CA ANZ has responded to Treasury’s consultation on improving the efficiency of Australia’s climate-related financial disclosure regime. Our submission supports targeted refinements that reduce unnecessary cost and complexity while maintaining disclosure quality, implementation certainty and international comparability.

Australia is among the first jurisdictions to implement climate-related disclosures aligned with IFRS S2 alongside sustainability assurance standards aligned with ISSA 5000. Early implementation has required significant investment in governance, data, systems and capability, but it is also producing benefits, including stronger board engagement and better climate-related information and processes.

The priority now should be to provide stability while reporting and assurance practices mature.

For this reason, CA ANZ supports retaining limited assurance at this stage rather than setting a fixed transition to reasonable assurance. With some Group 1 entities yet to lodge their first reports and Groups 2 and 3 still entering the regime, there is not yet enough evidence to determine whether the benefits of mandatory reasonable assurance for users of the information would outweigh the additional cost and complexity. Any future transition should be informed by user demand, market capability and experience across all reporting groups and disclosure areas.

The most immediate opportunity to improve efficiency is practical implementation support. Rather than amending internationally aligned standards, AASB S2 and ASSA 5000, guidance should focus on the areas creating the greatest uncertainty, including proportionality, undue cost or effort, materiality, Scope 3 emissions, scenario analysis, anticipated financial effects and value-chain boundaries. Worked examples, case studies and decision tools would help entities apply the existing requirements more consistently and proportionately.

A central, well-publicised repository of guidance, domestic emissions factors, calculation tools and practical resources would reduce duplication and support more consistent reporting. Free access to sustainability reports lodged with ASIC would also allow entities to learn from emerging practice and compare how others are applying the requirements.

CA ANZ also recommends amending Registered Company Auditor (RCA) eligibility requirements so statutory sustainability assurance experience counts towards prescribed practical experience, supporting the future pipeline of assurance practitioners as reporting expands.

Our submission also asks Treasury to consider a limited extension of Scope 3 transitional relief, minimise legislative requirements that duplicate or modify AASB S2 concepts, revisit modified liability settings so later reporting cohorts receive comparable benefits, and monitor international passporting initiatives that may reduce duplication for multinational groups. Together, these targeted measures would improve how the existing framework operates without undermining its core requirements.