Australian Sustainability Reporting Standards (ASRS) – Where Do You Start?
- Patrick Ilott
- Sep 17
- 3 min read
Updated: Sep 18
The Australian Sustainability Reporting Standards (ASRS) will reshape the way companies disclose climate-related financial risks and opportunities. Aligned with the International Sustainability Standards Board’s IFRS S1 and S2, the new regime introduces a consistent, investor-focused framework for sustainability and climate disclosures.
For many organisations, the challenge isn’t whether to act... It’s knowing where to start. The breadth of ASRS requirements can feel overwhelming, and the temptation is to try to tackle everything at once. But jumping straight to drafting disclosures without a comprehensive GHG emissions inventory can quickly lead to:
Incomplete or unreliable data
An inability to understand your impact, and therefore your risks and opportunities
Inadequate disclosure of your climate-related financial risks
A failure to robustly address directors’ duties
The Best Starting Point? Your Inventory
The most effective first step is to go back to basics: take stock of what you know, and don’t know, about your GHG emissions.
Most organisations already hold some GHG emissions data, but it’s not always clear if that data is sufficiently comprehensive or aligned with best practice. An independent, data-led review of your inventory against the GHG Protocol and ISO standards is a logical starting point. It identifies significant gaps, highlights reasonable ways to address them, and ensures you understand your current impact before moving into risk assessment, target setting, or emissions reduction planning.
A structured review of your data, systems, and governance will anchor your ASRS journey. This means mapping:
Organisational boundaries – ensuring your emissions inventory aligns with your financial reporting boundaries.
Emissions boundaries – determining which GHG scopes, categories, and activities should be included. What activity data and emission factors do you already use? Are these applied consistently?
Accounting methodologies – assessing whether your chosen methods are reasonable, practical, and comparable. Are you using the most accurate data sources available?
Gap analysis – uncovering blind spots such as wholly-owned subsidiaries left out, major Scope 3 categories (like purchased goods and services) missing, unaccounted facilities, or reliance on sweeping assumptions.
Recommendations – setting out clear, prioritised actions to resolve gaps. This builds stronger systems for next year’s inventory, supports credible target-setting, and gives directors a transparent picture of where you stand.
Why Your Inventory Matters within the Australian Sustainability Reporting Standards
ASRS is designed to give investors and regulators confidence in the credibility of disclosures. The standards emphasise:
Governance – clear board and management oversight of sustainability risks.
Risk management – transparent processes for identifying and managing climate-related risks.
Metrics and targets – consistent, comparable data on emissions, strategy, and financial impacts.
This is especially critical if you’re an emissions-intensive business. Regulators, investors, and the public will scrutinise your disclosures more closely, with an expectation that you not only report comprehensively but also demonstrate credible plans for transition. A weak or incomplete inventory will undermine your ability to meet these legal and market expectations.
Crawl Before You Run
Based on international experience with IFRS-aligned standards, organisations that rushed straight to disclosure often faced qualified reports, regulatory scrutiny, and costly rework. Those that slowed down to establish a robust baseline achieved smoother, more efficient reporting journeys.
Think of it as a crawl-walk-run approach:
Inventory – catalogue your current GHG emissions across relevant scopes, categories, and activities.
Gap analysis – identify missing or inadequate data and methods.
Recommendations – design a phased approach to compliance that resolves gaps, builds stronger systems for future inventories, enables realistic targets, and equips directors with the clarity they need.
Final Thought
ASRS compliance doesn’t need to be overwhelming. By starting with a clear-eyed review of your GHG emissions inventory, you can avoid ballooning costs, late disclosures, and reputational risks, while building trust with investors, regulators, and stakeholders.
If you’re unsure how ready your organisation is, especially if you’re an emissions-intensive business, now is the time to take stock. Get in touch with us to map your current inventory, identify your gaps, and develop a practical roadmap to ASRS compliance.
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