Group 2 | on or after 1 Jul 2026 | > $200m | > $500m | > 250 |
| Group 3 | on or after 1 Jul 2027 | > $50m | > $25m | > 100 |
NGER reporters and large asset owners can be brought into the earlier groups regardless of these tests. The exact criteria are in section 292A of the Corporations Act and ASIC's guidance.
What you must lodge
1. Sustainability report (AASB S2)
Lodged with ASIC alongside the annual financial report. Climate is currently the only required topic. It covers:
- Governance: who oversees climate risk
- Strategy: climate risks and opportunities, including scenario analysis
- Risk management: how risks are identified and managed
- Metrics and targets: Scope 1 and 2 emissions, Scope 3 from the second reporting year, and any targets
The report must be audited or reviewed, with assurance requirements phased in over several years. Scope 3, scenario analysis and transition plans have limited liability protection in the early years.
ASIC: Sustainability reporting · ASIC RG 280 · AASB S2 (compiled standard) · ASIC: audit and review FAQs
2. NGER report
Required if your facility or corporate group crosses an NGER threshold:
| Emissions (Scope 1 + 2) | Energy produced or consumed | |
|---|---|---|
| Facility | 25 kt CO₂-e | 100 TJ |
| Corporate group | 50 kt CO₂-e | 200 TJ |
Reports cover the financial year and are submitted through the Clean Energy Regulator's EERS system by 31 October. New reporters must register first.
3. Safeguard Mechanism
Applies to facilities with more than 100,000 t CO₂-e of covered (Scope 1) emissions a year, mainly in mining, oil and gas, manufacturing, transport and waste. Net emissions must stay below a declining baseline; any excess is covered by surrendering ACCUs or Safeguard Mechanism Credits (SMCs). Compliance deadline: 1 April.
CER: Safeguard Mechanism · Ecopedia: carbon markets explained
4. Pollutants and licences
Facilities above NPI substance thresholds report by 30 September. Holders of state environmental licences may have annual returns; in Queensland they are due 1 April when a notice is issued.
Business Queensland: NPI · Business Queensland: EA annual returns
Key dates
| Date | What |
|---|---|
| 1 April | Safeguard Mechanism compliance deadline · QLD environmental authority annual returns |
| 30 June | End of the NGER reporting year (and of the financial year for most companies) |
| 31 August | NGER registration deadline for new reporters |
| 30 September | NPI reports due |
| 31 October | NGER reports due |
| With the annual report | Sustainability report (AASB S2) lodged with ASIC |
Calculating emissions
NGER reporting follows the methods in the NGER (Measurement) Determination. For voluntary and Scope 3 estimates, most organisations use the National Greenhouse Accounts Factors and the GHG Protocol.
DCCEEW: NGA Factors · GHG Protocol: Corporate Standard · ASIC: educational modules
Sources
- ASIC, Sustainability reporting
- ASIC, Regulatory Guide 280: Sustainability reporting
- Clean Energy Regulator, NGER Scheme
- Clean Energy Regulator, Safeguard Mechanism
- Business Queensland, National Pollutant Inventory
- Accounting Times, Proposed 2026 budget reforms and climate disclosure thresholds
This article is general information, not legal or financial advice.