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When do AASB S2 reporting start dates apply for Group 1, Group 2 and Group 3?

AASB S2 reporting start dates are phased by group under the Corporations Act 2001. An entity’s first sustainability report covers the first financial year that begins on or after the start date for its group.

Key points

  1. Group 1: financial years beginning on or after 1 January 2025
  2. Group 2: financial years beginning on or after 1 July 2026
  3. Group 3: financial years beginning on or after 1 July 2027
  4. First-year relief from comparatives and Scope 3 (paragraphs C3 and C4)
  5. Assurance, modified liability and the directors' declaration are phased from the same dates

Start dates by group

Group First financial year beginning on or after First report for a 30 June year end First report for a 31 December year end
Group 1 1 January 2025 Year ending 30 June 2026 Year ending 31 December 2025
Group 2 1 July 2026 Year ending 30 June 2027 Year ending 31 December 2027
Group 3 1 July 2027 Year ending 30 June 2028 Year ending 31 December 2028

How the group is decided

The group depends on the size thresholds, registration under the NGER Act and, for asset owners, the value of assets, all set out in section 292A of the Corporations Act. An entity that does not meet the Group 1 criteria enters reporting later if it meets the Group 2 or Group 3 criteria.

What the first report can leave out

AASB S2 gives relief in the first annual reporting period in which an entity applies it. The entity need not disclose comparative information (paragraph C3). It may keep using a measurement method other than the GHG Protocol that it used in the year before, and need not disclose Scope 3 greenhouse gas emissions (paragraph C4). Either relief can continue to be used for the comparative figures in later reports (paragraph C5).

What is phased from the same dates

Several Corporations Act settings follow the same timetable:

  • Assurance: in the first year the auditor reviews only governance, climate-related risks and opportunities, and Scope 1 and Scope 2 emissions, with wider review and then audit in later years.
  • Modified liability: statements about Scope 3 emissions, scenario analysis and transition plans are protected for financial years beginning between 1 January 2025 and 31 December 2027.
  • Directors’ declaration: for financial years beginning in the same window, directors declare that the entity has taken reasonable steps to comply, rather than that the report complies.

Lodgement

The sustainability report is lodged with ASIC with the annual report, within three months of year end for disclosing entities, registered schemes and registrable superannuation entities, and within four months for other entities.

References & sources

Primary regulatory documents and authoritative references underpinning this answer.

  1. ASIC: Who must prepare a sustainability report?asic.gov.au
  2. ASIC Regulatory Guide 280 Sustainability reporting (March 2025)download.asic.gov.au
  3. AASB S2 Climate-related Disclosures (September 2024)standards.aasb.gov.au
  4. AASB: AASB S2 General FAQsaasb.gov.au