The proposed amendment to Listing Rule 17.5 maintains the current approach: listed entities will only face mandatory suspension if they fail to lodge the annual directors’ report, statutory financial report or auditor’s report by the due date. This approach provides a transitional period for entities adapting to new sustainability reporting requirements and therefore will not trigger suspension if the sustainability report is it is not lodged with annual reporting package to the ASX by the due date.

Many entities are still determining their sustainability reporting status (Group 1, 2 or 3). CA ANZ recognises that a phased approach is necessary and does not support immediate trading suspension for late sustainability report lodgment during the initial implementation phase. Instead, failure to lodge sustainability reports alongside financial statements should be treated as a significant event under Listing Rule 3.1, requiring prompt market disclosure.

The proposed amendment should be temporary, addressing initial challenges. CA ANZ recommends reviewing the rule after Group 3 entities complete their first reporting year, to align climate-related disclosures with financial statements and directors’ reports.