Group 2 and running late? What matters now, and what can wait?

Your first reporting period under the Australian Sustainability Reporting Standards (ASRS) started on 1 July 2026, and for most Group 2 finance teams it's landed on an already full plate. This free guide shows what year one asks of you, a month-by-month plan to lodgement, and what can safely wait.

CFOsFinance DirectorsSustainability ManagersRisk & ComplianceBoard Members
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AASB Australia's Mandatory Climate Reporting

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“Trace’s AI capabilities have significantly streamlined our data collection and validation processes, reducing manual effort and giving us greater confidence .”

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" Starting early [with the Trace platform] meant we avoided the scramble - saving time, money, and a lot of stress"

HEAD OF ESG, PADDY PALLIN

See What’s Inside

What's inside

Each section picks up where the last one finishes. You'll get what AASB S2 Climate-related Disclosures requires in year one, a dated plan, resourcing options and Group 1's lessons.

Where you stand, in four checklists

Work through governance, strategy, risk management, and metrics and targets, ticking off what's already in place. Each checklist shows what your auditor will review in year one, so you can see which gaps matter most. Whatever's left unticked becomes your to-do list.

What can't wait, and what can

Catching up is mostly about getting the order right. Governance, your Scope 1 and 2 data and an early conversation with your auditor can't slip any further. Scope 3, comparatives and detailed scenario modelling can wait or stay light in year one, because that relief is built into the standard.

A month-by-month plan to lodgement

A timeline from November 2026 to lodgement shows when to start each of six steps for a 30 June year end. Flags mark the latest you can start each one without putting your deadline at risk. Listed companies can also see where a half-year review is likely to fall.

Three ways to resource the work

See how building in house, a hybrid model and fully outsourcing compare on your team's hours and the chance of rework at audit. In the hybrid model your team owns the data and decisions, with AI where it helps and experts where it matters. A one-minute check helps you work out how much support you need.

Key Findings

What the first reporters wish they'd known

Trace prepared first-year climate reports for Group 1 companies and worked alongside their auditors. The same lessons kept coming up, and most of them aren't in the official guidance.

Governance has to run all year

Auditors expect board oversight of climate to have operated during the reporting period, with written responsibilities, agendas and minutes behind it, and it can't be pieced together at year end. If your period started on 1 July, put oversight in writing now and get climate on every board agenda.

Evidence is a job in itself

Group 1 companies found evidence requests were much bigger than they'd planned for, and they arrived at the busiest time of year. Auditors told us every number and judgement needs a documented source, method and sign-off. Build that trail as the work happens and walk your auditor through a dry run before year end.

Choosing your risks is the hardest part

Teams found it hard to pick the right climate risks and explain why some were material and others weren't. Auditors often saw risks that weren't connected to financial consequences, with materiality calls left undocumented. Because the risk assessment feeds your metrics and financial disclosures, starting it late squeezes everything that follows.

More drafts mean more review rounds

Well-prepared reporters needed one or two drafts, while those who went it alone needed five or six, each triggering a full re-review. Unassured sections still drew comments, because auditors read the whole report against the financial statements. Getting structure and evidence right early is what keeps the rounds down.

Who This Is For

Written for the people
making ASRS decisions

This ebook is written at CFO grade, with enough detail to be genuinely useful to sustainability leads and risk teams. Not a primer. Not a sales deck.

CFOs & Finance Directors

Responsible for signing off on the disclosure. Needs to understand what auditors will scrutinise in year two, and where the financial integration gaps are in first-round disclosures.

Sustainability Managers & ESG Leads

Building the disclosure internally. Needs to understand what peers are doing on Scope 3, scenario analysis and materiality so the internal benchmark is calibrated correctly.

Risk & Compliance Teams

Needs to understand where governance documentation is falling short in first-round disclosures and what auditors are already flagging as areas for year-two improvement.

Board Members & Audit Committee

Accountable for climate risk oversight under AASB S2. Needs a clear picture of what comparable entities are disclosing and what the governance standard looks like in practice.

This ebook is particularly relevant if:

Your entity is likely to fall under ASRS Group 1, 2 or 3 (or you're not yet sure which group applies)

Your board or audit committee has asked about climate disclosure obligations for the first time

You're preparing a Group 2 first disclosure and want to learn from what Group 1 entities got right and wrong

You need to brief internal stakeholders on what AASB S2 actually requires versus what others are choosing to include

What Comes Next

From ebook to
compliant disclosure.

01

Download the ebook

Understand what first reporters did. Where they focused, where they struggled, and what auditors are already signalling for year two.

Get it now

02

Run your readiness assessment

Trace maps your current data, governance and reporting position against ASRS requirements. You get a clear picture of where you are and a prioritised gap list.

See how it works

03

Build your compliance roadmap

Trace turns your readiness assessment into a sequenced plan: what to do now, what to prepare for year two, and how to keep your board and audit committee informed throughout.

Book a call with our team

Questions we hear most from ASRS teams

These are the questions Trace’s team hears most often from CFOs and sustainability leads starting their ASRS journey. The full ebook answers all of them in depth.

What Group 2 finance teams are asking us
A: You're a Group 2 reporter if your financial year starts on or after 1 July 2026, you're not in Group 1, and you meet at least two of three group-level tests at year end: 250 or more employees, gross assets of $500 million or more, or revenue of $200 million or more. National Greenhouse and Energy Reporting (NGER) reporters not in Group 1 are also Group 2, as are asset owners such as super funds with $5 billion or more in assets. For a 30 June year end, the first period runs from 1 July 2026 to 30 June 2027.
Q: When is a Group 2 company's first climate report due?
A: It depends on your year end and what kind of entity you are. Under ASRS, disclosing entities (including listed companies), registered schemes and registrable superannuation entities lodge their sustainability report and auditor's report with ASIC within three months of year end. Other reporting entities have four months. For a 30 June 2027 year end, that's 30 September or 31 October 2027. If your year ends in December, your first period is calendar 2027 and the report is due in 2028. Either way, governance needs to be running from day one of the period, because auditors look at the whole year.
Q: What does a first-year climate report need to include?
A: Under AASB S2, your first climate report covers four areas. Governance explains who oversees climate risks and opportunities, and how. Strategy sets out the risks and opportunities that could affect your prospects, their effects on your business and finances, and your climate resilience, tested with scenario analysis that includes a 1.5°C scenario and a high-warming scenario. Risk management explains how you find and monitor those risks and opportunities. Metrics and targets covers Scope 1 and 2 emissions, the cross-industry metrics and any targets you've set or must meet. Scope 3 emissions and prior-year comparatives aren't needed in year one.
Q: Which parts of a Group 2 climate report get assured in year one?
A: In your first reporting year, limited assurance covers three areas: governance, the strategy disclosures on climate risks and opportunities, and Scope 1 and 2 emissions. Risk management, scenario analysis and the other metrics aren't assured in year one. Your auditor will still read the whole report for consistency with your financial statements and can question any claim in it. That's why it's worth meeting them early to agree scope, timing and the evidence they'll expect, so gaps turn up while you can still fix them.
Q: Is it too late for Group 2 to start climate reporting?
A: No, but the order you do things in matters. With a 30 June year end, your reporting period started on 1 July 2026, so governance comes first: assign climate oversight to the board or a committee in writing and minute it at every meeting. Collect Scope 1 and 2 data back to 1 July 2026 and test it early, so missing invoices, sites or meters show up while there's time to sort them out. Meet your auditor soon, and start your climate risk assessment early in 2027 so the later steps don't all land in the final months.
Q: Can Group 2 companies leave Scope 3 emissions until later?
A: Yes. Scope 3 emissions aren't required in your first reporting year, and you don't need prior-year comparatives either. Some businesses start collecting Scope 3 in year one to get ahead, while others use the year to work out their likely categories and data gaps before it becomes mandatory in year two. Scenario analysis is still required in year one, but it can be proportionate and mostly qualitative, as long as it's defensible and documented. The relief doesn't extend to governance gaps, late lodgement or misleading statements.

Want deeper answers? The ebook has entity benchmarks, worked examples and expert commentary.

Download the full ebook →

Your deadline is coming.
Start with the data.

Download the free ebook and see what Australia’s first AASB S2 reporters have already disclosed. Then talk to Trace about where you stand.

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