An AASB S2 sustainability report follows the same lodgement timetable as the rest of the annual report under Chapter 2M of the Corporations Act 2001. It is lodged with ASIC together with the financial report and the directors’ report, not as a separate filing on a later date.
Key points
- Lodged with ASIC as part of the annual report
- Three months after year end for disclosing entities, registered schemes and registrable superannuation entities
- Four months for other entities
- Sustainability records kept for seven years after the report is completed
- A 30 June listed company lodges by 30 September, a month before the NGER report is due
Lodgement deadlines
| Entity | Deadline after financial year end |
|---|---|
| Disclosing entities, registered schemes and registrable superannuation entities | Three months |
| Other entities that must report | Four months |
A listed company is a disclosing entity. With a 30 June year end, it must lodge its sustainability report by 30 September. A company that is not a disclosing entity, with the same year end, has until 31 October.
Record keeping
An entity must keep sustainability records that correctly record and explain the matters in its sustainability report. The records must be kept for seven years after the report is completed. Failing to keep them is a strict liability offence, so no fault needs to be proved.
How this interacts with NGER
NGER reports are due on 31 October each year for the financial year ended 30 June. For a listed company with a 30 June year end, the AASB S2 sustainability report is due a month earlier. The emissions in the sustainability report therefore need to be finalised before the NGER report, and the two figures should reconcile once differences in boundary, method and global warming potential values are allowed for.
Why it matters for asset-intensive operations
Three months is a short close for a full-year emissions inventory. Fuel, electricity and production data from every site, emission factors, Scope 3 estimates and the auditor’s review all have to land inside that window, alongside the financial statements audit. Groups that close emissions monthly, with evidence captured at the source and approvals recorded as they happen, are in a far better position than those that assemble the year after it ends. The same records then serve the seven-year retention obligation without a separate archiving exercise.
References & sources
Primary regulatory documents and authoritative references underpinning this answer.