Glossary term

Cluster E · E8

Tier 3

Greenhushing

Definition

Greenhushing is deliberately under-disclosing climate targets, plans or performance to reduce the risk of a greenwashing claim. It is a rational response to enforcement risk for voluntary claims. For a captured entity it is not available for required disclosures, because omitting or obscuring material information is itself a compliance failure.

AASB S2 Appendix D

· paragraphs 18, B28, B29 and B30 ·

In force

In practice

Greenhushing became a recognisable pattern in Australia after the 2024 and 2025 enforcement outcomes, and the logic is easy to follow. If a target can be prosecuted and silence cannot, say less. Legal advice pointing in that direction is not irrational for voluntary marketing claims.

The reasoning breaks completely once disclosure is mandatory, and the distinction a board needs is between the two categories.

Voluntary claims. Marketing statements, certification badges, campaign commitments. Saying less here genuinely reduces risk, and an entity that retires unsubstantiated claims from its website is doing something sensible rather than something evasive.

Required disclosures. Everything AASB S2 requires. Silence here is not safety, it is non-compliance, and the standard’s own materiality definition makes the point directly. Appendix D paragraph 18 provides that information is material if omitting, misstating or obscuring that information could reasonably be expected to influence the decisions primary users make on the basis of general purpose financial reports. Omission and obscuring sit alongside misstatement as failure modes with equal weight.

Appendix D paragraph B28 adds the temporal dimension: an entity shall reassess its materiality judgements at each reporting date to take account of changed circumstances and assumptions, since information that was material may cease to be and information not previously disclosed may become material. A materiality assessment carried forward unchanged from last year is not an assessment.

And Appendix D paragraph B29 closes the obvious workaround, providing that an entity shall not reduce the understandability of its disclosures by obscuring material information with immaterial information. Burying a difficult figure in volume is a named failure, not a presentational choice.

The forms greenhushing actually takes in a first Australian report are subtler than outright omission, and they are worth listing because they look like caution rather than avoidance.

Declining to set any target, so that paragraph 33 never engages. This is legitimate (there is no requirement to have a target) but it should be a real strategic decision recorded as such, not a disclosure-avoidance decision, because the difference will be visible in the board papers.

Describing a transition plan in terms so general that nothing in it is checkable. AASB S2 requires disclosure of information about a transition plan where the entity has one, and a plan that exists internally in specific form and externally in vague form is the disclosure equivalent of the marketing gap that produced every enforcement action to date.

Reporting emissions at maximum aggregation so that no component is visible. This runs directly into Appendix D paragraph B30, which provides that information shall not be aggregated if doing so would obscure material information.

And withdrawing a previously published target without explaining why. The withdrawal is more conspicuous than the target ever was, and an unexplained disappearance invites exactly the scrutiny it was meant to avoid.

The position that actually reduces risk is neither claim-maximisation nor silence. It is disclosure that is complete, specific, sourced and bounded: state the scope, state the base year, state what is estimated, state what the target does and does not cover, and state the uncertainty. A specific target with stated limits is harder to attack than a vague aspiration, because the reader can see exactly what was promised. Vagueness feels safe and is not; it is what leaves an ordinary reader free to form an expectation the entity never intended.

What the assurer does with it

Completeness of disclosure is squarely inside the assurance scope, and it expands in the second reporting year when ASSA 5010 paragraph 10(b) extends review to all disclosures in the sustainability report.

The assurer tests disclosure completeness against the standard itself, working the requirements as a checklist. Where a requirement is not addressed, they ask why, and “we decided not to disclose that” is answered by asking for the materiality assessment that supports the omission.

They also test in the other direction, using knowledge obtained during the engagement. Where the assurer has seen a board paper describing a material climate risk that does not appear in the report, that is a completeness finding and it is one the assurer cannot ignore, because they have the evidence in their own file.

They accept an omission supported by a documented, current-period materiality assessment applying the Appendix D paragraph 18 definition. They reject an omission with no assessment behind it, a materiality assessment rolled forward without reconsideration contrary to Appendix D paragraph B28, a disclosure that addresses a requirement in words without addressing it in substance, and aggregation that removes visibility of a component the assurer knows to be material.

The most awkward version is the internal-external gap: a risk register, a board paper or a strategy document naming a material climate risk that the published report does not. The assurer sees both documents. There is no good answer to that question at the approval meeting.

Commonly confused with

Greenwashing, its opposite. Also confused with commercial confidentiality, which is a legitimate consideration but not a general exemption from disclosure. AASB S2 provides relief in specific defined circumstances, and a general commercial-sensitivity objection is not one of them; where an entity wants to withhold on that basis it needs to identify the specific relief it is relying on.

Sources

1

AASB S2 Climate-related Disclosures

AASB

2

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

AUASB

3

Regulatory Guide 280 Sustainability reporting

ASIC

Review status

Review required

Last reviewed

15 September 2026

Editorial pass, unsigned

Reviewer required

Corporate lawyer or registered company auditor

Next scheduled review

1 July 2027

Part of

Cluster E, Measurement and governance / Governance, board and directors

10 terms on what the board must be able to evidence, what personal exposure directors carry, and how the audit and risk committee engages with the assurer. Governance disclosures sit inside the year-one assurance scope.