What do you need to know?

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Just checking if we’re captured

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Short answers, opened in place

Are we captured?

Australia’s mandatory climate reporting captures entities that already lodge financial reports and meet two of three size tests, plus NGER reporters and large asset owners. The three groups phase in from FY2025 to FY2028. If you meet the Group 3 tests you report for a financial year beginning on or after 1 July 2027.

When is our first report due?

Your sustainability report forms part of your annual report, so it is due on your existing lodgement date, not a separate one. That makes the practical deadline your year end plus the usual reporting window. Work backwards from it, because the data retrieval is the item with the longest lead time.

What data do you need from us?

Twelve months of energy and fuel invoices, fleet and travel records, refrigerant logs, a list of sites with ownership or lease status, and your organisational chart for the boundary. For Scope 3, spend data by supplier category. Nothing that does not already exist somewhere in your finance system.

What does it cost?

Preparation is quoted as a fixed price against a defined scope, so the number does not move unless the scope does. Assurance is billed separately by your assurance provider, because the same firm cannot do both. Ask any provider what triggers a variation before you sign.

Who signs the report?

The directors. The sustainability report carries a directors’ declaration in the same way the financial report does, which is why the board needs the judgement register and the basis of preparation, not only the final numbers. Preparers do not sign, and neither does your assurance provider.

Does the board have to approve the methodology?

Management makes and owns the decisions that drive the numbers: the organisational boundary, the emission factors, the estimation approach. Whoever prepares the report may propose them, but if they also decide them they have assumed a management responsibility. Document each decision and who approved it.

Do we need assurance in year one?

Yes. Assurance phases in alongside the reporting groups, starting with limited assurance over Scope 1 and Scope 2 and the governance disclosures, and widening over time. Plan for an assurance provider from the start, because their evidence expectations shape how you keep records all year.

Can our auditor prepare the report?

Usually not. Once a firm holds the assurance engagement, preparing the disclosure it will later assure creates a self-review threat, which APES 110 treats as one that safeguards cannot reduce to an acceptable level for a public interest entity. The service is then prohibited, not merely discouraged.

What is an organisational boundary and who decides it?

It is the line that decides which entities, sites and activities sit inside your emissions numbers. Management decides it, in writing, before year end. Changing it later means restating comparatives, so it is the single decision most worth getting right in your first reporting year.

Do we have to report Scope 3?

Scope 3 is required, with relief in the first year of a group’s reporting and a value-chain measurement approach that improves over time. Start with the categories that are material to your business and document why the rest are not, rather than attempting every category at once.

What happens if we get it wrong?

The regime carries a modified liability period for certain forward-looking and Scope 3 statements, which narrows who can act on them and for how long. It is relief on exposure, not on the obligation to report. Keeping the working papers is what makes a good-faith position demonstrable.

Where does the report get lodged?

With your annual report to ASIC, as a distinct sustainability report alongside the financial report and directors’ report. It is not a separate voluntary publication, and it is not a sustainability page on your website. Consistency between the two reports is checked.

How much of this can our finance team do?

More than most teams expect on the data, less than they expect on the file. The scarce skill is not carbon accounting, it is knowing what an assurance file has to contain. Teams that succeed in-house usually have several reporting entities and a multi-year programme.

We are not captured yet. Should we do anything?

Two things, both cheap. Confirm which group you fall into and the first year it applies, and start keeping the source documents you will need for a full year of history. Everything else can wait. Retrieving a year of invoices retrospectively cannot.

Answered in full

Our auditor cannot prepare our climate report. Who should we use?

1,036 words · 4 sources

How long does a first report take?

1,126 words · 3 sources

Can one firm do both, prepare and assure?

985 words · 5 sources

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