Are Australian companies ready to report under the mandatory ASRS climate legislation? - 100% Renewables

Are Australian companies ready to report under the mandatory ASRS climate legislation?

Welcome back to our comprehensive exploration of the Australian Sustainability Reporting Standards (ASRS), where the exposure draft standard recently closed for comments on 1st March this year. In this instalment, we’re asking the question whether Australian companies are truly prepared for the proposed mandatory ASRS climate reporting that is on the horizon.

Join Barbara Albert, our Co-CEO, as she discusses whether Australian companies are truly prepared for the proposed mandatory ASRS climate reporting

Previously in the series

Before investigating whether Australian companies are ready to report under IFRS/ASRS, be sure to understand the proposed reporting timelines and assurance requirements.

Let’s explore the readiness of Australian companies for mandatory climate reporting by examining their preparedness through two critical perspectives – their engagement level and their understanding.

Figure 1: ASRS Readiness
Figure 1: ASRS Readiness

Reporting voluntarily

First on our map are businesses that are proactively ‘reporting voluntarily’ under frameworks like GRI or CDP to showcase their commitment to sustainability. The reporting of these companies typically covers a wide range of environmental, social, and governance (ESG) topics, with ‘E’ or environmental topics typically including GHG emissions, energy use, climate risks and opportunities, emissions reduction initiatives and climate goals. While CDP focuses more on climate-related information and GHG emissions, GRI provides a broader framework covering the full spectrum of sustainability issues, including environmental, social, and governance aspects.

Companies that are reporting voluntarily showcase high engagement and knowledge, positioning themselves well for the ASRS transition.

Public companies often have a head start over private companies in sustainability reporting, because they are subject to more stringent requirements and scrutiny from regulatory bodies, stock exchanges, and investors. Being in the public eye, these companies are also more sensitive to market expectations and the potential reputational impacts of their actions.

However, the introduction of ASRS represents a shift towards uniformity in sustainability reporting. By mandating structured and comprehensive climate-related disclosures, ASRS will level the playing field, encouraging companies to elevate their sustainability practices and to step up.

Mandatory reporters

Following are the ‘mandatory reporters,’ already familiar with reporting under the National Greenhouse and Energy Reporting (NGER) scheme and, in some cases, the Safeguard Mechanism. Under NGER, these companies disclose:

➡️Scope 1 emissions: Direct emissions from sources they own or control.

➡️Scope 2 emissions: Indirect emissions from the generation of purchased energy.

➡️Energy production and consumption: Quantities of energy produced and consumed, encompassing both renewable and non-renewable sources.

The Safeguard Mechanism further obligates large facilities, emitting over 100,000 tonnes of CO2-equivalent annually, to adhere to emission baselines. Exceeding these baselines requires offsetting through mechanisms like purchasing carbon credits.

However, while these mandatory reporters are adept at handling scope 1 and 2 emissions, gaps remain that ASRS will spotlight. Many have not:

➡️Fully assessed or reported their scope 3 emissions

➡️Evaluated the financial impact of their climate risks and opportunities

➡️Published comprehensive transition plans

Thus, while they have a foundational understanding of emissions reporting, mandatory reporters must expand their efforts to fully comply with the detailed requirements of the proposed ASRS.

Companies that are aware

In the ‘aware’ category, we find those organisations that are ‘aware’ of the incoming climate disclosure standards but haven’t begun any sustainability reporting. Companies that fall into this category often share certain characteristics:

➡️Mid-sized enterprises: These are businesses that are significant enough to feel the impact of ASRS but have not been subject to mandatory reporting requirements in the past. They might be on the threshold of the reporting requirements in terms of revenue, assets, or employee numbers and are becoming aware of their potential obligations under ASRS.

➡️Supply chain participants: Businesses that operate within the supply chains of larger corporations, especially those in Group 1 and Group 2, might fall into the ‘aware’ category. They’re becoming aware due to the increasing demand from their customers (larger corporations) to provide emissions data and other sustainability-related information.

➡️Companies with growing public and market exposure: These could be rapidly growing businesses that are starting to attract more attention from investors, customers, and the public. As their profile rises, so does the scrutiny of their sustainability practices, pushing them to become aware of and understand ASRS and similar frameworks.

➡️Industries facing increased regulatory and consumer pressure: Companies in sectors such as manufacturing, energy, and retail, where there is both heightened regulatory focus on sustainability and increasing consumer demand for transparency and sustainability. Even if they are not yet required to report, the trend towards greater accountability makes them aware of the need to understand and eventually comply with standards like ASRS.

Private companies with ambitious sustainability goals: Some private companies, while not currently obligated to report under any mandatory scheme, may have set ambitious internal sustainability targets. Their awareness of ASRS may stem from a desire to align their voluntary sustainability efforts with emerging standards and best practices.

Regional arms of international corporations: Some businesses may have relatively low scale or environmental impact locally, but are part of a larger international corporation, and are being required to align their reporting and practices to those of their parent company. This may arise due to increasing requirements that are in place or emerging in Europe, North America and the Asia-Pacific region, for example, and are being cascaded down to countries like Australia.

Companies in the ‘aware’ segment are typically in a stage where they recognise the importance of sustainability reporting and are beginning to explore what ASRS might mean for them. They are in the process of assessing their current capabilities and determining what steps they need to take to not only comply with future regulations but also to leverage these changes to enhance their sustainability practices and market positioning.

At 100% Renewables, we have experienced a surge in inbound requests from these businesses seeking clarity and direction. Questions we are hearing range from whether and how ASRS may affect them, what group they might fall under, and crucially, how they can begin to prepare for these legislative changes. For businesses in this category, the path forward involves transitioning from awareness to active preparation and engagement.

Companies that are unaware

At the base, there’s a significant portion of the business landscape that falls into what we’re calling the ‘unaware’ category. These are businesses that don’t currently get caught under mandatory reporting legislation and may not have sustainability reporting on their radar. They are more likely to have taken ad hoc climate action in the past, and may possibly be in Group 3 under ASRS, depending on the final model. Even if they don’t directly fall into any ASRS group, they might still be impacted by ASRS through supply chain pressures, as their customers begin to demand compliance as part of their own ASRS reporting requirements.

Companies that might be unaware of the Australian Sustainability Reporting Standards (ASRS) often share common traits, which can include:

➡️Small businesses: Many small businesses, especially those with limited exposure to international markets or supply chains, might be unaware of ASRS. Their focus tends to be on immediate operational concerns rather than broader regulatory changes, especially if they perceive such standards as applicable only to larger corporations.

➡️Companies outside high-impact industries: Businesses operating in sectors that have historically been less scrutinised for environmental impact—such as small service-based industries, local retail, or businesses not directly linked to high-energy consumption or emissions—may not be aware of ASRS and its implications.

➡️Organisations with limited external financing: Companies that rely less on external investors or capital markets may be less exposed to the growing emphasis on sustainability reporting and, as a result, less aware of emerging standards like ASRS. These companies often do not feel the immediate pressure from investors and stakeholders to align with such standards.

➡️Privately held companies with local focus: Privately owned businesses that operate primarily within a local context and have a small footprint may not be aware of ASRS. Their engagement with sustainability issues might be driven more by local regulations or community expectations than by global or national standards.

➡️Businesses lacking sustainability leadership or focus: Companies that have not yet integrated sustainability into their core business strategy or leadership agenda may be unaware of ASRS. Without a dedicated focus on sustainability, updates and developments in reporting standards may go unnoticed.

The companies that are in the ‘unaware’ segment may not realise it yet, but the ripples of change are likely heading their way, and they need to be prepared. If your business falls into this category, or if you’re in a position to influence these companies, please share this to ensure no one is left behind in this significant transition.


Regardless of where you find your business on this spectrum, the transition to ASRS compliance will present both a challenge and an opportunity. It’s imperative to understand where you stand and to start preparing now. The benefits of early preparation cannot be overstated, from ensuring compliance to seizing the opportunity to lead in corporate sustainability.”

If you’re unsure about your preparedness or where to begin, that’s where we come in. 100% Renewables specialises in equipping businesses with the tools and strategies needed for ASRS readiness. From carbon footprint services to identifying climate risks and opportunities, setting targets, and developing transition plans, we’re here to guide you through every step.”

Next in the series

As we continue to navigate the path to ASRS compliance, stay tuned for our upcoming instalments of this course. In the next blog post, we will analyse how the requirements of ASRS flow through the economy and may affect even small and medium-sized companies.

Our ASRS complimentary course

In our ongoing dedication to assist businesses in their sustainability endeavours, we’ve revamped this multi-part blog and video series into a complimentary online course. Alongside the video content, the course offers additional resources and quizzes designed to enhance your comprehension of the ASRS.

Kickstart your journey towards mastering the ASRS. Join now by following this link. Don’t hesitate to share this opportunity within your network to collectively advance the climate agenda.

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