Climate change is recognised internationally as presenting material risks to the global financial system. These risks need to be managed by capital markets, regulators and corporations. They include physical risks of climate change and the transition risks associated with policy, regulatory and technological change brought on by efforts to mitigate climate change.
The Australian Government sought views on the proposed position of the detailed implementation and sequencing of standardised, internationally-aligned requirements for disclosing climate-related financial risks and opportunities standards issued by the International Stainability Standards Board (ISSB) in Australia from 27 June to 21 July 2023. The consultation built on the previous discovery consultation, which occurred from 12 December 2022 to 17 February 2023.
| Group | Timing | Meets two or more of these thresholds | Meets the NGER publication threshold |
| 1 | 2024-25
onwards | - More than 500 employees
- Consolidated gross assets of more than $1 billion
- Consolidated revenue of more than $500 million
| Yes |
| 2 | 2026-27
onwards | - More than 500 employees
- Consolidated gross assets of more than $1 billion
- Consolidated revenue of more than $500 million
| Yes |
| 3 | 2027-28
onwards | - More than 100 employees
- Consolidated gross assets of more than
$25 million - Consolidated revenue of more than $50 million
| Not applicable |
The Australian Government has issued a proposed roadmap for mandatory disclosure requirements under Chapter 2M of the Corporations Act, for entities which fulfill two of the three thresholds and which are ‘controlling corporations’ under the National Greenhouse and Energy Reporting (NGER) Act. (left) National Greenhouse and Energy Reporting (NGER) Entities would be phased in based on the publication threshold, which determines whether the Clean Energy Regulator (CER) publishes emissions data about reporters. The thresholds are:
- Controlling corporation threshold: Data is published if corporate totals have combined scope 1 and scope 2 greenhouse gas emissions equal to or greater than 50 kilotonnes carbon dioxide equivalence (CO2-e).
- Reporting transfer certificate holder threshold: Data ispublished if a facility has greenhouse gas emissions of 25 kilotonnes CO2-e or more; or production of energy of 100 terajoules or more; or consumption of energy of 100 terajoules or more.
The Australian Government is proposing climate-related financial disclosure requirements would be drafted as civil penalty provisions in the Corporations Act.
The application of misleading and deceptive conduct provisions to scope three emissions and forward-looking statements would be limited to regulator-only actions for a fixed
period of three years.
Continuous disclosure obligations would apply as they do presently, requiring entities to make timely and accurate disclosures.
Please reach out to your local PKF Audit & Assurance office for further insights of the reporting and assurance requirements of the climate-related financial disclosure.
