AASB S2 Reporting Deadlines: Which Group Does Your Organisation Fall Into?

Mandatory climate related financial disclosure is no longer a proposal on the horizon. It is Australian law, embedded directly in the Corporations Act 2001, and it is already being enforced. AASB S2 Climate related Disclosures (also referred to as ASRS S2, since it forms part of the Australian Sustainability Reporting Standards) sets out what in scope entities must disclose about governance, strategy, risk management, and emissions. But before any organisation can work out what it needs to disclose, it needs to answer a simpler question first: which group am I in, and when does my clock start?

A phased rollout, not a single deadline

Rather than applying to every company on the same date, AASB S2 is being phased in across three groups, based on entity size. Each group is assessed against the same three tests, and an entity is captured if it meets at least two of the three.

Group 1 was first to report. It applies to financial years beginning on or after 1 January 2025, and it captures entities meeting at least two of these thresholds:

• Consolidated revenue of $500 million or more
• Consolidated gross assets of $1 billion or more
• 500 or more employees

Group 2 entities became subject to mandatory reporting for financial years beginning on or after 1 July 2026. The thresholds step down to:

• Consolidated revenue of $200 million or more
• Consolidated gross assets of $500 million or more
• 250 or more employees

Group 3, the broadest cohort, follows for financial years beginning on or after 1 July 2027, with thresholds of:

• Consolidated revenue of $50 million or more
• Consolidated gross assets of $25 million or more
• 100 or more employees

Thresholds are assessed on a consolidated group basis, not just the size of the Australian reporting entity, so a smaller local subsidiary of a large offshore parent can still be caught.

Captured regardless of size

Meeting the revenue, asset, and employee tests is not the only route into scope. Two other categories are pulled in regardless of size:

• NGER reporters. Entities that report under the National Greenhouse and Energy Reporting Act and meet the relevant emissions publication threshold are captured under Group 1 timing, even if they fall well short of the financial thresholds.
• Large asset owners. Superannuation funds, registered schemes, and retail CCIVs managing $5 billion or more in assets are captured from Group 2 onwards, regardless of revenue or headcount.

If your organisation is a significant emitter or manages a large pool of capital, it is worth checking these tests separately, since they can bring forward an obligation that the size thresholds alone would not.

A word of caution on the 2026-27 Federal Budget changes

In May 2026, the Federal Budget proposed lifting the large proprietary company reporting thresholds under the Corporations Act to $100 million revenue and $50 million assets. It is easy to read this as a delay to AASB S2, but it is not. That proposal affects the separate test for whether a large proprietary company must lodge an audited financial report at all. It does not change the AASB S2 Group 1, 2, or 3 thresholds or timing described above. A company could fall out of the large proprietary company lodgement obligation and remain squarely inside its AASB S2 group. Until the Budget measure is legislated, and even after, the two tests need to be checked separately.

Working out where you sit

For most organisations, establishing group membership is a short exercise: pull consolidated revenue and gross assets from the latest financial statements, confirm headcount on a full time equivalent basis, and check the NGER and asset owner tests. The harder part is what comes next. Group status only tells you when your first reporting period starts. It does not tell you whether your governance arrangements, emissions data, and assurance readiness will hold up once that period arrives, and building that capability from a standing start inside a single financial year is a difficult position to be in.

Even organisations not yet captured by any group are increasingly affected in practice, as Group 1 and Group 2 customers push climate data requests down their supply chains to meet their own Scope 3 disclosure obligations. Understanding your likely group, and your likely runway, is useful well before your official start date arrives.