Australia's ASIC Issues Regulatory Guide 280 for Mandatory Climate Reporting

Australia's ASIC released Regulatory Guide 280 to guide companies disclosing climate-related financial risks under the September 2024 Treasury Laws Amendment Act. The phased mandatory regime, requiring Scope 3 emissions disclosure, mirrors the global reporting trend shaping India's BRSR and value-chain requirements.

The Australian Securities & Investments Commission (ASIC) released Regulatory Guide 280 (RG 280), a blueprint for companies disclosing climate-related financial risks under Australia's mandatory sustainability reporting law passed in September 2024 under the Treasury Laws Amendment Act. Companies must disclose greenhouse gas emissions across the value chain, including Scope 3 emissions from suppliers and customers, plus exposure to climate-related risks. The largest corporations begin reporting in 2025, medium-sized firms in 2026, and smaller ones in 2027, applying to public and large proprietary companies with audited financial statements.

The rules phase in by thresholds: 2025 captures companies with 500+ employees, $500 million+ revenue or $1 billion+ assets; 2026 adds those with 250+ employees, $200 million+ revenue or $500 million+ assets; 2027 covers firms with 100+ employees, $50 million+ revenue or $25 million+ assets. ASIC has adopted a 'pragmatic and proportionate' approach, engaging directly with companies to correct misleading information, granting relief under certain conditions, and prioritising enforcement against reckless or intentional violations rather than honest mistakes.

Companies should act now to prepare for compliance by investing in better data tracking, aligning with international standards, and ensuring sustainability reports withstand scrutiny, particularly on Scope 3 emissions that require tracking carbon output beyond direct operations. ASIC's final guide, updated following industry feedback, adds sections on climate scenario analysis and Scope 3 reporting plus clearer instructions for directors overseeing disclosures. Firms should map their reporting start date to the phased thresholds beginning 2025 and prepare directors for oversight obligations.

Key figure — First reporting tranche (2025): companies with 500+ employees or $1 billion+ assets