Group 3 covers companies meeting two of three size tests, for financial years from 1 July 2027, in full or through a documented materiality exemption.
In short: You're in Group 3 if your company meets two of three tests: consolidated revenue of $50 million or more, gross assets of $25 million or more, or 100 or more employees. Group 3 reports for financial years starting on or after 1 July 2027, either in full or through a documented materiality exemption, and both routes need an auditor's report. 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. They line up with the thresholds for large proprietary companies under the Corporations Act.
| Criteria | Group 3 threshold |
|---|---|
| Consolidated revenue | $50 million or more |
| Gross assets | $25 million or more |
| Employees | 100 or more |
| Size test | Meet at least two of the three above |
| First reporting period | Financial years starting on or after 1 July 2027 |
Compare all three groups in our mandatory climate reporting guide.
If you find no material climate-related financial risks or opportunities, you can claim an exemption from full AASB S2 reporting. It needs a formal materiality assessment documenting your reasoning.
A published statement, a directors' declaration confirming the assessment, and an auditor's report. Director liability still applies to misleading statements.
For financial years starting on or after 1 July 2027. The first report, or the materiality exemption statement, is due within 3 months (disclosing entities) or 4 months (other entities) of the end of the financial year, alongside the financial report.
Run the materiality assessment, build carbon accounting capability and get ready for supply chain data requests.
Full climate-related disclosures, or a materiality exemption statement.
Lodged with ASIC alongside the financial report. 3 months for disclosing entities, 4 months for other entities.
An auditor's report is required whichever route you take.
If you report in full, material value chain emissions must be disclosed from your second 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.
Even if you claim the materiality exemption, Group 1 and Group 2 entities in your supply chain are already asking for your energy data for their Scope 3 disclosures. Being able to produce clean electricity consumption and emissions figures is becoming a commercial requirement, not just a regulatory one. For franchise operators, hospitality venues, childcare centres and retailers, the pressure comes from both sides.
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:
Two of three: $50 million revenue, $25 million gross assets, 100 or more employees.
Decide whether the exemption applies or full disclosures are required.
Even if exempt, formal documentation and an auditor's report are mandatory, and director liability applies.
Group 1 and 2 entities will ask for your emissions data for their Scope 3.
Start carbon accounting with the right emission factors before your first period.
Full disclosure and the exemption route, with the steps for each.
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.
Not without documentation. A Group 3 entity can claim the materiality exemption if it finds no material climate-related financial risks or opportunities, but that needs a formal materiality assessment, a published statement explaining the conclusion, director sign-off and an auditor's report. You cannot simply choose not to report.
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.