3
Reporting groups
Phased in from 1 January 2025 to 1 July 2027 under the Corporations Act 2001.
Do I need to comply with AASB S2?
The groups, thresholds and first reporting dates, in one place.
Mandatory climate reporting is phased in under the Corporations Act 2001 across three groups of entities. Work through the size tests, the NGER trigger and the asset-owner threshold to find your group and your first reporting period.
AASB S2 applicability summary:
Who needs to comply with AASB S2?
An entity must prepare a sustainability report if it is required to prepare an annual financial report under Chapter 2M of the Corporations Act 2001 and meets one of the reporting thresholds in section 292A of the Act.
2 of 3
The size test
Consolidated revenue, gross assets and employees. Meeting any two puts you in a group.
$50m
Group 3 revenue threshold
The regime reaches medium-sized entities from July 2027.
There are three routes into the regime under section 292A: the corporate size test (two of three criteria on consolidated revenue, gross assets and employees), the emissions threshold for NGER reporters, and the value-of-assets threshold for registered schemes, superannuation entities and retail CCIVs.
Reporting is phased across three groups: Group 1 from annual periods beginning on or after 1 January 2025, Group 2 from 1 July 2026, and Group 3 from 1 July 2027. The figures on this page are as set out in ASIC Regulatory Guide 280 (RG 280).
What are the AASB S2 reporting thresholds?
Group 1, periods from 1 January 2025
Two of three: consolidated revenue of $500m or more, gross assets of $1bn or more, 500 or more employees. Also NGER reporters above the publishing threshold.
Group 2, from 1 July 2026
Two of three: revenue of $200m or more, gross assets of $500m or more, 250 or more employees. Also all other NGER reporters, and registered schemes, super entities and retail CCIVs with $5bn or more in assets.
Group 3, from 1 July 2027
Two of three: revenue of $50m or more, gross assets of $25m or more, 100 or more employees.
Not captured
Entities with no Chapter 2M financial reporting duty: most small proprietary companies, registered foreign companies and exempt charities.
Requirements
Which group am I in?
Start with Chapter 2M. If you do not prepare an annual financial report under the Corporations Act, the regime does not capture you.
Apply the two-of-three size test. Check consolidated revenue, gross assets at year end and employee count against each group’s criteria, largest group first.
Check the NGER trigger. NGER reporters above the publishing threshold are Group 1; all other NGER reporters are Group 2, regardless of size.
Asset owners have their own line. Registered schemes, superannuation entities and retail CCIVs report from Group 2 at $5 billion or more in assets, and under the size test from Group 3.
Work out your group in under a minute
Answer a few questions and get your group and first reporting period. The logic follows ASIC Regulatory Guide 280.
Do you prepare an annual financial report under Chapter 2M of the Corporations Act?
If you lodge audited financial reports with ASIC, the answer is usually yes.
General guidance, not legal or accounting advice. Thresholds per ASIC Regulatory Guide 280 (March 2025) and section 292A of the Corporations Act 2001. Check RG 280 for your specific circumstances.
Materiality
How does materiality affect what you disclose?
- Assess enterprise value impact. Focus on climate information that could influence investor decisions.
- Document thresholds. Record why a risk, opportunity, or Scope 3 category is material or not.
- Engage board and auditors. Agree on judgements early to streamline assurance.
- Update annually. Materiality decisions should be revisited each reporting cycle.
Compliance steps
When is your first report due?
Your first reporting period. The first financial year commencing on or after your group’s start date: 1 January 2025 for Group 1, 1 July 2026 for Group 2, 1 July 2027 for Group 3.
A worked example. A Group 2 entity with a 30 June year end first reports for the year 1 July 2026 to 30 June 2027.
The Group 3 relief valve. A Group 3 entity with no material financial risks or opportunities relating to climate may lodge a statement to that effect instead of full disclosures, under section 296B.
Below every threshold? Nothing is required yet, though large customers and lenders may ask for climate data regardless of your group.
Actions if you’re unsure about S2 applicability
Run the two-of-three test
Ten minutes with last year’s financial report answers most applicability questions.
See where you stand
The readiness assessment scores your process in about three minutes.
See what you’ll disclose
The AASB S2 disclosures checklist lists every requirement with its clause.
Plan the work
The CFO’s six-step operating guide covers the process from scope to assurance-ready disclosure.
Glossary snapshot
AASB S2 applicability glossary snapshot
The size test. Two of three criteria on consolidated revenue, gross assets and employees, set out in section 292A of the Corporations Act 2001.
NGER. The National Greenhouse and Energy Reporting Act 2007. NGER reporters are captured regardless of the size test.
Groups 1 to 3. The phased reporting groups, starting 1 January 2025, 1 July 2026 and 1 July 2027.
FAQs
Do I need to comply with AASB S2? FAQs
Do I need to comply with AASB S2?
If you prepare an annual financial report under Chapter 2M of the Corporations Act and meet one of the section 292A thresholds, yes. Reporting starts with Group 1 (periods beginning on or after 1 January 2025), then Group 2 (1 July 2026) and Group 3 (1 July 2027).
What are the Group 1 thresholds?
Two of three: consolidated revenue of $500 million or more, consolidated gross assets of $1 billion or more, or 500 or more employees. NGER reporters above the publishing threshold are also Group 1. See ASIC Regulatory Guide 280.
What are the Group 2 and Group 3 thresholds?
Group 2: two of three of $200 million revenue, $500 million gross assets and 250 employees, plus all other NGER reporters and asset owners with $5 billion or more. Group 3: two of three of $50 million revenue, $25 million gross assets and 100 employees.
Do superannuation funds and managed schemes report?
Yes. Registered schemes, registrable superannuation entities and retail CCIVs with $5 billion or more in assets report from Group 2, and under the size test from Group 3.
What if a Group 3 entity has no material climate risks?
It may lodge a statement to that effect instead of full climate disclosures, under section 296B of the Corporations Act. The materiality assessment follows AASB S2.
What if I'm below every threshold?
No sustainability report is required. Many smaller entities still get asked for climate data by large customers and lenders, so knowing your position is worth the ten minutes.
Drova's AASB S2 solution keeps objectives, approvals, and disclosures aligned across finance and sustainability teams.
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