Who Must Report Under AASB S2 — Groups, Thresholds & Dates | ESGAgent.ai
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Who must report under AASB S2: groups, thresholds and dates

Mandatory climate reporting phases in over three years, largest entities first. You are in a group if you meet at least two of its three size thresholds at the end of the financial year (consolidated revenue, gross assets and employee count), or if you are captured through NGER.

Group 1 · years beginning on or after 1 January 2025

Two of: revenue ≥ A$500m · assets ≥ A$1b · 500+ employees. Also NGER reporters above the publication threshold.

Group 2 · years beginning on or after 1 July 2026

Two of: revenue ≥ A$200m · assets ≥ A$500m · 250+ employees. Also all other NGER reporters, and asset owners with A$5b+ under management.

Group 3 · years beginning on or after 1 July 2027

Two of: revenue ≥ A$50m · assets ≥ A$25m · 100+ employees.

Two details catch people out. First, NGER capture: if you lodge under the National Greenhouse and Energy Reporting scheme, you can be pulled into Group 1 or 2 regardless of your size against the financial thresholds. Second, the dates refer to when your financial year begins . A Group 2 entity with a July year-end reports first on FY2026-27, meaning the systems and baselines need to exist before that year starts, not before the report is due.

Group 3 entities get one concession: if they assess that they face no material climate risks or opportunities, they may make a statement to that effect instead of a full report, but that assessment itself has to be defensible.

Not sure which group you land in? The free readiness check works it out from five questions, then shows you where your biggest gaps sit against the disclosure requirements.

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