HOW TO GET READY FOR ASRS - AUSTRALIA
STEP 4 SIMULATE SUCCESS
Given the complexity of the reporting scheme, it is wise to complete a ‘dry run’ ahead of your official lodgement date. For most groups, this will be 12 – 18 months prior to the reporting deadline, allowing time to adjust processes if needed. This should focus on the following: 1. Data coverage, accuracy and completeness, and the processes used to close off the reporting period. 2. How you analyse and quantify the risks and opportunities. 3. Whether you have an agreed procedure for sharing reporting information with senior leadership for sign-off. 4. Engaging with your auditor to ensure you understand what evidence and process documentation will be required.
ASRS reporting is no different from financial reporting, so you can include the same steps and timing considerations, such as alignment with Board meetings or input from external auditors.
Think about assurance Assurance for your data is expected to be a feature of the reporting requirements. This will begin with limited assurance for scope 1 and 2 emissions data from year one. The higher standard, known as reasonable assurance, will be mandatory from year four onwards, however, adopting this standard early on is recommended to provide deeper insight into your data coverage and more time to improve. Your ‘sustainability report’ must also be assured by your financial advisors to ensure the accuracy and reliability of disclosures.
Get board sign-off The report also requires both board approval and a directors’ declaration. Plan ahead, as Board and Director sign-off processes may take additional time, especially if these disclosures are new to your organisation. What happens if I don’t lodge? Given the regulatory requirement to lodge your sustainability report, penalties will apply for non-compliance. ASIC has a penalty
relief period which will be in effect during the transition period, from the commencement of the legislation in financial year 2026 through to 2028. At present, it is not known what penalties will be in place for non-compliance following this transition period.
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