Group 2 covers companies meeting two of three size tests, other NGER reporters and large asset owners, for financial years from 1 July 2026.
In short: You're in Group 2 if your company meets two of three tests (consolidated revenue of $200 million or more, gross assets of $500 million or more, 250 or more employees), is an NGER reporter not in Group 1, or is an asset owner with $5 billion or more under management. Group 2 reports for financial years starting on or after 1 July 2026, so for a July year start your first reporting period is already running. Our readiness checklist is free: 40+ items, sent to your inbox. Termina is an Australian and New Zealand business energy procurement company and energy data platform.
Meet at least two of the three size tests, or be an NGER reporter not in Group 1, or an asset owner with $5 billion or more under management. Group 2 entities report under Chapter 2M of the Corporations Act.
| Criteria | Group 2 threshold |
|---|---|
| Consolidated revenue | $200 million or more |
| Gross assets | $500 million or more |
| Employees | 250 or more |
| Size test | Meet at least two of the three above |
| Or | An NGER reporter not in Group 1 |
| Or | An asset owner with $5 billion or more in assets under management |
| First reporting period | Financial years starting on or after 1 July 2026 |
Compare all three groups in our mandatory climate reporting guide.
For financial years starting on or after 1 July 2026. The first report is due within 3 months (disclosing entities) or 4 months (other entities) of the end of the financial year, alongside the financial report, so the systems that produce it need to run through the whole first year.
Gap analysis, carbon accounting systems, board training and auditor engagement.
Scope 1 and 2 data collection starts for financial years starting on or after this date.
Lodged with ASIC alongside the financial report. 3 months for disclosing entities, 4 months for other entities.
Your auditor gives limited assurance over the first year's disclosures.
Material value chain emissions must be disclosed from your second reporting year.
Reasonable assurance across all climate-related financial disclosures.
Four pillars, aligned with the TCFD framework, in a sustainability report lodged with ASIC.
Board and management oversight of climate-related risks and opportunities: directors' duties, controls, skills and how often the board is told.
Material climate risks and opportunities, scenario analysis under 1.5°C and above 2°C pathways, the expected financial effects, and any transition plan.
How climate-related risks are identified, assessed, prioritised and built into your enterprise risk management.
Scope 1 and Scope 2 greenhouse gas emissions from year one, material Scope 3 from year two, your methodology and emission factors, climate targets and capital deployed.
From your electricity bills: kWh per NMI, per site and per billing period, converted to CO₂-e with the state grid factor and traceable back to each invoice. Termina builds that dataset for you, and your first 50 bills are free.
With 250 or more employees, your organisation likely spans multiple sites, states and electricity retailers. The time to consolidate energy data across all locations is before your first reporting period ends, not after. For franchise networks, hospitality groups, healthcare providers and multi-site retail chains, Scope 2 is the biggest operational lift: kWh from every NMI, across every retailer, mapped to state-specific emission factors. That isn't a one-month project.
Termina turns those bills into audit-ready emissions data for AASB S2 reporting. Upload your first bills to see the data today. Authorise us once and we update the billing contact with each retailer, so every bill after that comes straight to us. Nothing to install, and nothing about your supply or retailer changes.
Each bill is re-added against its own totals, tested against your contract where we hold it, and flagged where it needs review. Then it's structured by meter (NMI, MIRN or ICP), site and period, with the right factor applied to each fuel and the source bill behind every figure.
Your first 50 bills on the platform are free.
Roughly a year of monthly bills across four sites. Enough to see whether your data comes back clean before you commit to anything.
Or talk to us about more options. Nothing is charged without you agreeing to it first.
Building your own pipeline? POST a bill PDF and get raw extracted data back as JSON, not validated. 50 API credits free, separate from the 50 platform bills. Docs at docs.termina.com.
See how it works on the free energy data platform, or read how to extract usage and rates from an electricity bill.
A 40+ item readiness assessment covering every AASB S2 disclosure requirement, from carbon accounting and emissions to governance and ASIC lodgement. Six of the items:
Compare current reporting against every climate-related disclosure obligation.
Board oversight, management accountability, directors' duties and internal controls for sustainability data.
Direct emissions, purchased energy and your value chain, with the right emission factors.
Set up data sharing for material value chain emissions.
1.5°C and above 2°C scenarios covering transition and physical climate risks.
Agree scope and timing for limited assurance with your auditor.
Get the full checklist by email. It's free.
AASB S2 Climate-related Disclosures is Australia's mandatory standard for climate-related financial disclosures, part of the Australian Sustainability Reporting Standards (ASRS). It is aligned with IFRS S2 and built on the TCFD framework. Reporting began for Group 1 entities with financial years starting on or after 1 January 2025, Group 2 follows from 1 July 2026 and Group 3 from 1 July 2027.
AASB S2 is the mandatory standard and covers climate-related disclosures only. AASB S1 is voluntary and covers broader sustainability-related risks and opportunities, such as biodiversity and social issues. Only AASB S2 is currently required by law under the Corporations Act.
Non-compliance carries civil penalties that mirror financial reporting breaches under the Corporations Act, including director liability for misleading disclosures. For the first 3 years, private enforcement for Scope 3, scenario analysis and transition plan disclosures is limited to action by ASIC. Scope 1 and 2, governance and risk management disclosures have no such protection.
No. Scope 3 reporting is optional in your first reporting year and mandatory from your second. Most organisations start mapping their value chain in year one so the data is ready for year two.
If your financial year started on 1 July 2026, your first reporting period is already running. Carbon accounting, climate governance and auditor engagement need to be working during that first year, because the report covering it is due within 3 or 4 months of year end.
No. Termina supplies the validated energy data underneath it: Scope 1 and 2 by site and period from your electricity, gas and LPG bills, with the source bill behind every figure. You keep your carbon accounting platform and your auditor. Your first 50 bills on the platform are free.
Free to start with your first 50 bills, or $0 when we run your procurement. Talk to us about more options. Building your own pipeline instead? The bill extraction API is a separate offer for developers: raw extracted data, not validated, with 50 API credits free at docs.termina.com.
This page is general information, not legal or accounting advice. Check your position with your auditor or adviser.
40+ items covering climate-related disclosures, emissions across all three scopes, scenario analysis, governance and ASIC lodgement. Sent straight to your inbox.
Need the Scope 2 numbers themselves? Your first 50 bills on the platform are free.