ASRS Group 1: what you must disclose in your first sustainability report
If you're Group 1 (FY commencing on/after 1 Jan 2025), your first AASB S2-aligned climate disclosures are due. Here's exactly what goes in.
Who is Group 1
You're Group 1 if any of: revenue ≥$500M, assets ≥$1B, ≥500 employees, NGER high emitter (≥50K tCO2-e), or asset owner with ≥$5B AUM. FY commencing on/after 1 January 2025.
The four AASB S2 pillars
- Governance — body / individual(s) overseeing climate; monitoring; management role + reporting cadence.
- Strategy — short/medium/long-term risks + opportunities; strategy impact; scenario analysis; resilience.
- Risk management — identification + assessment + prioritisation processes; integration with overall risk management; transition plan (if any).
- Metrics + targets — Scope 1 + 2 (year 1), Scope 3 (year 2+), other metrics, targets with base years.
Scope 1 and Scope 2 in year 1
Scope 1: direct emissions (combustion, fugitive, process). Scope 2: indirect from purchased energy (location + market based). Calculate per GHG Protocol; use NGER methods where applicable.
Scope 3 — relief in year 1, mandatory year 2
Group 1 has Scope 3 reporting relief in year 1; mandatory from year 2. Start data collection NOW. Categories: purchased goods + services, capital goods, fuel + energy related, upstream + downstream transport, waste, business travel + commuting, use of sold products, investments (financial services).
Scenario analysis
At least one well-below-2°C scenario (IEA NZE or equivalent) + one higher-emissions scenario. Year 1 can be qualitative; year 2+ quantitative.
Assurance pathway
Year 1 — limited assurance on Scope 1+2 + governance + risk management. Year 3 — reasonable assurance on all in-scope. Year 5 — reasonable assurance on Scope 3 + scenario analysis + financial impact. Engage your financial auditor early.
Frequently asked
What if I don't meet any single threshold but cross 2 of 3?
Group 1 applies if you meet ANY of: revenue/assets/employees/NGER/asset owner. The Ch 2M financial-reporting 'any 2 of 3' analog does NOT apply here.
Is the sustainability report public?
Yes — published alongside the annual financial report. Lodged with ASIC; auditor's assurance report attached.
What if I'm in scope but don't have Scope 3 data?
Year-1 relief; develop Scope 3 mapping during FY25 for year-2 reporting.
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Obligations covered
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