Glossary›Measurement and governance / Governance, board and directors›Management-level climate responsibility

Glossary term

Cluster E · E6

Tier 3

Management-level climate responsibility

Definition

Management-level climate responsibility identifies the roles below the board that own climate data, judgements and disclosures, and how they report upward. AASB S2 requires disclosure of whether the role is delegated to a specific management position or committee, how oversight is exercised over it, and whether management uses controls and procedures.

· paragraph 6(b), ASSA 5010 paragraph 10(a)(i) ·

In force

In practice

Paragraph 6(b) is the second half of the governance disclosure and it gets a fraction of the attention paragraph 6(a) gets, despite being the half that describes where the work actually happens.

It requires disclosure about management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities, including whether the role is delegated to a specific management-level position or committee and how oversight is exercised over that position or committee.

Three practical consequences.

A named position, or a stated absence of one. The disclosure asks whether the role is delegated to a specific position or committee. The honest answer for many first-year private reporters is that responsibility sits with the CFO alongside everything else, with an analyst or financial controller doing the work. That is a disclosable answer. What is not disclosable is a job title that exists on an organisation chart and has no occupant.

Oversight of the delegate. The standard asks how oversight is exercised over the position or committee, which means the reporting line and the challenge mechanism, not just the appointment. A CFO who owns the disclosure and reports to a board that never questions it is described accurately by saying so.

Controls and procedures. The word “controls” appears in paragraph 6(b) and it is the bridge into the assurance conversation. Management’s controls over sustainability data are what reasonable assurance will test directly from each entity’s fourth reporting year. A first-year disclosure that describes controls management does not have is creating a problem three years out, and a disclosure that honestly describes a manual process being formalised is not a deficiency.

The single-point-of-failure problem. For a mid-market Australian group the emissions inventory is typically built by one person. That person holds the method, the assumptions and the undocumented decisions. The management responsibility disclosure is the place this becomes visible, and a board reading it carefully should ask the succession question: if this individual left in March, could the report be produced. If the answer is no, the disclosure is accurate but the entity has a reporting continuity risk it has just described in a public document.

What the assurer does with it

Management responsibility disclosures are inside the year-one limited assurance scope under ASSA 5010 paragraph 10(a)(i), because they are part of the paragraph 6 governance disclosures.

The assurer tests them through inquiry and documents. They ask the named individual what they do and compare the answer to the disclosure. They ask for the position description, the delegation and the reporting line. Where controls are described, they ask for evidence the control operated: a sign-off, a review record, an exception log.

This is the point where a limited assurance engagement quietly becomes useful to the entity. The assurer is not testing controls for reliance in year one, but the act of asking which controls exist produces a list of what does not, a full three years before reasonable assurance makes it expensive.

They accept a disclosure naming a position that matches a real role with a real position description and an evidenced reporting line. They reject a named committee with no terms of reference and no minutes, a described control with no evidence of operation, and a disclosure asserting management oversight where the only evidence is the annual report approval.

Commonly confused with

Board oversight under paragraph 6(a), which is the governance body’s role. The two are separate sub-requirements and entities regularly answer 6(a) thoroughly and 6(b) in a sentence. Also confused with internal controls over sustainability reporting, which is the control environment itself; this disclosure is about who is accountable for it.

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

Review status

Review required

Last reviewed

15 September 2026

Editorial pass, unsigned

Reviewer required

Company secretary or governance practitioner

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.