Who must report under AASB S2 is set by the Corporations Act 2001, not by the standard itself. An entity must prepare a sustainability report, and apply AASB S2, if it is required to prepare an annual financial report under Chapter 2M and it meets one of the sustainability reporting thresholds in section 292A.
Key points
- The obligation comes from section 292A in Chapter 2M of the Corporations Act 2001
- Size test: meet two of consolidated revenue, consolidated gross assets and employees
- Group 1 size test: $500 million revenue, $1 billion gross assets, 500 employees
- Group 2 size test: $200 million revenue, $500 million gross assets, 250 employees
- Group 3 size test: $50 million revenue, $25 million gross assets, 100 employees
- NGER registered corporations and asset owners with $5 billion or more are captured regardless of size
The sustainability reporting thresholds
Entities are placed in one of three groups. A size test is met when an entity meets at least two of the three criteria in its group.
| Group | Size test (two of three) | Other entities captured |
|---|---|---|
| Group 1 | Consolidated revenue of $500 million or more, consolidated gross assets of $1 billion or more, 500 or more employees | Registered corporations under the NGER Act that meet the corporate group threshold in section 13(1)(a) of that Act |
| Group 2 | Consolidated revenue of $200 million or more, consolidated gross assets of $500 million or more, 250 or more employees | All other registered corporations under the NGER Act, and registered schemes, registrable superannuation entities and retail CCIVs with assets of $5 billion or more |
| Group 3 | Consolidated revenue of $50 million or more, consolidated gross assets of $25 million or more, 100 or more employees | None beyond the size test |
Entities that do not have to report
ASIC lists these entities as not required to prepare a sustainability report:
- foreign companies registered under Division 2 of Part 5B.2 of the Corporations Act
- small proprietary companies and registered charities that are not required to prepare an annual financial report under Chapter 2M
- entities with ASIC relief from preparing an annual financial report
Why it matters for asset-intensive operations
The NGER test captures entities regardless of size. A company that is registered under the NGER Act falls into Group 1 or Group 2 even if its revenue, assets and headcount sit below the size thresholds. Entities outside the thresholds may still apply AASB S2 voluntarily, but must meet all of its requirements to claim compliance.
References & sources
Primary regulatory documents and authoritative references underpinning this answer.