Who must prepare a sustainability report?

This page contains information on:

Thresholds for preparing a sustainability report
Exempt entities

Thresholds for preparing a sustainability report

Section 292A of the Corporations Act requires the following entities to prepare a sustainability report for a financial year, if they also prepare a financial report for the financial year:

Large entities: Entities which meet two of the relevant thresholds for consolidated revenue, value of consolidated assets and/or number of employees;
NGER reporters: Entities with reporting obligations under the National Greenhouse and Energy Reporting (NGER) scheme; or
Asset owners: Registrable superannuation entities (RSEs), registered schemes, and retail corporate collective investment vehicles (CCIVs) which meet relevant thresholds

Sustainability reporting requirements will commence for the financial year commencing on or after 1 January 2025, with reporting entities separated into three groups and their obligations phased in over a period of three years as set out in the table below.

Reporting entities	Group 1 First annual reporting periods starting on or after 1 Jan 2025	Group 2 First annual reporting periods starting on or after 1 Jul 2026	Group 3 First annual reporting periods starting on or after 1 Jul 2027
Large entities and their controlled entities meeting at least two of three criteria	Consolidated revenue: $500 million or more EOFY consolidated gross assets: $1 billion or more EOFY employees: 500 or more	Consolidated revenue: $200 million or more EOFY consolidated gross assets: $500 million or more EOFY employees: 250 or more	Consolidated revenue: $50 million or more EOFY consolidated gross assets: $25 million or more EOFY employees: 100 or more
National Greenhouse and Energy Reporting (NGER) Reporters	Above NGER publication threshold in s 13(1)(a) of the NGER Act 2007	All other NGER reporters	N/A
Asset Owners (registered schemes, RSEs and retail CCIVs)	N/A	$5 billion assets under management or more	N/A

General threshold

Entities that are required to prepare a financial report under Ch 2M of the Corporations Act (for example, because they are a disclosing entity, public company or large proprietary company) are generally required to prepare a sustainability report if they meet at least two of the following three criteria:

the consolidated revenue of the entity (and the entities it controls) is $50 million or more;
the value of the consolidated gross assets of the entity (and the entities it controls) at the end of the financial year (EOFY) is $25 million or more;
the number of employees of the entity (and the entities it controls) at the end of the financial year is 100 or more.

Phasing-in of obligations

For large entities, the obligation to prepare a sustainability report is phased in over three years, based on the size of the entity (and any entities it controls) as set out in the table below:

Financial year commencing	Sustainability reporting thresholds for large entities (including controlled entities)
From 1 January 2025 to 30 June 2026	Entities must report if they are not a registered scheme, RSE or retail CCIV, and meet at least two of the following three criteria: consolidated revenue of $500 million or more; EOFY consolidated gross assets of $1 billion or more; EOFY employees of 500 or more.
From 1 July 2026 to 30 June 2027	Entities must report if they meet at least two of the following three criteria: consolidated revenue of $200 million or more; EOFY consolidated gross assets of $500 million or more; EOFY employees of 250 or more.
On or After 1 July 2027	Entities must report if they meet at least two of the following three criteria: consolidated revenue of $50 million or more; EOFY consolidated gross assets of $25 million or more; EOFY employees of 100 or more.

General obligation

Entities that are required to prepare a financial report under Ch 2M of the Corporations Act and are a registered corporation under the National Greenhouse and Energy Reporting Act 2007 (NGER Act) at the end of the financial year, or required to make an application to be registered under s12(1) of the NGER Act in relation to that financial year, are generally required to prepare a sustainability report.

NGER reporters are required to prepare sustainability reports even if they do not meet the size thresholds that apply to other entities.

Phasing-in of obligations

For NGER reporters, the obligation to prepare a sustainability report is phased in over two years, as set out in the table below:

Financial years commencing	Sustainability reporting criteria
From 1 January 2025 to 30 June 2026	Entities must report if they: are a registered corporation under the NGER Act at the end of the financial year; or are required to apply to be registered under the NGER Act in relation to the financial year; and meet the publication threshold in s13(1)(a) of the NGER Act, i.e., total greenhouse gases (GHGs) emitted from the operation of facilities under the operational control of the registered corporation or its relevant subsidiaries under s8(3) of the NGER Act (the corporate group) has a carbon dioxide equivalence (CO2-e) of 50 kilotonnes or more (scope 1 and scope 2 emissions).
On or after 1 July 2026	Entities must report if they: are a registered corporation under the NGER Act at the end of the financial year; or are required to apply to be registered under the NGER Act in relation to the financial year. An entity must apply to be registered under the NGER Act if the entity, together with its relevant subsidiaries under s8(3) of the NGER Act (the corporate group), meets one or more of the following thresholds in s13 of the NGER Act: total GHGs emitted from the operation of facilities under the operational control of the corporate group is 50 kilotonnes CO2-e or more (scope 1 and scope 2 emissions); total energy produced or consumed from the operation of facilities under the operational control of the corporate group is 200 terajoules or more; or a member of the corporate group has operational control of a facility, the operation of which during the year causes: emission of GHGs of 25 kilotonnes CO2-e or more (scope 1 and scope 2 emissions); or production or consumption of energy of 100 terajoules or more.

Financial years commencing

Sustainability reporting criteria

From 1 January 2025 to 30 June 2026

Entities must report if they:

are a registered corporation under the NGER Act at the end of the financial year; or
are required to apply to be registered under the NGER Act in relation to the financial year; and
meet the publication threshold in s13(1)(a) of the NGER Act, i.e., total greenhouse gases (GHGs) emitted from the operation of facilities under the operational control of the registered corporation or its relevant subsidiaries under s8(3) of the NGER Act (the corporate group) has a carbon dioxide equivalence (CO2-e) of 50 kilotonnes or more (scope 1 and scope 2 emissions).

On or after 1 July 2026

Entities must report if they:

are a registered corporation under the NGER Act at the end of the financial year; or
are required to apply to be registered under the NGER Act in relation to the financial year.

An entity must apply to be registered under the NGER Act if the entity, together with its relevant subsidiaries under s8(3) of the NGER Act (the corporate group), meets one or more of the following thresholds in s13 of the NGER Act:

total GHGs emitted from the operation of facilities under the operational control of the corporate group is 50 kilotonnes CO2-e or more (scope 1 and scope 2 emissions);
total energy produced or consumed from the operation of facilities under the operational control of the corporate group is 200 terajoules or more; or
a member of the corporate group has operational control of a facility, the operation of which during the year causes:
- emission of GHGs of 25 kilotonnes CO2-e or more (scope 1 and scope 2 emissions); or
- production or consumption of energy of 100 terajoules or more.

General thresholds

Asset owners that are RSEs, registered schemes and retail CCIVs and are required to prepare a financial report under Ch 2M of the Corporations Act, are generally required to prepare a sustainability report if:

the value of their assets at the end of their financial year (EOFY), including the assets of any entities they control, is $5 billion or more; or
they meet the general reporting thresholds for large entities.

For retail CCIVs, the $5 billion threshold applies to the whole CCIV (that is, the sum of all assets under management in all sub-funds).

Reporting requirements under Ch 2M generally apply to retail CCIVs in respect of each sub-fund. Thus, if a retail CCIV is subject to the sustainability reporting regime, it must prepare a sustainability report for each sub-fund. For general information about CCIVs, see: Corporate collective investment vehicles | ASIC

Asset owners that are not an RSEs, registered scheme or retail CCIVs should refer to the general reporting thresholds for large entities.

Phasing-in of obligations for asset owners that are RSEs, registered schemes and retail CCIVs

For asset owners that are RSEs, registered schemes and retail CCIVs, the obligation to prepare a sustainability report is phased in over two years, as set out in the table below:

Financial years commencing	Sustainability reporting thresholds for asset owners that are RSEs, registered schemes and retail CCIVs (including controlled entities)
From 1 July 2026 to 30 June 2027	Asset owners must report if: the value of their EOFY assets is $5 billion or more; or they meet at least two of the following three criteria: consolidated revenue of $200 million or more; EOFY consolidated gross assets of $500 million or more; EOFY employees of 250 or more.
On or after 1 July 2027	Asset owners must report if: the value of their EOFY assets is $5 billion or more; or they meet at least two of the following three criteria: consolidated revenue of $50 million or more; EOFY consolidated gross assets of $25 million or more; EOFY employees of 100 or more.

Financial years commencing

Sustainability reporting thresholds for asset owners that are RSEs, registered schemes and retail CCIVs (including controlled entities)

From 1 July 2026 to 30 June 2027

Asset owners must report if:

the value of their EOFY assets is $5 billion or more; or
they meet at least two of the following three criteria:
- consolidated revenue of $200 million or more;
- EOFY consolidated gross assets of $500 million or more;
- EOFY employees of 250 or more.

On or after 1 July 2027

Asset owners must report if:

the value of their EOFY assets is $5 billion or more; or
they meet at least two of the following three criteria:
- consolidated revenue of $50 million or more;
- EOFY consolidated gross assets of $25 million or more;
- EOFY employees of 100 or more.

Exempt entities

In general, entities that are not required to prepare annual financial reports under Ch 2M are also not required to prepare a sustainability report.

Entities are also exempt if:

they are a small or medium sized entity which falls below the relevant size thresholds in s292A of the Corporations Act and are not an NGER reporter; or
they are registered with the Australian Charities and Not-for-profits Commission.

Who must prepare a sustainability report?

Thresholds for preparing a sustainability report

Large entities

General threshold

Phasing-in of obligations

NGER reporters

General obligation

Phasing-in of obligations

Asset owners

General thresholds

Phasing-in of obligations for asset owners that are RSEs, registered schemes and retail CCIVs

Exempt entities