Climate reporting for HSE leaders in Australia FAQs

NGER reports for 2025-26 are due on Monday 2 November 2026, and the Clean Energy Regulator has said it can’t grant extensions. More on that in the NGER answer below.

Mandatory climate reporting has ended up with HSE teams in a lot of Australian organisations, often with little warning. Over the three sessions of Managing What Matters, our series with myosh Academy, HSE and HSEQ leaders sent us their questions. A few were about Scope 3, but most covered who is in scope, what the deadlines are, where the data ends up and how to bring leadership along.

Below are the answers, in roughly the order the questions tend to come up. We’ve merged ones that overlapped, and a UK edition will follow separately. The information is general and current as at October 2026. Check the primary sources we link, and take professional advice for your own situation.

Watch the first session in full:

The standards and who’s covered

How do ASRS, AASB S2 and IFRS fit together, and where does HSE come in?

AASB S2 is Australia’s version of IFRS S2, the global baseline set by the International Sustainability Standards Board. It forms part of the Australian Sustainability Reporting Standards (ASRS), which the Australian Accounting Standards Board issues. The UK has adopted the same baseline, and the EU’s standards are designed to align with it, so most jurisdictions are moving in the same direction.

HSE gets involved because of the data. Climate disclosure relies on fuel, energy, incident and site records that HSE teams already manage, and it needs documented, auditable numbers at site level rather than aggregated estimates. Session 1 covers this from 9:54, and we also have an explainer on AASB S2.

Who has to report, and when?

You must prepare a sustainability report if the Corporations Act (Chapter 2M) requires you to prepare an annual financial report and you meet either a size threshold or an NGER emissions threshold. ASIC sets out the thresholds in Regulatory Guide 280. For the size tests, you need to meet two of the three:

• Group 1 (reporting periods from 1 January 2025): revenue of $500 million or more, gross assets of $1 billion or more, or 500 or more employees.
• Group 2 (from 1 July 2026): $200 million, $500 million or 250 employees.
• Group 3 (from 1 July 2027): $50 million, $25 million or 100 employees.

Thresholds are measured on a consolidated basis, so they include the entities you control. Registered NGER corporations are also captured through a separate emissions threshold, as Group 1 or Group 2 whatever their size. The group walk-through is in Session 1 from 16:07, and we have a guide to AASB S2 Group 2 as well.

Do local governments have the same reporting requirements?

Not in the same way, and councils aren’t captured by this regime. Mandatory AASB S2 disclosure currently applies to large entities that prepare financial reports under the Corporations Act, so many councils sit outside it for now. ASIC’s guidance expects the public sector and other agencies to report under a variation of the sustainability standards eventually (RG 280, paragraph 113).

Meanwhile, state reporting obligations, grant conditions and community expectations are asking for similar data, and a number of councils have decided to get ahead of it. Those that build the data and the process now will avoid a scramble later, and will be better placed for funding that rewards demonstrated climate readiness.

Not sure which group you’re in, or whether you’re covered at all? A free readiness assessment will map what’s expected of you now against what’s coming. Book a call with our team.

Scope 3

What are the requirements for Scope 3 reporting in Australia?

Scope 3 isn’t required in your first reporting period, but it becomes mandatory in your second. For a Group 2 entity whose first period began on 1 July 2026, that means the period starting 1 July 2027.

You’ll need to disclose your absolute gross Scope 3 emissions for the material categories, using a defined methodology. Nobody expects the figures to be perfect at the start. AASB S2 assumes Scope 3 data will involve estimation, and it allows primary data (such as supplier data), secondary data (such as industry averages) or a mix of the two. Scope 3 is often the biggest part of an organisation’s footprint, so the groundwork you do in year one matters. The GHG Protocol’s Scope 3 Standard lists the categories, and we’ve written about why supplier data collection is so hard. The Scope 3 timing is in Session 1 from 18:56.

Does the modified liability period protect us from legal claims?

Partly, and only for certain statements. For sustainability reports covering financial years that commence between 1 January 2025 and 31 December 2027, statements about Scope 3 emissions (including financed emissions), scenario analysis and transition plans are “protected statements”. Only criminal action or action by ASIC can be brought over them, which means an investor can’t bring a civil claim alleging they’re misleading.

The protection has limits. It covers only statements made to comply with the standard, not voluntary disclosures, and it doesn’t extend to the same statements made elsewhere unless the law requires them. Forward-looking climate statements are only protected for financial years starting in 2025, so in practice this helps Group 1 only. ASIC sets this out in RG 280. The period exists to give entities room to settle in, so it’s a poor reason to put the work off.

NGER

How can we simplify NGER reporting?

Collect the data once. Record fuel and electricity by site, month by month, in a single place, and keep the source records, because NGER reports must be supported. If you do this well, the same site data can feed both NGER and AASB S2.

The two are separate regimes, so it helps to keep the differences clear:

• Who reports: a corporate group at 50 kilotonnes of CO2-e or 200 terajoules of energy, or a single facility at 25 kilotonnes or 100 terajoules.
• Who receives it: the Clean Energy Regulator, through its online system.
• When: by 31 October each year. For 2025-26 the deadline is midnight AEDT on Monday 2 November 2026, because 31 October falls on a Saturday. The Regulator has said no extensions can be granted.
• What’s measured: Scope 1 and 2 emissions, energy production and energy consumption, using NGER’s prescribed methods. Where NGER and AASB S2 call for different methods, record which one you applied.
• How they connect: a registered NGER corporation meets AASB S2’s emissions threshold, so check both.

For the wider picture, see our step-by-step guide to mandatory climate reporting in Australia.

Lodgement, assurance and preparation

Which framework should we use, and is there a form to fill out?

There’s no form. Entities in scope prepare a sustainability report under AASB S2 Climate-related Disclosures and lodge it with ASIC alongside the annual financial report. AASB S2 has four pillars: governance, strategy, risk management, and metrics and targets. For emissions measurement it draws on the GHG Protocol’s Corporate Standard and Scope 3 Standard.

A few habits make the biggest difference: one dataset, a documented method, a named owner for each data source, a clear audit trail, and early conversations with your assurance provider.

Where does the reported data go, and are there financial implications?

It goes into a public filing, and from there into decisions made by investors, lenders, insurers and customers. The sustainability report is lodged with ASIC within three months of year end for disclosing entities, superannuation entities and registered schemes, and within four months for other entities. Anyone can search ASIC’s register for it.

Directors sign a declaration about the report. For financial years commencing between 1 January 2025 and 31 December 2027, the declaration says they’ve taken reasonable steps to ensure the report complies. From financial years commencing on or after 1 January 2028, it becomes a full opinion on compliance (RG 280, paragraphs 58 and 59). You must also keep your sustainability records for seven years.

The financial implications come from several directions. Large facilities covered by the Safeguard Mechanism have emissions baselines that decline over time, so measured data affects cost. Investors, lenders and insurers increasingly ask for the same figures, and large customers screen suppliers on them in tenders. A report that can’t be assured carries its own risk too.

How is assurance phased in, and when does the full audit start?

ASSA 5010 sets the phasing, using fixed date windows for each group:

• Year 1: a review (limited assurance) over governance, parts of strategy (the climate-related risks and opportunities you identify and describe), Scope 1 and 2 emissions, and any statement that you have no material climate risks or opportunities.
• Years 2 and 3: a review of all disclosures in the sustainability report, including Scope 3.
• Year 4 onward: an audit (reasonable assurance) over all disclosures.

Year 4 begins with the first financial year commencing on or after 1 July 2028 for Group 1, 1 July 2029 for Group 2 and 1 July 2030 for Group 3. These are financial year start dates, so an entity with a 30 June year end reaches year 4 on that date, and one with a 31 December year end reaches it on the following 1 January. From financial years commencing on or after 1 July 2030, the Corporations Act requires every sustainability report to be audited.

What do we need to do to prepare, and what actually matters?

Begin by working out where you stand, before you pick a framework or a platform. Find out what you already measure, what data exists but isn’t formally captured, and what your reporting deadline and obligations are. Group 2 entities started their first reporting period on 1 July 2026, so for many organisations the clock is already running.

After that, three things matter most. Capture Scope 1 and 2 data from HSE continuously, because you can’t rebuild twelve months of fuel logs when the auditor turns up. Document your methodology as you go. And bring your assurance provider in early, since a review of Scope 1 and 2 applies from your first report.

A practical first step is to check what your HSE system already holds against four categories: fuel and generator logs, refrigerant top-upsm m, grid electricity by site, and contractor vehicle movements. When we onboard organisations, most find the bulk of their Scope 1 and 2 data is already in their HSE logs, as Grace Phelan explains in Session 1 (from 9:14). The gaps tend to be in documentation and methodology. The data itself is usually there. She also covers the one thing to do this week, from 22:15.

Climate and HSE

How do climate and health and safety relate?

They’re moving closer together quickly. Climate and sustainability disclosure draws heavily on data HSE teams already manage, including energy use, fuel, incident and site records. It’s also increasingly sitting inside the same risk and assurance framework as safety reporting, instead of running as a separate stream.

For many organisations, this means the people already responsible for H&S compliance are well placed to lead the climate work too, without a new function being created. The four things HSE already owns are covered in Session 1 from 20:19.

How does climate change affect workplace health and safety?

It changes both the hazards and the controls. Extreme heat raises the risk of heat stress for outdoor work and plant operation. Bushfire smoke affects air quality and site access, and floods and storms damage sites and disrupt operations. AASB S2’s own definition of physical climate risk includes extreme temperature changes that affect premises, operations and employee health and safety, so the hazard identification and controls HSE teams already run form part of climate risk management.

How do we raise the environment up the corporate agenda?

Present it the way HSE already presents risk, as an operational risk with a legal obligation attached. Directors sign a declaration about the sustainability report, so the board has a direct stake.

From there, get specific. Show leadership the data you already hold, put the deadlines and assurance dates on one page, and explain what happens if the data can’t be rebuilt at year end. A named executive sponsor, usually from finance or risk, helps a lot. The people who move early often end up as the link between operational data and the legal obligation.

How does incident reporting through to corrective action apply to emissions?

The same loop works with very little change. A site burning more diesel than expected, or a refrigerant top-up that keeps recurring, looks a lot like a repeat incident. Identify the hotspot by source and by site, find the cause, assign an action with an owner and a due date, and check that it worked.

Where you can, log these in the risk register and corrective action workflow you already use, so emissions hotspots sit next to your other operational risks rather than in a separate spreadsheet. Session 2 of the series applied critical control thinking to carbon hotspots in this way. The recording is also on the myosh Academy page.

HSE emissions data and systems

How do we consolidate multiple systems without losing historical data?

Before moving anything, map each system’s fields to one common set of categories. Load prior years as a baseline with the source documents attached, and keep legacy systems available in read-only form until their numbers have been reconciled. Record every mapping decision and assumption so a future auditor can follow your reasoning, and lock each period once it’s been reported.

eco-shaper is built to bring divisions and sites into a single reporting structure, and it locks each reporting period once it’s closed.

Can data collection and emission factors be automated?

Partly. Automation works where the source data is structured, such as electricity interval data, fuel card feeds and meter reads. Where data arrives on paper or from contractors, keep a person in the loop. Whatever you automate, keep the source record attached to every figure.

Emission factors need the same care. Grid electricity intensity varies by region, so a national average can overstate or understate a site’s footprint. eco-shaper applies regionally specific emission factors, and our piece on why the emissions factor database matters more than the method goes into the reasons.

How do we handle a much older site?

You don’t need perfect data to begin. Older sites often have limited metering, legacy equipment and patchy records, so set the boundary, gather 12 to 24 months of invoices and meter reads, and identify the biggest users. Look closely at older heating, cooling and refrigeration equipment, because refrigerant leaks are a significant and often missed source of Scope 1 emissions.

Where you have to estimate, document the method and the assumption, then plan sub-metering for the largest loads so the estimate gets better over time. A documented estimate that you keep improving is much easier to defend than an undocumented guess.

Priorities and KPIs

Where should we invest resources to minimise impact?

Build a hotspot view by source and by site, and work down from the largest. Location matters more than people expect. The myosh page for Session 2 gives the example of a mining site in Victoria, which emits roughly 3.5 times more from grid electricity than the same site in South Australia. That kind of difference changes where the effort should go. For Scope 3, a small number of categories usually account for most of the exposure, so identify those first.

How do we tell leaders that not investigating everything is good for business?

You could put it like this: “We’re prioritising the categories that drive most of our footprint, and we’ve documented why we’re deferring the rest.”

That position is consistent with the standard. AASB S2 asks entities to use reasonable and supportable information that is available without undue cost or effort, and ASIC’s guidance accepts that Scope 3 will involve estimation. The catch is documentation. ASIC has said it may scrutinise how entities apply these flexibilities, so keep a record of why each category was deferred. A reviewer has no way to tell a deliberate, evidence-based exclusion from something that was simply missed.

What KPIs suit small and medium businesses?

A short list is enough. Good starting KPIs include total Scope 1 and 2 emissions, emissions intensity (per employee, per project or per dollar of revenue), fuel use per operating hour, electricity use by site, and the share of waste diverted from landfill. For Scope 3, add the percentage of key suppliers providing actual data rather than estimates. Pick five or six and track them consistently.

What should a demolition and civil works group track to show clients it is cutting Scope 3?

Tag every record to a job. Clients such as builders and developers count your services and waste in their own Scope 3, so they need project-level numbers from you. Tag each fuel, waste and haulage record to a job number, and report by business unit, such as demolition, asbestos removal, civil works and waste facilities.

Useful metrics include fuel used by plant and by project, plant hours, waste tonnes by stream with the destination and the share recycled or reused, haulage distance, electricity at yards and facilities, and refrigerant recovered from decommissioned systems. Consistent project tagging matters more than how many metrics you track.

Still have a question?

If you’re working out where you stand, a free readiness assessment is a simple way to map what’s expected of you now against what’s coming. Book a call with our team and we’ll walk through it.

If suppliers are your biggest gap, see how eco-shaper’s supply chain engagement platform works. You can also find more at www.eco-shaper.com.