Australia now has early, practical insights into how organisations are responding to the Australian Sustainability Reporting Standards, following the publication of around 30 Group 1 listed entities climate disclosures so far. Additionally noting that some unlisted entities have also published their disclosures, which are included within their annual reports, which are available at a cost from the ASIC register. While this is a relatively small sample, these first reports provide useful signals about current practice and the likely direction of travel as reporting matures. 

From voluntary reporting to regulated financial disclosure 

Climate disclosures are now sitting squarely within the financial reporting framework, subject to governance, controls and assurance expectations comparable to other financial information. For many entities, this has required changes to responsibilities and processes, with finance teams playing a more central role alongside sustainability expertise. 

For some entities, this was their first experience of structured climate reporting. For others, including more established voluntary reporters, the transition still required adjustment to meet the discipline and specificity expected under mandatory standards. 

It is clear that climate information is increasingly being treated as decision‑relevant financial information, rather than supplementary narrative. 

Early reports show good‑faith engagement 

The first wave of disclosures shows a wide range of approaches. Some organisations have integrated climate risks and opportunities into strategy, capital planning and financial analysis. Others have, at least initially, focused more narrowly on meeting baseline requirements. 

This variation reflects differences in sector exposure, organisational maturity and prior experience with climate reporting. It also reflects the challenge of implementing new standards without many domestic or global precedents to draw on. 

Importantly, early reporters demonstrated that reporting under the standards is operational and achievable. Entities navigated governance, data, assurance and timing pressures, creating an initial reference point for subsequent reporting cohorts. 

Quantifying financial effects: progress and practical lessons

Disclosure of anticipated financial effects is one of the most discussed topics. 

Around half of early reporters provided some form of quantification, while others pointed to uncertainty, evolving methodologies or challenges in separating climate effects from other drivers. This is often less the result of a technical modelling issue and more a question of how organisations translate information they already use internally into external disclosures. 

Many entities already draw on scenario analysis, budgeting, investment planning and asset reviews. The challenge is connecting those insights to clear explanations of management’s current view of how climate‑related risks and opportunities may affect financial performance over time. 

The standards do not require precision or forecasting certainty. Instead they are more focused on transparency around assumptions, judgements and where there is uncertainty. From an investor perspective, quantified information supported by explanation is often more useful to users than the complete absence of disclosure, even where estimates remain incomplete. 

Organisations tend to make the most progress where scenario analysis, strategy and financial planning were developed together, rather than as separate exercises. 

A shifting regulatory perimeter 

In Tuesday night’s Federal Budget, the Government announced measures to reduce reporting burden by increasing the monetary thresholds for large proprietary companies — from $50 million to $100 million in consolidated revenue, and from $25 million to $50 million in consolidated gross assets. As a result, some Australian businesses that fall below these revised thresholds will no longer be required to lodge an annual audited financial report, directors’ report or sustainability report.

The Government also announced that it will consult on reforms to improve the efficiency of climate‑related financial disclosures while maintaining core sustainability reporting requirements. These reforms are expected to include clarifying how concepts such as undue cost or effort apply in practice, adjusting assurance settings so they are proportionate and practical, and setting clearer boundaries on supplier information requests to reduce cost and complexity, particularly for small businesses. 

These developments are relevant as organisations assess their future reporting obligations and implementation approaches alongside the early lessons emerging from current reporters. 

From compliance to entity‑specific information 

A consistent theme is that early reporting has focused, understandably, on completeness — identifying risks, responding to disclosure requirements and establishing internal processes. 

Looking ahead, greater emphasis is expected on entity‑specific information. Investors and other users are seeking clearer insight into how climate‑related risks and opportunities affect particular business models, asset bases and value chains. 

Disclosures that move beyond generic descriptions to explain where impacts arise, which parts of the business are exposed, and how management is responding are more likely to be decision‑useful. A practical test discussed during the session was whether disclosures could apply equally to many organisations, or whether they clearly reflect the reporting entity’s specific circumstances. 

Many of these insights come from a recent CA Sustainability Community webinar, which I moderated, focused on early lessons from Australia’s first climate disclosures and what they mean for current and upcoming reporters. The discussion brought together perspectives from standard‑setting, assurance and investors, with contributions from: 

• Jonathan Streng CA, Managing Director, Deloitte Australia 
• Fiona Manning, Manager, Engagement, Australian Council of Superannuation Investors 
• Jack Bisset, Climate Implementation Lead, Australian Accounting Standards Board (AASB) 

Together, the panel reflected on what we are seeing in the market from the first wave of mandatory climate disclosures, where organisations are making progress, and where further development is expected. 

Key messages for current and future reporters 

Three messages stand out for current and future reporters. 

First, mandatory climate reporting is underway and operational. Entities have delivered reports under the new framework and standard. 

Second, early preparation makes a significant difference. Entities that began building capability earlier, generally experienced smoother implementation and clearer outcomes. 

Third, climate reporting will continue to evolve. Each reporting cycle offers an opportunity to strengthen analysis, improve financial connectivity and refine disclosures as data, systems and governance mature. 

The focus now is on steady improvement — building relevance, confidence and usefulness over time — supported by ongoing regulatory refinement, professional judgement and market experience.