AustraliaServices ESG & sustainabilityAASB S2 readiness assessment

ESG & sustainability

AASB S2 readiness assessment for Australian businesses

Where you stand against the climate-reporting standard before your group’s start date — gaps named, evidence mapped, no surprises.

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What is aasb s2 readiness assessment?

Where you stand against the climate-reporting standard before your group’s start date — gaps named, evidence mapped, no surprises.

AASB S2 is the climate half of Australia's new sustainability reporting standard (AASB S1/S2, built on the ISSB baseline), and it applies through Chapter 2M of the Corporations Act — the same chapter that already makes a company prepare a financial report and a directors' report each year. From your entity's Group start date, a climate statement sits alongside those existing reports, not instead of them, and it goes through the same annual reporting cycle: prepared, reviewed, signed by directors, lodged with ASIC.

Three groups are phased in by size, and size is worked out under section 292A of the Corporations Act on a 'meets two of three' test against consolidated revenue, consolidated gross assets and employee count — consolidated across the entity and anything it controls, not the standalone figure. Group 1 — consolidated revenue $500 million or more, consolidated gross assets $1 billion or more, or 500 or more employees (any two of the three) — reports for financial years starting on or after 1 January 2025; for a calendar-year reporter that means the first statutory climate statement lodges around 30 September 2026. Group 2 — $200 million revenue, $500 million assets, or 250 employees — starts from financial years beginning on or after 1 July 2026, which for most Australian companies means the year that has just started. Group 3 — $50 million revenue, $25 million assets, or 100 employees — starts from financial years beginning on or after 1 July 2027. NGER Act reporters above the NGER publication threshold and asset owners above $5 billion in assets are pulled into the regime independently of these size tests.

Who does what

Preparation and gap analysis only — directors sign the statement, and assurance belongs to AUASB-registered practitioners we refer to.

Who does what

Your CapEasy teamAASB S2 readiness assessment, the reconciliations and reporting behind it, and the questions list that keeps it honest.
Your registered BAS or tax agentEverything that carries a licence in Australia — rendered exactly as written: work out what goes on your bas, or advise you on it — under tasa 2009 that requires registration we do not hold.
YouOne conversation with one named person, and the decisions that are genuinely yours.

AASB S2 readiness assessment in Australia

Group membership is a two-of-three test, not a single number

Section 292A treats an entity as being in a group if it meets at least two of that group's three thresholds — consolidated revenue, consolidated gross assets, employee count — for the financial year. A business that clears the revenue line for Group 3 but sits well under the assets and employee count lines is not automatically in scope; the test has to be run against all three metrics on a consolidated basis (the entity plus anything it controls), before a start date can be assigned with any confidence.

Group 1's first lodgement window is close, and it sets the pattern for Group 2 and 3

A Group 1 entity with a financial year starting 1 January 2025 has a reporting period ending 31 December 2025, with the climate statement due to lodge with ASIC on the same statutory clock as the annual report — around 30 September 2026 for most calendar-year filers. Group 2 entities whose financial year began 1 July 2026 are now inside their first in-scope reporting period; their statement follows the same four-section structure and lodges on the same cycle roughly a year later.

The modified liability period narrows enforcement, it does not remove the requirement

For the first three reporting years after an entity's Group start date, ASIC — not a private party — is the only body that can act on a misleading or deceptive statement confined to the forward-looking parts of the disclosure: Scope 3 emissions estimates, climate scenario analysis, and transition plan content. Governance disclosures, Scope 1 and 2 emissions, and factual statements sit outside that protection from year one, which is why the readiness assessment treats those sections as the ones to get right first.

A Group 3 entity with no material climate risk can publish a short-form statement instead

An entity that lands in Group 3 but can demonstrate it has no material climate-related risks or opportunities is permitted to publish a short 'no material risk' statement rather than the full four-section disclosure — but reaching that statement still requires doing the assessment work to establish materiality, and the statement still needs director sign-off and an auditor's report. It's a genuinely smaller exercise, not a way to skip the assessment; we describe this as a separate, related service rather than folding it into this one.

What your registered BAS or tax agent receives from us

  • A gap assessment mapped against AASB S2's four sections — governance, strategy, risk management, metrics and targets — with each requirement marked closed, partially evidenced, or open.
  • A Group-membership working paper: the section 292A two-of-three test run against your consolidated revenue, gross assets and employee count — the entity plus anything it controls — with the resulting start date and first lodgement window stated.
  • An evidence index — board papers, risk registers, existing emissions records, supplier and customer data requests already on file — linked against the specific disclosure requirement each one supports.
  • A Scope 1 and 2 emissions data inventory: what activity data exists, what is missing, and what needs to be collected before the first reporting period closes.
  • A prioritised remediation list ordered by what falls outside the modified liability protection first (governance, Scope 1/2, factual statements), so the highest-exposure gaps get closed before the lower-stakes forward-looking ones.
  • A draft climate statement structured to AASB S2, built from the closed and partially-evidenced items in the gap assessment, ready for your board to review, amend and sign.

Questions worth asking before you start

Who actually does the work — a person or an AI tool?

A named person on our team owns your file and reviews everything that leaves it. Software does a real share of the grinding underneath it — coding, matching, flagging the obvious gaps — but nothing regulated happens without a person’s judgement, and nothing here is signed or filed by an algorithm.

Who can legally lodge this?

Preparation and gap analysis only — directors sign the statement, and assurance belongs to AUASB-registered practitioners we refer to.

Which software do you work in?

Whatever you already run. Most commonly QuickBooks, Xero, NetSuite, Sage, Zoho Books and a handful of others — we work inside your system rather than moving you onto one of our own.

How does this actually start?

A short, free read-only look at what you already have, and a written note on what we found. A scoping call decides the size of the engagement — nothing here commits you to anything.

What does it cost?

There is no published price for aasb s2 readiness assessment — it depends on volume, how many entities are involved, and how far behind the books are. We quote after the read-only review, which is free.

How does this fit with the rest of esg & sustainability?

AASB S2 readiness assessment sits inside esg & sustainability, alongside Scope 3 supplier data pack, Group 3 “no material risk” statement prep. Most clients end up buying the category as a whole rather than one leaf at a time, but starting narrow is fine.

Which Group am I in, and when do I actually have to start reporting?

It's a two-of-three test under section 292A against consolidated revenue, consolidated gross assets and employee count — the entity plus anything it controls, not the standalone figure. Group 1 (revenue $500m+, assets $1b+, or 500+ employees) started from financial years beginning 1 January 2025; Group 2 ($200m/$500m/250 employees) from financial years beginning 1 July 2026; Group 3 ($50m/$25m/100 employees) from financial years beginning 1 July 2027. We run the working paper against your actual consolidated numbers rather than estimate from the headline thresholds.

Is this a checklist tool or an actual assessment?

An assessment. We map your existing governance, risk, and data evidence against AASB S2's four sections and hand back a gap list with each item marked closed, partially evidenced, or open, plus a prioritised remediation plan — not a self-serve questionnaire.

Do you sign the climate statement or lodge it with ASIC?

We prepare the gap assessment and a draft statement built from it. Your directors review and sign the statement, and it lodges with ASIC on the same statutory cycle as your annual report — the same officeholder process your existing financial report already goes through.

What is the modified liability or "safe harbour" period, and does it mean I can skip the hard parts?

For the first three reporting years after your Group start date, only ASIC — not a private litigant — can act on a misleading forward-looking statement in the climate disclosure: Scope 3 estimates, scenario analysis, transition plan content. It does not cover governance disclosures, Scope 1/2 emissions, or factual statements, which is why we prioritise those in the assessment regardless of where you sit in the modified liability period.

Do I need an audit of my climate statement in year one?

Assurance is being phased in progressively rather than applying to every entity from its first reporting period — the AUASB sets the standard and the phase-in schedule. We flag the assurance date that applies to your Group as part of the assessment, and refer you to an AUASB-registered assurance practitioner once your board is ready to engage one — assurance is that practitioner's role, separate from our preparation work.

We are under the Group 3 thresholds today — do we still need to do anything?

If you supply into a Group 1 or Group 2 reporter, or your bank or insurer is asking climate questions as part of credit or underwriting, you can be answering emissions data requests well before your own mandate arrives. That is a separate, narrower service (our Scope 3 supplier data pack) from a full AASB S2 readiness assessment.

What is the Group 3 'no material risk' statement, and can we just publish that instead?

An entity that lands in Group 3 but can demonstrate it has no material climate-related risks or opportunities can publish a short-form statement instead of the full four-section disclosure. Reaching it still requires an assessment to establish materiality, and the statement still needs director sign-off and an auditor's report — we treat it as a smaller, related engagement, not a shortcut around the assessment.

Is the $50 million Group 3 threshold definitely staying where it is?

Not necessarily. Treasury has a live proposal to raise the Corporations Act's large proprietary company thresholds from $50 million to $100 million in revenue, and Group 3's climate-reporting thresholds are pegged to those figures. A change would shrink the Group 3 cohort. We track the consultation and flag it in any Group 3 assessment rather than treating the current threshold as fixed.

What does the gap assessment actually check against?

AASB S2's four required sections: governance (board and management oversight of climate risk), strategy (risks, opportunities and their financial effect, including scenario-based resilience), risk management (how climate risk is identified and integrated into existing processes), and metrics and targets (starting with Scope 1 and 2 emissions). Each requirement is checked against evidence you already have, not assumed.

How does Scope 1 and 2 emissions data fit into a readiness assessment if we have never measured it before?

We inventory what activity data already exists — utility bills, fuel records, fleet data — and identify what is missing, because that collection work takes the longest and sits outside the modified liability protection from your very first reporting year. Getting this started early is one of the main things a readiness assessment is for.

What's the difference between this and CapEasy's CDP or EcoVadis services?

AASB S2 readiness is prep for a statutory Corporations Act disclosure with a legal start date and ASIC lodgement. CDP and EcoVadis are voluntary questionnaire responses driven by a customer or investor request, not a legal mandate — different trigger, different document, same underlying data discipline.

Your CapEasy experts

Connect with us

Talk to the people who handle this work every day — no call centre, no hand-offs.

Ayush Joshi

Ayush Joshi

Co-Founder

Ex-OYO and Tenaciousfly. 7+ years in business development, strategic acquisitions, financing and debt syndication.

Aditya Jain

Aditya Jain

Co-Founder

Ex-Bank of America. 4+ years in investment banking, EU & Indian compliances, ESG compliances, and project management.

Manav Raval

Virtual CFO & Tax Specialist

Section 80-IAC, tax planning and startup compliance. Previously at Toyota Motor Corporation and Jaguar Land Rover.

Ayush Faldu

Virtual CFO & Tax Specialist

Financial strategy, budgeting and cash flow — a CFO’s judgement, monthly.

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