- ASIC outlines a pragmatic enforcement strategy, initially focusing on serious or reckless misconduct.
- Mandatory reporting begins in 2025 for Australia’s largest companies, expanding gradually to medium and small companies.
- Guide introduces new details on climate scenario analysis and scope 3 emissions reporting.
Australia’s financial regulator, ASIC, has issued its new Regulatory Guide 280 (RG 280), clarifying compliance expectations under the country’s mandatory climate reporting law.
The law, enacted in September 2024, requires public companies, large proprietary companies, and significant asset owners to disclose climate-related risks, opportunities, and greenhouse gas emissions.
ASIC Commissioner Kate O’Rourke emphasized the importance of the new requirements:
“Climate-related financial information that is consistent, comparable and of high quality, facilitates confident and informed decision making by investors and other users of that information.”
Pragmatic Enforcement Approach
ASIC will adopt a “proportionate and pragmatic” strategy initially, offering direct engagement and corrective opportunities before pursuing enforcement actions.
ASIC stated clearly:
“The sustainability reporting requirements are new for Australia. Both market practice and policy developments relating to climate-related financial disclosures will also continue to evolve both domestically and internationally.”
Investigations and enforcement actions will prioritize:
- Serious or reckless misconduct
- Failure to prepare required sustainability reports
Gradual Implementation Timeline
Reporting begins in July 2025 for:
- Companies with over 500 employees, revenues exceeding $500 million, or assets above $1 billion
- Asset owners managing assets over $5 billion
Medium-sized companies begin reporting in July 2026, with smaller companies following in July 2027.
Enhancements Following Consultation
ASIC’s final guide reflects stakeholder feedback, adding:
- Guidance on climate scenario analysis and scope 3 emissions disclosure
- Specific instructions for directors of reporting entities
- Clarifications on applying sustainability reporting thresholds
Commissioner O’Rourke highlighted:
“The publication of RG 280 is a critical piece that supports the implementation of these sustainability reporting requirements passed by the Australian Parliament. We will continue to expand our broader suite of publications related to sustainability reporting over time as market practices evolve.”
ASIC will also consider granting relief from reporting and audit requirements under specific conditions and provide targeted support to entities navigating the new regulations.
Read the full guide here.
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