Commonwealth Climate Disclosure is the Government’s policy for Commonwealth entities and Commonwealth companies to publicly report on their exposure to climate risks and opportunities, as well as their actions to manage them. This delivers transparent and consistent climate disclosures to the Australian public.
Refer to Commonwealth Climate Disclosure (RMG 140) for specific information on the Commonwealth Climate Disclosure initiative policy.
Non-corporate Commonwealth entities (NCEs) are required to complete climate disclosures. Corporate Commonwealth entities (CCEs), and Commonwealth companies that are not required to prepare a sustainability report under section 292A of the Corporations Act 2001, are encouraged to complete climate disclosures. It is intended that the policy is mandated through amendments to section 516A of the Environment Protection and Biodiversity Conservation Act 1999 in the future. Commonwealth companies that are required to prepare a sustainability report under section 292A of the Corporations Act 2001, are subject to that initiative (refer to Stream 1).
The PGPA Flipchart is a reference of all non-corporate and corporate Commonwealth entities and companies. Commonwealth entities and companies are government bodies that are subject to the Public Governance, Performance and Accountability Act 2013.
The Commonwealth Climate Disclosure initiative aligns with a number of Government priorities including the Sustainable Finance Roadmap and the Australian Government’s Approach to Climate Risk and Opportunity Management in the Public Sector. It is complementary to the Net Zero in Government Operations Strategy.
Commonwealth Climate Disclosure Streams
Commonwealth entities and companies have been divided into 2 streams, as outlined in the diagram below.
Stream 1
There are currently at least 8 Commonwealth companies that are required to prepare a sustainability report under Section 292A of the Corporations Act 2001. These Commonwealth companies are categorised as Stream 1 under the Commonwealth Climate Disclosure policy architecture.
Stream 1 Commonwealth companies will report against the Australian Sustainability Reporting Standard AASB S2 Climate-related Disclosures (AASB S2) in accordance with Section 292A of the Corporations Act. AASB S2 is based on the International Sustainability Standards Board's (ISSB) 4 pillars of governance, strategy, risk management, and metrics and targets, with specific tailoring for Australia's large businesses and financial institutions.
RMG 137 Annual Reports for Commonwealth Companies includes additional information for Stream 1 Commonwealth companies following AASB S2 for climate disclosures.
A community of practice has been established to support Commonwealth companies reporting under the Corporations Act.
Stream 2
Stream 2 comprises all NCEs, CCEs and Commonwealth companies that are not required to prepare a sustainability report under Section 292A of the Corporations Act 2001.
Phased implementation
Climate disclosure by Commonwealth entities and Commonwealth companies in Stream 2 is being phased in over a period of 5 years. Commonwealth entities and Commonwealth companies are divided into 4 tranches according to entity type, size and profile (Tranches 0, 1, 2, and 3) as part of the phased implementation (refer to the accordion below for tranche categorisation, and information on the Tranche 3 carve-out).
Entities may and are encouraged to voluntarily report on their exposure to and management of climate risks and opportunities before their allocated date.
Tranche 0 (pilot)
Climate disclosures by Tranche 0 entities commenced with a Commonwealth Climate Disclosure Pilot by all Departments of State and entities that voluntarily opted-in. These entities prepared disclosures against the Pilot Guidance in their FY2023-24 annual reports.
Entities
- All Departments of State.
- Entities that voluntarily opted-in.
Tranche 1
First disclosure for FY2024-25 and then onwards.
Entities
- All Departments of State
- All Commonwealth entities and Commonwealth companies that are a 'controlling corporation' under the National Greenhouse and Energy Reporting Act 2007.
- All Specialist Investment Vehicles and the Future Fund Management Agency.
- Commonwealth entities and Commonwealth companies that fulfill two out of the four thresholds below:
- Referenced in Part 1 of the Climate Change (Consequential Amendments) Act 2022
- Has over 500 employees
- The value of total assets at the end of the financial year of the entity/company and any entities it controls is $1 billion or more
- The annual expense for the financial year is $500 million or more.
- All Commonwealth entities with responsibility for climate change or climate risk disclosure policy design or implementation, not otherwise covered by the previous criteria.
Tranche 2
First disclosure for FY2025-26 and then onwards.
Entities
Commonwealth entities and Commonwealth companies that fulfill 2 out of the 4 thresholds below:
- Referenced in Part 1 of the Climate Change (Consequential Amendments) Act 2022
- Has over 250 employees
- The value of total assets at the end of the financial year of the entity/company and any entities it controls is $500 million or more
- The annual expense for the financial year is $200 million or more.
Tranche 3
First disclosure for FY2026-27 and then onwards.
Entities
All remaining Commonwealth entities and Commonwealth companies, including Commonwealth companies not required to prepare a sustainability report under Section 292A of the Corporations Act 2001.
Carve out
Commonwealth entities and Commonwealth companies that meet the following criteria are only required to meet emissions reporting obligations under the Net Zero in Government Operations Strategy, and if applicable, obligations under the APS Net Zero by 2030 target. They are not required to publish a climate disclosure.
- Classified as Tranche 3
- Have less than 20 employees
- Have been assessed to not have material exposure to climate risks and opportunities
