The New Sustainability Reporting Landscape: Corporations Act + ASRS (AASB S2)
Australia has entered a new era of mandatory sustainability reporting. Entities captured under Chapter 2M of the Corporations Act and the relevant thresholds must prepare a sustainability report containing climate-related financial information in accordance with AASB S2. ASIC’s Regulatory Guide 280 sets out how ASIC will administer and supervise these obligations and what “good” looks like in practice.
NGERS — Australia’s Mandatory Baseline
NGERS requires large facilities and corporate groups to report Scope 1 and 2 emissions annually. Thresholds include:
- ≥25,000 tCO₂-e or ≥100 TJ for a facility
- ≥50,000 tCO₂-e or ≥200 TJ across a corporate group
Corporations must register by 31 August and report by 31 October, with penalties reaching over $600,000 per contravention. NGERS covers only Scope 1 and 2 — not Scope 3. However, ICT recycling and asset recovery processes can contribute NGERS-relevant Scope 1 and 2 data, especially when processed through certified pathways such as Recover-E.
ASRS — Mandatory Climate Disclosures in Financial Reports
ASRS embeds climate-related disclosures into audited financial statements. It requires companies to report:
- Scope 1, Scope 2 and Scope 3 emissions
- Climate governance and risk management
- Strategy, targets and transition plans
- Metrics aligned with AASB S2 and ISSB standards
Implementation is phased from FY25 to FY27, beginning with Australia’s largest entities. Limited assurance is required initially, progressing to reasonable assurance by 2030. ASIC oversees compliance and will act on misleading statements or incomplete disclosures.
Why ICT Procurement Is Now a Compliance Checkpoint
ICT sits at the intersection of NGERS, ASRS and AASB requirements. It is a high-value, high-frequency category with significant embodied emissions, logistics impacts and end-of-life considerations. Scope 3 emissions from ICT can include manufacturing, packaging, freight, cloud infrastructure, and disposal — categories that often make up more than 70% of a company’s total emissions.
Under ASRS, generic estimates or industry averages will no longer satisfy auditors. Organisations must obtain supplier-specific, evidence-backed data. This makes ICT procurement a critical compliance checkpoint — and a significant risk if suppliers cannot provide verified information.
How TechForGood Supports NGERS and ASRS Compliance
TechForGood provides ICT procurement data that is NGERS-ready today and ASRS-aligned tomorrow. This includes:
- Scope 3 emissions data linked to ICT procurement events
- ISO-certified recycling, destruction and material recovery data through Recover-E
- Landfill diversion evidence required for environmental and circularity disclosures
- Secure data destruction certificates supporting governance and risk controls
- Supplier-level audit trails to satisfy ASSA 5000/5010 assurance
This approach ensures ICT procurement contributes directly to ASRS disclosures while reducing compliance burden for finance, sustainability and procurement teams.
Director Liability, Assurance and ASIC Oversight
The updated ESG regime increases accountability across leadership:
- Directors must ensure disclosures are accurate and complete
- Auditors will test data under ASSA 5000/5010 standards
- ASIC will monitor greenwashing and misleading claims
- Entities must retain clear, verifiable records
Supplier-provided, auditable ICT data helps organisations meet these obligations. Without procurement-aligned evidence, ASRS reporting becomes a significant assurance risk
Integrating NGERS, ASRS and AASB Through ICT Procurement
TechForGood’s model supports multiple compliance areas simultaneously:
- NGERS: Scope 1 & 2 contributions from ICT recycling
- ASRS: Scope 3 emissions from devices, logistics, packaging and end-of-life
- AASB S2: Climate governance, risk processes and emission metrics
- ASSA 5000/5010: Evidence aligned with assurance requirements
- ASIC oversight: Reduced risk of misleading or unsupported claims
Through verified supply chain data, ICT procurement becomes a compliance enabler — not an assurance liability.
How This Strengthens Broader ESG Outcomes
Beyond compliance, TechForGood supports environmental and social outcomes through:
- Circular recovery and landfill diversion
- Carbon reduction pathways through Carbon Neutral IT Procurement
- Social procurement outcomes via the Social Procurement ICT Supplier model
- Governance assurance through working with a B Corp Certified ICT Supplier
This integrates environmental, social and governance performance into everyday ICT spend — reducing risk while increasing measurable impact.
Australian Sustainability Reporting Standards (ASRS) – The New Sustainability Reporting Standard
The Australian Sustainability Reporting Standards represent the most significant change to corporate reporting in more than a decade. Legislated through amendments to the Corporations Act in 2024, these standards embed climate-related disclosures directly into audited financial reports for the first time.
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- Effective from financial years starting 1 Jan 2025.
- Mandatory disclosure (AASB S2): Climate-related financial disclosures included in audited reports.
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Scope covered:
- Scope 1 & 2 (NGERS methodology allowed).
- Scope 3 (supply chain, ICT procurement, packaging, logistics, financed emissions, end-of-life).
- Governance, risk, strategy, targets, and scenario analysis.
- Penalties: Regulatory consequences may include civil penalties, director accountability and enforcement action for misleading or non-compliant sustainability disclosures.
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Phased rollout:
- Group 1 (FY25): ≥ $500m revenue, ≥ 500 staff, or NGERS facility ≥ 100k tCO₂-e.
- Group 2 (FY26): ≥ $200m revenue, ≥ 250 staff.
- Group 3 (FY27): ≥ $50m revenue, ≥ 100 staff.
- Assurance: Limited assurance from day one → full reasonable assurance by 2030.
- Liability: Overseen by ASIC; Liability: Directors are responsible for governance and oversight of sustainability disclosures, including taking reasonable steps to ensure compliance with the Corporations Act.
- Why it matters: Climate reporting becomes public, auditable, and comparable — raising the bar for ESG data integrity.
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Phased rollout:
Why this matters for ICT procurement
Technology purchases, cloud services, logistics, and end-of-life recycling sit inside Scope 3 emissions. Choosing suppliers who provide auditable data and circular IT outcomes ensures ICT spend supports compliance under the Australian Sustainability Reporting Standards.
National Greenhouse and Energy Reporting (NGERS) – Australia’s Emissions Reporting Scheme
The National Greenhouse and Energy Reporting scheme, legislated in 2007, remains Australia’s cornerstone emissions compliance regime. It provides the statutory baseline for reporting greenhouse gas emissions and energy use, covering direct (Scope 1) and indirect electricity-related (Scope 2) emissions.
- Introduced in 2007 under the NGER Act. NGERS is foundational but incomplete — it covers only Scope 1 and Scope 2, not Scope 3.
- Scope covered: Scope 1 (direct emissions) + Scope 2 (purchased energy).
- Scope covered: Scope 1 (direct emissions) + Scope 2 (purchased energy).
- Obligations: Annual self-assessment, register by 31 Aug, report by 31 Oct via CER’s EERS portal.
- Penalties: Regulatory consequences may apply for non-compliance with NGERS obligations, including civil penalties and enforcement action.
- Why it matters: NGERS data underpins the National Greenhouse Accounts and feeds into broader ESG reporting.
While NGERS remains a standalone emissions reporting scheme, its data may inform certain climate disclosures within broader sustainability reporting frameworks where applicable.
Other Sustainability, Assurance and Governance Requirements
Sustainability reporting sits alongside a broader set of assurance, governance and regulatory expectations.
Key Dates & Thresholds at a Glance
| Framework | Scope | Who Reports | Deadlines |
|---|---|---|---|
| ASRS (AASB S2) | Scope 1, 2 & 3 + governance/targets includes Scope 3 ICT procurement disclosures |
Group 1: FY25; Group 2: FY26; Group 3: FY27 |
Annual financial reporting cycle |
| NGERS | Scope 1 & 2 | Facilities ≥25k tCO₂-e OR Corp Groups ≥50k tCO₂-e | Register: 31 Aug; Report: 31 Oct |
| ASSA Assurance | Independent assurance of sustainability disclosures | ASRS reporting entities | Phased → full assurance by 2030 |
| ASIC Oversight | Sustainability and climate disclosure integrity | All reporting entities | Ongoing |
Frequently Asked Questions
What do the ASRS reporting requirements mean for ICT procurement?
ASRS requires organisations to disclose supplier-related sustainability information, including Scope 3 ICT emissions where material. TechForGood provides ASRS-aligned ICT procurement, carbon neutrality and recycling evidence to support accurate reporting.
What ICT information do we receive for NGERS and ASRS reporting?
You receive transaction-level carbon neutrality evidence. For Switch customers, the invoice supports sustainability reporting by evidencing procurement through a certified carbon neutral supplier. Where Recover-E is used, you also receive ISO-certified end-of-life reporting and social procurement impact data.
How does TechForGood reduce the risk of ASRS or NGERS non-compliance?
We provide clear, auditable documentation for ICT purchasing and disposal. Because supplier emissions data is rarely available in the ICT supply chain, our carbon neutrality evidence and Recycling/Recover-E reporting reduce estimation risk in ESG, NGERS and ASRS disclosures.
Can this data support ESG assurance or internal audit?
Yes. Our documentation supports internal audit, ESG assurance processes and external reporting for ASRS, AASB2 and NGERS
Is guidance available for sustainability reporting?
Yes. ASIC has released free educational modules to support preparation for sustainability reporting under AASB S2
Will ASRS require ongoing ICT supplier data?
Yes. ASRS emphasises supplier-related disclosures. TechForGood ensures that carbon neutrality evidence and circularity outcomes from ICT procurement are consistently captured and available for reporting.
