Hero banner for NGERS & ASRS ESG compliance explained, featuring sustainability reporting context in Australia. Highlights ICT procurement data for Scope 1, 2, and 3 compliance with ISO 27001, ISO 14001, Certified B Corporation, Social Traders certified social enterprise, and NetNada carbon neutral business.

ASRS & AASB S2 Sustainability Reporting Explained

Mandatory sustainability reporting under the Corporations Act is now being phased in, based on AASB S2 Climate-related Disclosures. NGERS remains a separate emissions reporting scheme and may inform emissions measurement for some organisations — but it is not the sustainability reporting regime ASIC is training the market on.

Navigating the Sustainability Reporting Landscape in Australia

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 Credits for ICT Supply
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 most significant change to corporate reporting in more than a decade. Legislated through the Corporations Act in 2024, ASRS embeds climate-related disclosures directly into audited financial reports for the first time.

Effective 1 Jan 2025

Legislated — Corporations Act

AASB S2 mandatory

Mandatory Disclosure

AASB S2 — climate-related financial disclosures

Effective from FY starting 1 Jan 2025 — included in audited financial reports.

Scope covered:

Scope 1 and 2 — NGERS methodology allowed

Scope 3 — supply chain, ICT procurement, packaging, logistics, financed emissions, and end-of-life

Governance, risk, strategy, targets, and scenario analysis

Penalties and Liability

Overseen by ASIC — directors responsible

Regulatory consequences may include civil penalties, director accountability, and enforcement for misleading or non-compliant disclosures.

Directors responsible for governance and oversight — must take reasonable steps to ensure Corporations Act compliance.

Assurance: limited assurance from day one → full reasonable assurance by 2030.

FY2025

Group 1 — now

Large entities

≥ $500m revenue

≥ 500 staff, or

NGERS facility ≥ 100k tCO₂-e

FY2026

Group 2 — upcoming

Mid-size entities

≥ $200m revenue

≥ 250 staff

FY2027

Group 3 — planned

Smaller entities

≥ $50m revenue

≥ 100 staff

Climate reporting becomes public, auditable, and comparable — raising the bar for ESG data integrity across every supply chain, including ICT procurement.

Public reporting Auditable disclosures Scope 3 required VAGO aligned NGERS methodology

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)

Legislated in 2007, NGERS is Australia’s cornerstone emissions compliance regime. It provides the statutory baseline for reporting greenhouse gas emissions and energy use across Scope 1 and Scope 2.

Introduced under the NGER Act 2007 and covers Scope 1 and Scope 2 only, not Scope 3.

Annual obligations include registration by 31 August and reporting by 31 October via CER’s EERS portal.

NGERS data underpins the National Greenhouse Accounts and can support broader ASRS disclosures.

While standalone, NGERS data informs climate disclosures within broader sustainability frameworks.

Compliance professional reviewing emissions reporting checklist

NGERS compliance reporting

Scope 1 — covered

Direct emissions

Combustion, industrial processes, and fugitive emissions from sources owned or controlled by the organisation.

NGERS covered

Scope 2 — covered

Purchased energy

Indirect emissions from purchased electricity, heat, or steam consumed by the organisation.

NGERS covered

Scope 3 — not covered

Supply chain and ICT

ICT procurement, logistics, financed emissions, and end-of-life are required under ASRS but sit outside NGERS.

Not in NGERS

Civil penalties and enforcement action may apply for non-compliance with NGERS obligations.

Overseen by the Clean Energy Regulator, with directors responsible for governance.

Misleading disclosures may carry additional liability under relevant reporting obligations.

NGERS baseline data can support ASRS climate disclosures and National Greenhouse Accounts.

ICT often sits in Scope 3, which requires verified supply chain data beyond NGERS.

TechForGood helps close the Scope 3 gap left by NGERS alone.

Other Sustainability, Assurance and Governance Requirements

Sustainability reporting sits alongside a broader set of assurance, governance and regulatory expectations.

ASSA assurance standards

Independent assurance of sustainability disclosures will be phased in under ASSA standards, with mandatory assurance requirements applying over time.
ASIC oversight

ASIC will supervise and enforce sustainability reporting requirements, including action on misleading or unsubstantiated climate-related disclosures.
Director accountability

Directors are responsible for oversight of sustainability reporting and must take reasonable steps to ensure disclosures comply with the Corporations Act.
Future expansion

Sustainability reporting requirements are expected to expand over time, including deeper supply chain disclosures and broader assurance 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

Where ICT Procurement Fits

ICT is a growing emissions hotspot across manufacture, cloud, logistics and end-of-life. TechForGood supports sustainability reporting through:

ASRS-aligned ICT Scope 3 data

We provide assurance that devices supplied by TechForGood are carbon credited on a cradle-to-gate basis, through certified offsetting and/or Recover-E pathways.
Supplier Scope 1–3 disclosures

ICT purchases from TechForGood sit within your organisation’s Scope 3 category for Purchased Goods and Services.
NGERS-ready ICT data

Data from ICT recovery and recycling activities that may inform Scope 1 and Scope 2 emissions reporting where applicable.
Auditable reports

Transaction-level, audit-ready documentation from a certified carbon credited B Corp, with ISO-certified Recover-E reporting for end-of-life outcomes.

TechForGood is not a consultancy — we act as a compliance checkpoint supplier.

Navigating the ESG Compliance Landscape in Australia — a practical guide to NGERS, ASRS, assurance requirements, and director responsibilities.

Frequently Asked Questions

Everything you need to know about buying Microsoft licensing through TechForGood.

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 credited and recycling evidence to support accurate reporting.

What ICT information do we receive for NGERS and ASRS reporting?

You receive transaction-level carbon credited evidence. For Switch customers, the invoice supports sustainability reporting by evidencing procurement through a certified carbon credited 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 credited 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

ASIC Training Modules

Will ASRS require ongoing ICT supplier data?

Yes. ASRS emphasises supplier-related disclosures. TechForGood ensures that carbon credited evidence and circularity outcomes from ICT procurement are consistently captured and available for reporting.