What 20 Australian Finance Leaders Told Us About Mandatory Climate Reporting

Updated:
March 2026

What do the experts think...

Trace recently hosted a breakfast bringing together 20 CFOs, Chief Risk Officers, Compliance leaders and Heads of Sustainability to talk openly about how their organisations are approaching mandatory climate reporting under AASB S2.

The conversation was candid. These were not organisations at the start of their awareness journey. Most had a reasonable grasp of what ASRS requires. Many had already begun some form of preparation. The question on the table was less "what is this?" and more "are we doing this right?"

The consistent theme that emerged across the room: strong momentum, but limited clarity on what "good" looks like in Year One.

That gap between intent and confidence is worth examining. Below are the eight themes that came through most clearly.

Cost, urgency and the mandate

1. Cost discipline is the starting point for everyone

Regardless of whether organisations were Group 1, 2, or 3 reporters, cost was the first thing that came up. Not because people were looking for shortcuts, but because the numbers they had heard, from consultants, from peers, from the press, ranged so widely that nobody felt confident anchoring a budget.

The organisations that felt most in control were those that had done scoping work early: understanding what was genuinely required before engaging vendors or committing to platforms. Those that hadn't done that work yet felt exposed, not because they were behind on delivery, but because they couldn't yet answer their own board's question about what this would cost.

Cost confidence, it turns out, does not come from a cheaper solution. It comes from a clearer scope.

2. Reporting is mandatory, and delay only reduces optionality

There is still some uncertainty in the market about enforcement timelines and how quickly non-compliance will be tested. That uncertainty occasionally surfaces as a reason to wait. The room was largely past that framing.

The direction of travel is clear and the legal obligations are real. What delay actually does is compress the time available for deliberate decisions. Organisations that start early get to choose their approach. Organisations that start late get to manage their constraints.

The leaders in the room who had started preparation earliest were not necessarily further ahead on delivery. They were making better decisions with less stress, which is a different and arguably more valuable form of progress.

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Governance, boards and the business case

3. The business case needs to be broader than risk alone

Several people in the room flagged the same challenge: framing ASRS disclosure as a risk management exercise was not landing well with boards or executive teams. Risk is real, but it is not the language that moves people to act.

The cases that were gaining traction internally connected disclosure to things boards already care about: access to capital, customer and revenue protection, competitive positioning relative to peers who are already disclosing, and long-term resilience as regulatory expectations continue to evolve internationally.

Framing climate disclosure as a risk exercise invites the question of whether the risk is material enough to justify the cost. Framing it as a strategic capability question is harder to defer.

4. Boards and executives must understand what they are signing off on

ASRS disclosures carry legal accountability. Directors and senior executives are signing off on statements that will be scrutinised by auditors, regulators and investors. And yet, across the room, there was consistent recognition that board and ELT understanding of what they are actually signing was still developing.

This is not a criticism. AASB S2 is genuinely complex, and the governance and financial integration requirements go well beyond what most boards have previously been asked to consider in a sustainability context.

The organisations that had invested in structured board education early, not just updates, but genuine working sessions on what the standard requires, were finding sign-off conversations significantly easier. The organisations that hadn't done that work yet were anticipating it as a risk closer to reporting deadlines.

Finance, technology and AI

5. Finance has a central role, even where ESG teams exist

Even in organisations with a dedicated ESG or sustainability function, finance was deeply involved in ASRS preparation. The standard requires integration with financial statements, assurance over disclosure, and governance sign-off at board level. None of those sit comfortably outside finance.

In organisations without an ESG team, finance was carrying the workload almost entirely. Either way, the learning curve is steep and the upskilling requirement is real. Several attendees described ASRS as the moment finance was being asked to take genuine ownership of something it had previously observed from a distance.

The opportunity in that is significant. Finance functions that navigate this well will have a more strategic role in their organisations than they did before. The ones that resist it will find it arrives on their desk anyway, but with less preparation time.

6. AI is widely accepted, but not without human judgement

There was strong openness in the room to using AI to streamline processes, reduce manual effort in data gathering, and improve the consistency of disclosure outputs. Nobody pushed back on the idea of AI playing a role.

The caveat that came up repeatedly was the need for experienced oversight. Climate disclosure is not a context where outputs can go unreviewed. The regulatory expectations, the assurance requirements, and the legal accountability mean that AI works best when it is paired with human judgement that can assess whether outputs are reasonable, defensible, and consistent with the organisation's actual position.

7. Automation creates value, but maturity will be incremental

Automating the processing of financial and operational data is already delivering real efficiency gains for organisations that have invested in it. Connecting data flows at source, so that emissions and climate-related financial data flows directly into reporting systems rather than being assembled manually each period, represents an even greater opportunity.

Most organisations in the room expected to build toward that level of maturity over multiple reporting cycles rather than achieve it in Year One. That is a realistic and sensible position. The key is building the foundations now, in a way that makes automation genuinely possible later rather than treating Year One as a standalone exercise.

Scope 3 and the precision trap

Despite growing familiarity with the standard overall, Scope 3 remains the area where uncertainty is highest and anxiety is most visible. The core challenges are not changing: data availability from suppliers and value chain partners, methodological choices that affect comparability, and the tension between completeness and what is actually achievable in early years.

What the room surfaced was a specific pattern worth naming: many organisations are assuming a level of precision for Scope 3 that is not actually required in Year One. The standard requires disclosure of material Scope 3 categories with appropriate explanation of methodology and limitations. It does not require a complete, audited footprint from day one.

Understanding that proportionality is permissible, and is actually what the standard expects, can meaningfully reduce the perceived scale of Scope 3 work without reducing the credibility of the disclosure.

What this adds up to

The organisations in the room were not struggling with awareness or intent. They were struggling with confidence: confidence in their scope, confidence in their board conversations, confidence that what they were building would be seen as credible by auditors and regulators.

That confidence does not come from spending more. It comes from starting with clarity about what is genuinely required and building from there with a structured, proportionate approach.

If your organisation is working through any of these challenges, we would be glad to help.

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