Waiting for the ASRS rollback? It's done. And if you're over $100m, you're still reporting.

For the last six months, a lot of finance and risk leaders have been quietly hoping that mandatory climate reporting would be walked back. New government, productivity agenda, a Federal Budget with "regulatory reform" stamped on the cover. Surely something would give.

Last week, something did. But it's probably less than you were waiting for.

Treasury proposed two changes that genuinely reduce ASRS scope and effort: the "large proprietary company" thresholds double, and the assurance regime gets recalibrated. Together, these are the so-called rollbacks.

If you sit above $100 million in consolidated revenue, the rollback has now happened and you didn't fall under it. The deadline holds. The standard holds. The clock has not moved.

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What actually changed

The Budget made two material concessions to the ASRS regime.

1. The thresholds doubled. Under the proposal, a proprietary company is treated as "large" if it meets at least two of the three tests below. Businesses that drop below the new tests no longer need to lodge an annual audited financial report, directors' report or sustainability report with ASIC.

ThresholdCurrentProposedConsolidated revenue$50 million$100 millionConsolidated gross assets$25 million$50 millionGroup employees100100 (no change)

2. Assurance is being recalibrated. Treasury has committed to "adjusting assurance settings to ensure they are proportionate and practical." That sits alongside two related signals in the same package: clearer guidance on the "undue cost or effort" exemption, and explicit limits on how much information reporting entities can demand from small business suppliers.

These are real concessions. They reduce cost. They reduce friction. They acknowledge that first-year disclosures should not be over-engineered.

But none of this is a delay. Group 1 is reporting now. Group 2 still reports from 1 July 2026. Group 3 still follows in 2027. No phasing has moved. Your group determines your reporting deadline, and the phasing has not been touched.

If you're under $100m: take the relief

The honest read on the new thresholds is that the Government has chosen to take a chunk of the mid-market out of mandatory ASRS scope. If your business sits between $50m and $100m in consolidated revenue, or below the gross asset test, you may now fall out entirely.

Most service providers are defending the change with a version of the same argument: "yes but your Group 1 customers will still ask you for Scope 3 data, so you still need to report." It's worth being honest about what that argument really is. It's vendor self-interest.

AASB S2 does not require supplier-level emissions data. Reporting entities are expected to disclose material Scope 3, but they are not entitled to demand granular figures from every supplier. The Budget has now explicitly told them to set clearer boundaries on what they can ask of small businesses.

If you're a $50m–$100m business, our straightforward advice is this: don't build a full ASRS apparatus on the assumption you'll be forced to. If a Group 1 customer asks for emissions data, give them what you have. If a lender asks, give them what you have. Build the carbon data you actually need for your business, your covenants and your largest customers. Don't build for an audit you no longer have to pass.

Voluntary reporting can make sense in specific situations: B Corp recertification, a tender requirement, an exposed property portfolio. But voluntary is the operative word. The Budget just made it one.

If you're over $100m: nothing has been pulled back for you

For the businesses still above the new threshold, and that is the majority of organisations preparing for ASRS, none of this is relief. You are still in scope. The deadline is fixed. And if you're in Group 2, you have months, not quarters.

What did change is the size of the apparatus you reasonably need to build. The assurance recalibration is real. The "undue cost or effort" clarification is real. Treasury is telling preparers, auditors and assurers that proportionality is the operating principle.

That is exactly the case for Minimum Viable Compliance. AASB S2 is built on proportionality and materiality. It does not reward gold-plated processes. It rewards disclosures that are reasonable, supportable and honest about where understanding is still developing.

For Group 2 entities specifically, three things matter this quarter.

• Your group determines your deadline. Confirm it in writing. The threshold change makes this worth re-checking, particularly for proprietary structures and holding companies sitting near the new limits.
• Scope Year One as MVC. Document the governance you already have. Right-size your climate risk assessment. Run scenario analysis against publicly available pathways. Cover material Scope 1, 2 and 3. Caveat what is still developing. That is what a credible Year One disclosure looks like.
• Don't wait for assurance settings to finalise. They will be proportionate. They will still require a defensible audit trail. The work that matters: clean data, clear methodology, traceable assumptions. That work is the same regardless of where the final assurance line lands.

The decision in front of most leaders this week

The Budget did not delay mandatory climate reporting. It clarified, slightly, who is on the bus and how much luggage they have to bring.

If you're under $100m revenue: get off the bus, and don't let anyone sell you a seat.

If you're over $100m: the destination hasn't moved. Keep it simple. Get going.

FAQ

Has the ASRS reporting deadline been delayed by the Federal Budget?No. The Budget did not change any group phasing dates. Group 1 is reporting now. Group 2 reports from 1 July 2026. Group 3 follows in 2027. The only changes were to the large proprietary company revenue and gross asset thresholds, and to the assurance settings.

What are the new ASRS large proprietary company thresholds?Under the proposed changes, a proprietary company is "large" if it meets two of three tests: consolidated revenue above $100 million (up from $50 million), consolidated gross assets above $50 million (up from $25 million), or 100 or more employees (unchanged). Businesses below the new tests no longer need to lodge ASRS reports with ASIC.

If my revenue is between $50m and $100m, do I still need to report under ASRS?Not under mandatory ASRS, if you fall below the new thresholds. You may still choose to report voluntarily, and some lenders or Group 1 customers may request emissions data, but you are not legally required to produce a full ASRS disclosure. Build what your business and key stakeholders actually need.

What does assurance recalibration mean for my ASRS disclosure?Treasury has committed to making assurance requirements more proportionate, particularly for early-year disclosures. The "undue cost or effort" exemption will be clarified. In practice, this means first-year disclosures should not be over-engineered, but you still need a defensible audit trail: clean data, traceable methodology, documented assumptions.

What is Minimum Viable Compliance for ASRS?Minimum Viable Compliance (MVC) is Trace's framework for building a credible, audit-ready Year One ASRS disclosure without unnecessary cost or complexity. It focuses on documenting existing governance, right-sizing climate risk assessments, and covering material Scope 1, 2 and 3 emissions, while being transparent about where methodology is still developing.

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How Trace can help

We work with finance and risk leaders across Group 1, 2 and 3 organisations to scope ASRS requirements and build a clear, audit-ready pathway through Year One, without unnecessary cost. If you're still in scope under the new thresholds and want to know what MVC looks like for your business, we'd be glad to walk you through it.

Book a free ASRS consultation

Trace is a climate reporting platform specialising in ISSB and AASB standards, helping businesses navigate mandatory climate disclosure with clarity and confidence.

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