Glossary›AASB S2 disclosure requirements / AASB S2 mechanics›Transition plan (disclosure requirement)

Glossary term

Cluster C · C12

Tier 1

Transition plan (disclosure requirement)

Definition

A climate-related transition plan is an entity’s plan for responding to climate-related risks and opportunities, including any greenhouse gas emissions targets. AASB S2 does not require an entity to have one. It requires disclosure of the plan if the entity has one, including the assumptions it depends on and how it will be resourced.

· strategy and decision-making disclosures, paragraph 14(a)(iv) ·

In force

In practice

The distinction between having a plan and disclosing one is the practical point. An entity with no transition plan is not non-compliant. An entity with a plan that discloses only the headline target, without the assumptions, dependencies and resourcing behind it, is on weaker ground.

Directors should be aware that a published transition plan is a forward-looking statement with consequences. Statements about a transition plan are protected under section 1707D for financial years commencing 1 January 2025 to 31 December 2027 inclusive, but that protection is time-limited and does not extend to voluntary statements repeated elsewhere, such as in an investor presentation.

What the assurer does with it

The transition plan is disclosed under paragraph 14, which comes into review scope from the second reporting year when ASSA 5010 paragraph 10(b) extends the review to all disclosures.

The assurer tests whether the plan disclosed is the plan the entity actually has. They ask for the board or committee approval, the assumptions and dependencies register behind it, and the budget or capital plan that resources it. They accept a plan traceable to an approved document with stated assumptions and a funding line. They reject a transition plan described in the sustainability report that the board has not approved, a resourcing claim that appears in no budget, and a plan whose targets differ from the targets disclosed under paragraphs 33 to 36.

Commonly confused with

A climate-related target, which is the destination rather than the route. A target is disclosed under paragraphs 33 to 36; the plan for achieving it is disclosed under paragraph 14(a)(iv). Also confused with a requirement to have a plan, which AASB S2 does not impose.

Timing and relief

Statements about a transition plan fall inside the modified liability settings in section 1707D of the Corporations Act, which apply to financial years commencing between 1 January 2025 and 31 December 2027 inclusive. That protection is time-limited and ends with those periods, and it does not extend to the same statements repeated in voluntary material outside the sustainability report.

Sources

1

AASB S2 Climate-related Disclosures, compiled to December 2025

AASB

2

Corporations Act 2001 (Cth)

Federal Register of Legislation

3

ASSA 5010 Timeline for Audits and Reviews of Information in Sustainability Reports under the Corporations Act 2001

AUASB

Review status

Review required

Last reviewed

15 September 2026

Editorial pass, unsigned

Reviewer required

Registered company auditor

Next scheduled review

31 December 2027

Part of

Cluster C, AASB S2 disclosure requirements / AASB S2 mechanics

25 terms on what the climate disclosure standard actually requires, pillar by pillar, plus the reliefs and the effort standard.