2. Readiness: your roadmap & budget to compliance (ASRS AASB S2)

Amelia Shore

Environmental Risk Consultant

WHAT YOU'LL LEARN

WHAT YOU'LL LEARN

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Top 5 things you need to know if you’re in...

  1. Mandatory climate reporting is now legislated in Australia, with companies entering the rollout in three phases. starting in 2025.

  2. Entities meeting 2 of these 3 criteria fall into Group 2, and need to prepare now: consolidated revenue ≥$200M, consolidated gross assets ≥$500M, or ≥100 employees must start reporting for periods beginning 1 July 2026 AASB S2 reporting standard

  3. Disclosure requirements cover governance, strategy, risk management, and metrics including Scope 1, 2 and 3 emission

  4. Your sustainability disclosures require a directors' declaration, with penalties mirroring financial reporting – up to $15 million or 10% of annual turnover, with directors personally liable AASB S2 knowledge hub

Finance

CFO’s, Financial Controllers, Finance Managers

  1. Mandatory climate reporting is now legislated in Australia, with companies entering the rollout in three phases. starting in 2025.

  2. Entities meeting 2 of these 3 criteria fall into Group 2, and need to prepare now: consolidated revenue ≥$200M, consolidated gross assets ≥$500M, or ≥100 employees must start reporting for periods beginning 1 July 2026 AASB S2 reporting standard

  3. Disclosure requirements cover governance, strategy, risk management, and metrics including Scope 1, 2 and 3 emission

  4. Your sustainability disclosures require a directors' declaration, with penalties mirroring financial reporting – up to $15 million or 10% of annual turnover, with directors personally liable AASB S2 knowledge hub

Risk & Compliance

CFO’s, Financial Controllers, Finance Managers

  1. Mandatory climate reporting is now legislated in Australia, with companies entering the rollout in three phases. starting in 2025.

  2. Entities meeting 2 of these 3 criteria fall into Group 2, and need to prepare now: consolidated revenue ≥$200M, consolidated gross assets ≥$500M, or ≥100 employees must start reporting for periods beginning 1 July 2026 AASB S2 reporting standard

  3. Disclosure requirements cover governance, strategy, risk management, and metrics including Scope 1, 2 and 3 emission

  4. Your sustainability disclosures require a directors' declaration, with penalties mirroring financial reporting – up to $15 million or 10% of annual turnover, with directors personally liable AASB S2 knowledge hub

ESG

CFO’s, Financial Controllers, Finance Managers

  1. Mandatory climate reporting is now legislated in Australia, with companies entering the rollout in three phases. starting in 2025.

  2. Entities meeting 2 of these 3 criteria fall into Group 2, and need to prepare now: consolidated revenue ≥$200M, consolidated gross assets ≥$500M, or ≥100 employees must start reporting for periods beginning 1 July 2026 AASB S2 reporting standard

  3. Disclosure requirements cover governance, strategy, risk management, and metrics including Scope 1, 2 and 3 emission

  4. Your sustainability disclosures require a directors' declaration, with penalties mirroring financial reporting – up to $15 million or 10% of annual turnover, with directors personally liable AASB S2 knowledge hub

a Board role

CFO’s, Financial Controllers, Finance Managers

  1. Mandatory climate reporting is now legislated in Australia, with companies entering the rollout in three phases. starting in 2025.

  2. Entities meeting 2 of these 3 criteria fall into Group 2, and need to prepare now: consolidated revenue ≥$200M, consolidated gross assets ≥$500M, or ≥100 employees must start reporting for periods beginning 1 July 2026 AASB S2 reporting standard

  3. Disclosure requirements cover governance, strategy, risk management, and metrics including Scope 1, 2 and 3 emission

  4. Your sustainability disclosures require a directors' declaration, with penalties mirroring financial reporting – up to $15 million or 10% of annual turnover, with directors personally liable AASB S2 knowledge hub

ESG Consulting or Professional services

CFO’s, Financial Controllers, Finance Managers

What is a Readiness Assessment, and why now?

Don’t know where to start with Australia’s Sustainability Reporting Standard (ASRS) AASB S2?

A readiness assessment is your compliance health check for mandatory climate reporting. It maps your current capabilities against AASB S2 requirements and gives you a clear roadmap - covering resourcing, systems and budget. In plain terms, it shows you where the gaps are in governance, data, risk management and reporting before they could expose you to penalties. The upper end of the spectrum for false or misleading statements, potentially resulting up to $16.5 million or 10% of annual turnover.

And the risk is real. ASIC fined Vanguard $12.9 million, Mercer $11.3m, and Active Super $10.5m in 2025 for misleading claims.

An AASB S2 readiness assessment also clarifies whether you need systems, consultants, or both. For most Group 2 and 3 organisations, a hybrid approach is the most cost-effective, keeping budgets tight and audits smooth to avoid expensive remediation when deadlines hit.

Why now?

Group 2 entities begin reporting from 1 July 2026 (less than 10 months away) and Group 3 follow soon after with just 22 months to build systems, governance, and emissions measurement from the ground up.

Starting now turns what could be a 12-month scramble into a strategic plan, saving hundreds of thousands in consultant fees, system rework and audit overruns - while putting you ahead of competitors still trying to decode AASB S2.

Not sure what Group your business falls in? See the Preliminary readiness assessment toolkit below.

Why conducting a Readiness Assessment matters for your business

Picture your next board meeting: "Are we ready for mandatory climate reporting?".

The room falls silent, and all eyes turn to you.

Without a readiness assessment and roadmap to AASB S2 compliance, businesses risk chasing the wrong priorities - wasting months and potentially hundreds of thousands on misaligned solutions. Worse still, breaches of corporate law could see directors personally liable, including prison terms.

A readiness assessment isn’t a box-ticking exercise. It’s your business case for resources, your insurance against failure, and your pathway to building lasting capability.

The benefits of acting now are quantifiable, with unprepared companies facing

  • Emergency consultant and assurance fees often double standard rates
  • Failed first attempts that need costly rework, usually when time has already run out
  • Extended audit timelines when under ASIC deadline pressure

ASIC Commissioner Kate O’Rourke has already warned entities to implement strong governance and sustainability record-keeping processes now, highlighting the far-reaching impact of this reform.

Meanwhile, prepared companies secure better terms with service providers, build capabilities that serve beyond compliance, and position themselves as leaders with investors and customers.

The assessment also reveals unexpected benefits: operational efficiencies through better data, enhanced risk management frameworks, and strategic insights about climate opportunities previously invisible.

ASRS AASB S2 Readiness assessment Mandatory climate reporting

The practical guide to Readiness: who needs to do what, by when

What AASB S2 actually requires

AASB S2 requires disclosure of climate-related risks and opportunities affecting cash flows, access to finance or cost of capital. These disclosures must be reported with the same rigour as financial reporting.

Main requirements relate to governance, strategy, risk management, and metrics and targets, including scenario analysis and Scope 1, 2 and 3 emissions. Your readiness assessment must evaluate capabilities across all four AASB S2 pillars:

  • Governance: Board oversight mechanisms and management accountability structures
  • Strategy: Climate scenario analysis capability and financial impact quantification
  • Risk Management: Integration with enterprise risk frameworks
  • Metrics & Targets: Emissions measurement systems with audit trails
ASRS AASB S2 Readiness Assessment output - Greener

The high-level, step by step guide

To make it easy for you, here’s the 6 step process to undertake a Readiness Assessment, outlining who needs to do what.

Considering Group 2 entities have <10 months to start reporting (and <22 months for Group 3), regardless of what Group you’re in, the when for these activities is now.

The key is starting early enough to address gaps systematically rather than in crisis mode.

Step 1: Mobilise your cross-functional assessment team

  • Who: CFO leads, with Risk, Sustainability, Operations, HR and IT
  • When: Immediately (week 1)
  • How:
    • Appoint executive sponsor with board reporting line
    • Identify subject matter experts across functions
    • Establish weekly steering committee
  • Output: Project charter with clear accountabilities

Step 2: Map current state against requirements

  • Who: Cross-functional assessment team
  • When: Week 2
  • How:
    • Use AASB S2 requirements checklist (220+ items)
    • Document existing policies, systems and data
    • Identify what's missing, partial or complete
  • Output: Board-approved climate governance charter

Step 3: Assess data and systems readiness

  • Who: Finance, IT and Operations teams
  • When: Week 2
  • How:
    • Inventory current emissions data sources
    • Test data quality and audit trails
    • Evaluate system integration needs
  • Output: Data maturity assessment and system requirements

Step 4: Evaluate governance and capability

  • Who: Company Secretary and HR
  • When: Week 3
  • How:
    • Review board and management structures
    • Assess climate expertise gaps
    • Survey stakeholder understanding
  • Output: Governance gap analysis and capability plan

Step 5: Define your resource needs

  • Who: CFO with department heads
  • When: Week 3
  • How:
    • Estimate internal FTE requirements
    • Identify technology investments needed
    • Calculate external support costs
  • Output: Resource plan with budget estimates

Step 6: Build your compliance roadmap

  • Who: Executive team
  • When: Week 4
  • How:
    • Prioritise gaps by risk and effort
    • Sequence initiatives over 12-18 months
    • Define success metrics and milestones
  • Output: Board-ready roadmap with investment case

"Large businesses and financial institutions should ensure that they implement appropriate governance arrangements and sustainability record-keeping processes ahead of the mandatory climate reporting requirements taking effect from 1 January 2025” Kate O’Rourke, ASIC Commissioner AASB S2
ASRS AASB S2 Readiness assessment Mandatory climate reporting

Common mistakes to avoid

Mistake #1: Treating readiness assessment as a box-ticking exercise

Rushing through compliance formality, businesses can end up with shallow outputs that satisfy initial disclosure requirements, but need to be reworked and miss strategic value.

Do instead: Use it as strategic planning that identifies opportunities. 80% of directors that see climate as material risk also see opportunity.

Mistake #2: Excluding key functions from assessment

Limiting the process to finance or sustainability ignores critical dependencies across IT, HR, risk and operations - leading to blind spots across systems, data and controls.

Do instead: Involve finance, risk, operations, HR and IT from day one. Less than 60% have involved technology function in their mandatory climate reporting efforts despite planning to.

Mistake #3: Leaving it too late

AASB S2 compliance can take years, not weeks, and rushing means exposing your gaps to investors, auditors or strategic clients.

Do instead: Conduct your readiness assessment now. Use any available lead time to test systems, build processes, and ensure your first report is audit-ready to save on cost.

Quick wins

Quick win #1: Confirm your start date

Check if your business is captured by the legislation, and identify which rollout group you fall into (see the Preliminary readiness assessment toolkit below).

Result: Clarity on your reporting timelines.

Quick win #2: Conduct a preliminary readiness assessment

Get an early view of your compliance roadmap and key risks, along with indicative budget needs for planning (see the Preliminary readiness assessment toolkit below).

Result: An initial view on your roadmap to compliance and placeholder budget needs for your upcoming budget planning cycle.

Quick win #3: Proactively inform your board

Share your one-page preliminary readiness dashboard with the board to let them know you are proactively preparing for compliance, while embarking on your complete readiness assessment.

Result: Immediate board engagement and sponsorship


ASRS AASB S2 Readiness assessment Mandatory climate reporting

Toolkit: Preliminary readiness assessment

It takes less than 5 mins, and you get a high-level, board ready roadmap to AASB S2 compliance, that surfaces immediate gaps, risks and initial placeholders for budget season.

It’s low effort and high impact, designed to give Executives and Boards clarity while mobilising for the complete readiness journey across all 149 disclosures.

Walk into your next board meeting with confidence, knowing where you stand today and what to do next.

Disclaimer: This toolkit provides a preliminary snapshot, and should not be solely relied on for your AASB S2 report submission.

Greener's complimentary ASRS AASB S2 Readiness Assessment takes less than 5 mins and provides a Board ready output and roadmap to compliance, that includes budgeting needs
ASRS AASB S2 Readiness assessment Mandatory climate reporting


Next steps: Your 30 day action plan

ASIC urges all entities, including Groups 2 and 3, to begin preparing now - here's your action plan to get started.

Week 1: Mobilise & engage

  • Use the preliminary readiness assessment tool to confirm which AASB S2 Group you’re in, and get an early view on your roadmap to compliance
  • Use this to brief your Executive team on AASB S2 and form cross-functional assessment team
  • Schedule board briefing on findings

Week 2: Assess

Week 3: Analyse

  • Prioritise gaps by risk and effort
  • Develop preliminary resource & budget estimates
  • Identify quick wins for immediate action

Week 4: Plan

  • Create 18-month implementation roadmap
  • Prepare board paper with investment case
  • Establish governance structure

What’s after readiness?

With your readiness baseline established, Module 3 will guide you through building the governance framework essential for AASB S2 compliance (coming soon).

Additional AASB S2 resources

Additional resources

For those who want to dive deeper, here is some additional reading:

Written by:
Amelia Shore

Amelia is an expert in environmental science, corporate sustainability, and climate risk advisory, with a reputation for blending technical rigour with practical commercial insight. She helps businesses align with frameworks such as TCFD, IFRS S2, and AASB S2, delivering audit-ready disclosures and strategies that turn compliance into competitive advantage.

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