Mandatory climate reporting - Australia

AASB S2 compliance checklist for Scope 1, 2 & 3 emissions

A free, step-by-step readiness checklist for Australia’s mandatory climate-related financial disclosures under the Australian Sustainability Reporting Standards (ASRS)

Whether you're a franchise group with 200+ sites, a national hospitality chain, a multi-site retailer, or any reporting entity under the Corporations Act - this checklist covers what you need to disclose, how to calculate your greenhouse gas (GHG) emissions across every site and state, and how to meet your AASB S2 obligations.

● Group 1 - Reporting now

Large entities

≥ $500M revenue · ≥ $1B assets · > 500 employees
Or: NGER publication threshold
First period: FY from 1 Jan 2025
View Group 1 checklist
● Group 2 - From July 2026

Mid-size entities

≥ $200M revenue · ≥ $500M assets · ≥ 250 employees
Or: NGER reporter · AUM ≥ $5B
First period: FY from 1 Jul 2026
View Group 2 checklist
● Group 3 - From July 2027

Smaller reporting entities

≥ $50M revenue · ≥ $25M assets · ≥ 100 employees
Materiality exemption available
First period: FY from 1 Jul 2027
View Group 3 checklist
Understanding emissions scopes

What are Scope 1, 2 and 3 emissions?

Under the GHG Protocol - the global standard for carbon accounting - greenhouse gas emissions are classified into three scopes. Scope 1, 2 and 3 emissions together represent your organisation's total carbon emissions profile. AASB S2 requires Australian entities to measure and disclose scope 1 2 3 emissions as part of mandatory ESG reporting, phased over the first two years.

Scope 1 - Direct emissions

Emissions you generate

Greenhouse gas emissions from sources your organisation owns or directly controls. These are the emissions your operations physically produce.

Examples: Burning natural gas for heating, diesel in company vehicles, refrigerant leaks from HVAC systems, process emissions from manufacturing, on-site fuel combustion.

→ AASB S2: Mandatory from Year 1. Location-based method. Must be disaggregated by GHG type.
Scope 2 - Indirect energy emissions

Emissions from purchased energy

Indirect GHG emissions from the generation of purchased electricity, steam, heating, or cooling that your organisation consumes. You don’t produce these emissions directly, but your energy demand causes them.

Examples: Electricity purchased from the grid to power offices, warehouses, or data centres. Steam purchased for industrial processes. Cooling supplied by a district system.

→ AASB S2: Mandatory from Year 1. Location-based method required. Market-based optional.
Scope 3 - Value chain emissions

Everything else

All other indirect emissions across your upstream and downstream value chain. Scope 3 typically represents 70–90% of a company’s total carbon footprint and is the most challenging to measure.

Examples: Purchased goods and services, business travel, employee commuting, transportation and distribution, use of sold products, waste disposal, leased assets, investments (financed emissions).

→ AASB S2: Mandatory from Year 2. Must assess all 15 GHG Protocol categories for materiality.

Why Scope 2 is the hardest part of AASB S2 for multi-site businesses

Scope 1 is straightforward - count your fuel and refrigerants. Scope 3 is deferred to Year 2. But Scope 2 emissions data - the electricity consumed across every site your organisation operates - is where the real operational pain lives, especially for multi-site businesses.

The multi-site data problem

Scattered data, no single source of truth

A franchise network with 150 locations across NSW, VIC, and QLD will have electricity contracts with multiple retailers, bills arriving in different formats, on different cycles, to different email addresses. A national hospitality chain or multi-site retail business faces the same complexity. For AASB S2, every kilowatt-hour needs to be captured, mapped to the correct NMI, and converted to CO₂-e using state-specific emission factors.

Common gaps: Bills buried in retailer portals, sites on different contract end dates, no NMI-level data export, inconsistent formats across AGL, Origin, and EnergyAustralia, manual spreadsheets that break at audit.

What audit-ready Scope 2 looks like

From electricity bills to assured emissions data

Your auditor needs a clear trail from raw electricity consumption (kWh per NMI) through to CO₂-e per site, using the location-based method with the correct NGA emission factors for each state grid. For multi-site businesses, that means centralising data from every retailer, validating it against actual bills, and producing a dataset that can withstand limited assurance in Year 1 and reasonable assurance from 2030.

Required outputs: Site-level kWh consumption, state grid emission factors applied, CO₂-e disaggregated by location, reconciliation to retailer invoices, documented methodology, auditor-ready data trail.

How to calculate your greenhouse gas emissions

Calculating GHG emissions for AASB S2 follows the GHG Protocol methodology. For most businesses, Scope 2 - your electricity and purchased energy - is the starting point and the area where data quality matters most. Here is the carbon accounting process, with particular attention to getting your energy data right.

1

Define your boundary

Operational control, financial control, or equity share. Must be consistent with your NGER approach where applicable.

2

Collect activity data

For Scope 2: electricity consumption (kWh) per NMI from every site and retailer. For Scope 1: fuel (litres, GJ), refrigerants. For Scope 3: procurement spend, travel, logistics.

3

Apply emission factors

For Scope 2: use state-specific NGA grid emission factors (different for NSW, VIC, QLD, SA, WA). For Scope 1: NGA fuel factors. For Scope 3: IPCC or supplier-specific factors.

4

Calculate CO₂-e

Aggregate all greenhouse gases into CO₂ equivalent using global warming potential values consistent with AASB S2 requirements.

What is AASB S2?

AASB S2 Climate-related Disclosures is Australia’s mandatory standard for climate-related financial disclosures, embedded in the Corporations Act 2001. It is part of the Australian Sustainability Reporting Standards (ASRS) and closely aligned with the global baseline set by IFRS S2, issued by the International Sustainability Standards Board. Built on the TCFD framework, it requires in-scope entities to prepare an annual sustainability report disclosing climate-related risks and opportunities - including greenhouse gas emissions, scenario analysis, climate governance, and transition plans. Non-compliance carries civil penalties and director liability under the Corporations Act. Entities must meet at least two of three size thresholds (revenue, assets, employees) or qualify via NGER reporting or asset ownership criteria. For multi-site businesses, the Scope 2 data challenge is particularly acute - consolidating electricity data from dozens or hundreds of locations, across multiple retailers and states, into audit-ready emissions figures.

The four pillars of AASB S2

Climate-related disclosures under AASB S2 are structured around four pillars, aligned with the TCFD framework. All four must be addressed in your sustainability report, lodged with ASIC.

🏛

Climate Governance

Board and management oversight, directors’ duties, controls, and procedures for monitoring climate-related risks and opportunities.

🧭

Climate Strategy

Material climate risks, scenario analysis under 1.5°C and >2°C pathways, financial effects, and transition plans aligned with net zero targets.

🛡

Risk Management

How climate risks are identified, assessed, prioritised, and integrated into your enterprise risk management framework.

📊

Metrics & Targets

Scope 1 & 2 GHG emissions (Year 1), material Scope 3 (Year 2), carbon accounting methodology, emission factors, climate targets, and capital deployed. For multi-site businesses, this means centralising energy data across all locations and retailers.

Reporting timeline for all three groups

Mandatory climate reporting under AASB S2 is phased across three groups. Each group follows the same assurance pathway once reporting begins.

Group 1

Live now
1 Jan 2025
First reporting period begins
Jun 2026
First FY ends (Jul–Jun entities)
Sep–Oct 2026
First sustainability report due
Year 2
Scope 3 mandatory
Jul 2030
Reasonable assurance

Group 2

Months away
Now
Preparation window
1 Jul 2026
First reporting period begins
H1 2028
First sustainability report due
Year 2
Scope 3 mandatory
Jul 2030
Reasonable assurance

Group 3

Preparing
Now
Assess materiality
1 Jul 2027
First reporting period begins
H1 2029
First sustainability report due
Year 2
Scope 3 mandatory
Jul 2030
Reasonable assurance

Frequently asked questions

What are Scope 1, 2 and 3 emissions?
Scope 1 emissions are direct greenhouse gas (GHG) emissions from sources your organisation owns or controls, such as fuel combustion and company vehicles. Scope 2 emissions are indirect emissions from purchased electricity, heat, steam, or cooling. Scope 3 emissions cover all other indirect emissions across your value chain, including suppliers, business travel, and the use of your products. Under AASB S2, Scope 1 and 2 must be reported from Year 1, with Scope 3 mandatory from Year 2.
What is the difference between Scope 1, Scope 2 and Scope 3?
Scope 1 covers direct emissions you generate (e.g. burning fuel on-site). Scope 2 covers indirect emissions from energy you purchase (e.g. electricity from the grid). Scope 3 covers everything else in your value chain - upstream (suppliers, purchased goods) and downstream (product use, end-of-life). Scope 3 typically represents 70–90% of a company's total carbon footprint but is the hardest to measure.
How do I calculate my greenhouse gas emissions for AASB S2?
You need to collect activity data (e.g. fuel consumed, electricity used), select appropriate emission factors (such as the Australian National Greenhouse Accounts factors), and calculate emissions in CO2-equivalent (CO2-e) using global warming potential values. The GHG Protocol Corporate Standard provides the most widely accepted methodology. AASB S2 requires the location-based method for Scope 2 as a minimum.
What is AASB S2 and when does mandatory climate reporting begin?
AASB S2 Climate-related Disclosures is Australia's mandatory standard for climate-related financial disclosures, part of the Australian Sustainability Reporting Standards (ASRS). It is aligned with IFRS S2 and built on the TCFD framework. Reporting began for Group 1 entities from 1 January 2025, with Group 2 from 1 July 2026 and Group 3 from 1 July 2027.
What is the GHG Protocol and how does it relate to AASB S2?
The GHG Protocol is the world's most widely used greenhouse gas accounting framework. It defines the Scope 1, 2, and 3 categories that AASB S2 uses for emissions reporting. AASB S2 requires entities to consider the 15 Scope 3 categories defined in the GHG Protocol Corporate Value Chain Standard when determining which emissions are material.
What are emission factors and which ones should I use in Australia?
Emission factors convert activity data (e.g. litres of fuel, kWh of electricity) into greenhouse gas emissions. In Australia, the Clean Energy Regulator publishes the National Greenhouse Accounts (NGA) Factors, which are the standard reference for carbon accounting under both NGER and AASB S2. You may also use IPCC factors where NGA factors are unavailable.
Is AASB S2 the same as IFRS S2?
AASB S2 is closely aligned with IFRS S2 but includes Australian-specific modifications. Key differences include: AASB S2 functions as a standalone standard (incorporating relevant AASB S1 provisions), scenario analysis must include 1.5°C and >2°C pathways specifically, and the phased implementation timeline is set by the Corporations Act 2001 rather than the ISSB.
What are the penalties for non-compliance with AASB S2?
Non-compliance carries civil penalties mirroring financial reporting breaches under the Corporations Act. This includes director liability for misleading disclosures. For the first 3 years, private enforcement for Scope 3, scenario analysis, and transition plan disclosures is limited to ASIC-only action. Scope 1 and 2, governance, and risk management disclosures have no such protection.

How Termina helps with AASB S2 Scope 2 reporting

Getting audit-ready Scope 2 emissions data shouldn't mean months of chasing retailer portals and wrangling spreadsheets. Termina aggregates electricity data across all your sites and retailers into a single platform - giving you NMI-level consumption data, automated emission factor application, and a clean audit trail for AASB S2 disclosure. Whether you're a franchise group, hospitality chain, multi-site retailer, or any business managing energy across multiple locations, Termina turns scattered electricity bills into assured Scope 2 emissions figures.

Talk to us about your Scope 2 data →