We are Group 2. When is our first report actually due?

Group 2 obligations start with your first financial year commencing on or after 1 July 2026, not on 1 July 2026 itself. With a 30 June balance date that is the year ending 30 June 2027. It is lodged by 30 September 2027 if you are a disclosing entity, registered scheme or RSE, otherwise 31 October 2027.

Our financial year ends 30 June. What is our first reporting period?

Your first reporting period is the first financial year that begins on or after your group's start date, so the test applies to the start of the year and not its end. With a 30 June balance date that is the year ending 30 June 2026 for Group 1, 30 June 2027 for Group 2 and 30 June 2028 for Group 3.

What happens if we do not lodge?

The sustainability report is part of your Chapter 2M annual reporting, so failing to prepare or lodge it contravenes the Corporations Act and ASIC can act. ASIC has said enforcement is most likely where an entity fails to prepare a report at all, or where misconduct is serious or reckless.

Glossary›Regulation, capture and thresholds / Regulation, capture and timing›First reporting period vs first report due date

Glossary term

Cluster B · B6

Tier 1 · differentiator

First reporting period vs first report due date

Definition

The first reporting period is the financial year your climate disclosures cover. The first report due date is when the sustainability report must be lodged with ASIC: three months after year end for disclosing entities and registered schemes, and four months for other entities. The two dates are frequently confused and are usually more than a year apart.

Corporations Act 2001

· section 319 ·

In force

On this page

In practice
What the assurer does with it
Commonly confused with
Sources
Related terms
Related questions

Cluster

B · Regulation, capture and thresholds / Regulation, capture and timing, 26 terms

In practice

This distinction is worth its own page because the error is common, consequential and easy to make. “Group 2 starts 1 July 2026” describes when the reporting period begins, not when anything is filed.

Worked through for a Group 2 entity with a 30 June year end:

Step

Date

Group 2 obligation attaches to periods commencing on or after

1 July 2026

First reporting period

1 July 2026 to 30 June 2027

Data collection covers

the whole of that year, so it starts 1 July 2026

Report lodged with ASIC

within 4 months of 30 June 2027, so by 31 October 2027 (3 months, so by 30 September 2027, if a disclosing entity)

The operational consequence is that preparation starts before the reporting period does. Emissions data for July 2026 has to be captured in July 2026. An entity that begins work when it starts thinking about the lodgement date has already lost the first months of activity data and will be estimating them.

Confirmed 15 September 2026. Section 319(3) sets three months for disclosing entities, registered schemes and RSEs, and four months for everyone else, lodged on Form 398. No general transitional relief applies. Individual relief is available on application, decided case by case; ASIC asks entities to apply early and will generally refuse an application lodged after the statutory deadline because a breach has occurred and it cannot grant retrospective relief.

What the assurer does with it

The assurer plans backwards from the lodgement date, because the assurance conclusion has to be signed before the report is lodged, not by it. They fix the fieldwork window, the date the complete evidence file is due, and the date the management representation letter must be signed, all off that single date. What derails a first-year engagement is interim data: activity for the first nine months arriving in the final two weeks, unreconciled. The standard response is a request for an interim pass during the year. An entity that refuses one has chosen a compressed post-year-end engagement, and where the file is not ready the options narrow to a modified conclusion or a late lodgement.

Commonly confused with

The AASB S2 effective date, which is annual reporting periods beginning on or after 1 January 2025 for the standard itself, and the group commencement dates, which determine when a particular entity is captured.