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ASRS Group 3: are you in scope and don’t know it?

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Correct as at 13 September 2026. 

If your company is a large proprietary company, you may be legally required to report under Australia’s mandatory climate reporting rules from 1 July 2027 even if you have never reported emissions before. ASRSAustralian Sustainability Reporting Standards (ASRS) - Australia's mandatory climate-related financial reporting rules started on 1 January 2025 and are being phased in across three reporting groups. Group 3 captures companies on size and corporate reporting status, not emissions intensity. That is why so many businesses in scope do not think of themselves as carbon reporters. 

The Australian Sustainability Reporting Standards (ASRS) Group 3 threshold is about size, not emissions 

You are likely in Group 3 if your company has a Chapter 2M financial reporting obligation and meets at least two of these three thresholds: 

Nothing in that list mentions emissions. A distribution business, a professional services firm and a food manufacturer can each be captured on revenue and headcount alone, which is why the first companies to find out are often the ones who assumed the rules were aimed at someone else. 

The thresholds may rise, but don’t plan on it yet 

In the 2026–27 Budget the Government announced it would lift the monetary thresholds used to decide whether a proprietary company is large. Revenue would move from $50 million to $100 million and gross assets from $25 million to $50 million. The 100-employee test is expected to stay as it is. 

Treasury released a consultation paper on 24 August 2026 seeking feedback on this and other efficiency reforms, with submissions closing on 2 October 2026. Two points matter for your planning. Treasury has not confirmed when any threshold change would commence, and it has said the changes under consideration will not affect entities reporting for the 2026–27 financial year. 

If you sit between the current and the proposed thresholds, you are in an awkward spot: possibly captured, possibly relieved, with no date either way. Keep preparing until the change is legislated and its start date is known. 

Reporting starts 1 July 2027, but the work starts well before 

Group 3 reporting applies to annual reporting periods beginning on or after 1 July 2027. For a June-year company that means the year to 30 June 2028. 

That sounds comfortable until you look at what sits behind the report. You may need to collect emissions data across sites and fuels, confirm your reporting boundaries, assign internal responsibilities, document your assumptions and set up board-level governance most of it before the reporting period opens, because the first year’s data has to come from somewhere. Companies that wait end up building the system and producing the report at the same time. 

Being in scope doesn’t always mean full disclosure 

This is the part most Group 3 articles leave out. Under section 296B of the Corporations Act, a Group 3 entity that is not an NGERNational Greenhouse and Energy Reporting Scheme. Large energy users and greenhouse gas emitters that exceed the thresholds must report their detailed energy and emissions data each year to the Australian Clean Energy Regulator. More reporter and concludes it has no material climate-related financial risks or opportunities can lodge a statement saying so, rather than a full set of AASB S2 climate statements. 

That is not a way out. You still have to run the materiality assessment, hold the evidence behind the conclusion and have your directors declare it. It does change the size of the job, though, and it is worth knowing before you commission a reporting program you may not need. 

AASB S2 asks for more than a carbon footprint 

AASB S2 Climate-related Disclosures is the standard behind the regime. It covers four areas: 

The Australian version adds requirements beyond the international standard, including scenario analysis and disclosure of the financial effects. For most companies the hard part is not the writing. It is getting the data, the assumptions and the evidence trail into shape before the first period opens. 

A scope check should answer seven questions 

Before you commission anything larger, get clear answers to these: 

For industrial companies the answer usually turns on site-level energy and emissions data. For mid-tier corporates it more often turns on whether finance and compliance can evidence the disclosures. 

Where companies get this wrong 

The most expensive mistake is treating ASRS as an ESG project. It sits with financial reporting, governance and compliance, and it needs input from finance, risk, operations and the people who understand your energy use, assets and supply chain. 

The other mistakes we see most often: 

Book a free 30-minute ASRS scope assessment 

Northmore Gordon helps Australian businesses work out whether ASRS applies to them and what to do next. In 30 minutes we will cover which group you are likely to fall into, how the proposed threshold changes affect your position, whether the section 296B relief is open to you, what data you already hold and what your next practical step is. 

For industrial and commercial sites we can also connect the reporting obligation to operational data – energy use, fuels, equipment, production activity and emissions sources so your first report rests on measured inputs rather than estimates. Get in touch below for a 30-minute assessment

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What are the three thresholds used to determine if a company is in ASRS Group 3?

A company is likely in ASRS Group 3 if it has a Chapter 2M financial reporting obligation and meets at least two of these three thresholds: consolidated revenue of $50 million or more, consolidated gross assets of $25 million or more, and 100 or more employees.

Is the ASRS Group 3 threshold based on emissions?

No. The Group 3 threshold is about size, not emissions. Nothing in the criteria mentions emissions, meaning a distribution business, professional services firm, or food manufacturer can be captured based solely on revenue and headcount.

When does ASRS Group 3 reporting start?

Group 3 reporting applies to annual reporting periods beginning on or after 1 July 2027. For a company with a June financial year, this means the year to 30 June 2028.

Are the ASRS Group 3 thresholds expected to change?

In the 2026–27 Budget, the Government announced it would lift the monetary thresholds for deciding whether a proprietary company is large: revenue would move from $50 million to $100 million and gross assets from $25 million to $50 million. The 100-employee test is expected to stay the same.

Has the threshold change been confirmed or finalised?

No. Treasury released a consultation paper on 24 August 2026 seeking feedback on this and other efficiency reforms, with submissions closing on 2 October 2026. Treasury has not confirmed when any threshold change would commence, and has said the changes under consideration will not affect entities reporting for the 2026–27 financial year.

What should a company do if it falls between the current and proposed thresholds?

According to the article, if a company sits between the current and proposed thresholds, it is in an awkward spot—possibly captured, possibly relieved, with no date either way—and should keep preparing until the change is legislated and its start date is known.

Can a Group 3 entity avoid full ASRS disclosure?

Under section 296B of the Corporations Act, a Group 3 entity that is not an NGER reporter and concludes it has no material climate-related financial risks or opportunities can lodge a statement saying so, rather than a full set of AASB S2 climate statements. However, this is not a way out entirely—the company still must run the materiality assessment, hold the evidence behind the conclusion, and have directors declare it.

What is NGER in the context of ASRS reporting?

NGER refers to the National Greenhouse and Energy Reporting Scheme, under which large energy users and greenhouse gas emitters that exceed certain thresholds must report their detailed energy and emissions data each year to the Australian Clean Energy Regulator.

What four areas does AASB S2 Climate-related Disclosures cover?

AASB S2 covers Governance (how the board and management oversee climate-related risks and opportunities), Strategy (how risks and opportunities could affect the business model, operations, financial position and plans), Risk management (how risks are identified, assessed and managed), and Metrics and targets (numbers including scope 1, scope 2, and scope 3 greenhouse gas emissions).

What extra requirements does the Australian version of the standard add beyond the international standard?

The Australian version of AASB S2 adds requirements beyond the international standard, including scenario analysis and disclosure of the financial effects of climate-related risks and opportunities.

What questions should a company answer before commissioning a full ASRS reporting program?

A scope check should answer: whether the company has a Chapter 2M financial reporting obligation; which ASRS group it likely falls into; whether consolidated revenue, assets or employee numbers meet current thresholds; whether its position would change under proposed thresholds; whether it is an NGER reporter and whether section 296B relief is open to it; what emissions and activity data it already holds and where the gaps are; and who needs to be involved (finance, operations, procurement, legal, risk, ESG or the board).

What is the most common mistake companies make regarding ASRS?

The most expensive mistake is treating ASRS as an ESG project. According to the article, it actually sits with financial reporting, governance and compliance, and needs input from finance, risk, operations and people who understand energy use, assets and supply chain.

What other common mistakes do companies make with ASRS Group 3 compliance?

Common mistakes include relying on outdated threshold numbers without checking proposed changes, assuming proposed relief will arrive in time to help, waiting until the first reporting year to start collecting emissions data, assuming scope 1 and scope 2 emissions are already complete and evidence-ready, underestimating the scope 3 data task, using unsupported assumptions without keeping records, and asking the board to declare disclosures without a clear evidence trail.

What does Northmore Gordon offer companies unsure about their ASRS obligations?

Northmore Gordon offers a free 30-minute ASRS scope assessment covering which group a company is likely to fall into, how proposed threshold changes affect its position, whether section 296B relief is open to it, what data it already holds, and what its next practical step is. For industrial and commercial sites, they can also connect the reporting obligation to operational data such as energy use, fuels, equipment, production activity and emissions sources.

Who wrote the article on ASRS Group 3 and when was it published?

The article was written by Craig Morgan and published on September 18, 2026, with content correct as at 13 September 2026.

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