In December 2025, CA ANZ responded to the Department of Climate Change, Energy, the Environment and Water’s (DCCEEW) consultation on draft national climate scenario guidance.

Key points:

• Currently, there is an immediate gap in supporting reporting entities with scenario analysis, especially for those preparing sustainability reports for the first time.
• The draft guidance should align with the Corporations Act 2001, Climate Change Act 2022 and AASB S2 Climate-related Disclosures. Consistency is vital for reporting entities preparing mandatory climate disclosures.
• While AASB S2 requires assessment of both physical and transition risks, the draft guidance focuses only on physical risks.
• The guidance should avoid language that implies government endorsement and should present neutral, informative options.
• Worked examples and practical case studies should be included in guidance to support preparers.