Australia’s climate disclosure regime is no longer theoretical. For Group 1 entities, mandatory reporting under AASB S2 is approaching fast and energy data is one of the most scrutinised, audit-exposed components of the new framework.
While many organisations understand what they need to report, far fewer are confident their energy and emissions data is audit-ready, defensible, and aligned with financial reporting standards.
This is where preparation, not just compliance, matters.
What Is AASB S2 and Why Group 1 Entities Are Under Pressure
Australian Accounting Standards Board AASB S2 requires entities to disclose climate-related risks and opportunities that could reasonably affect financial performance, position, or cash flows.
For Group 1 entities (large listed companies and significant financial institutions), this includes:
- Scope 1, 2 and relevant Scope 3 emissions
- Energy consumption and procurement data
- Climate-related transition risks tied to energy contracts
- Governance, controls, and data assurance processes
Critically, this information must be consistent, verifiable, and capable of withstanding external audit, not just internally compiled sustainability reporting.
The Hidden Risk: Energy Data That Isn’t Audit-Ready
Energy data is often fragmented across:
- Multiple retailers and contracts
- Different sites, subsidiaries, or operating entities
- Manual invoices, PDFs, or spreadsheets
- Inconsistent emissions factors and methodologies
For Group 1 entities, this creates several material risks:
- Inability to reconcile energy data with financial statements
- Weak audit trails for Scope 2 emissions
- Inconsistent disclosures year-on-year
- Increased audit costs and review friction
- Exposure to regulatory scrutiny or restatement
In short: late preparation equals expensive clean-up.
What “Audit-Ready” Energy Data Actually Means
From an assurance perspective, energy data needs to be:
- Complete: covering all sites, meters, and contracts
- Accurate: using defensible emissions factors and methodologies
- Consistent: aligned across periods and entities
- Traceable: with source documentation and clear audit trails
- Reconciled: capable of linking to financial reporting and risk disclosures
This is not just a sustainability exercise. It’s an accounting and governance requirement.
How Termina Helps Group 1 Entities Prepare — At No Extra Cost
As part of Termina’s commercial energy procurement model, we help public companies prepare AASB S2-ready energy data, free of charge.
This isn’t an add-on consultancy. It’s built into how we manage energy procurement.
What’s Included
When Group 1 entities procure energy through Termina, we provide:
- Centralised energy and usage data across all sites
- Clean, standardised datasets suitable for audit review
- Emissions calculations aligned to reporting requirements
- Clear documentation of assumptions and methodologies
- Historical and forward-looking energy insights tied to transition risk
This allows sustainability, finance, and audit teams to work from the same single source of truth.
Why This Matters Before the Due Date
With AASB S2 deadlines approaching, organisations that wait until reporting season often face:
- Rushed data validation
- Increased reliance on external consultants
- Higher audit fees
- Internal rework across finance and sustainability teams
By embedding audit-ready energy data now, Group 1 entities can:
- Reduce reporting risk
- Lower compliance costs
- Improve governance confidence
- Avoid last-minute remediation
Procurement Is the Foundation of Climate Reporting
Energy procurement decisions directly affect:
- Emissions profiles
- Cost volatility
- Transition risk disclosures
- Forward-looking financial impacts
Treating procurement and reporting as separate workstreams is one of the most common mistakes we see.
Termina’s approach aligns energy procurement, emissions data, and reporting readiness in a single framework — so compliance becomes a by-product of good commercial decision-making.
Final Thought: Don’t Treat AASB S2 as a One-Off Exercise
For Group 1 entities, AASB S2 is not a box-ticking exercise. It’s the start of ongoing, auditable climate disclosure tied directly to financial performance.
Organisations that prepare early, particularly around energy data, will move through audits with far less friction.
Those that don’t will feel it in cost, complexity, and risk.

