Your ASRS readiness checklist: 12 months to go-live
By Geoff Gourley · 4/11/2026

For Australia's largest companies, the starting gun for mandatory climate reporting fires on 1 July 2024. For those in Groups 2 and 3, the deadlines of 2026 and 2027 will arrive sooner than you think. Preparing for the Australian Sustainability Reporting Standards (ASRS) is a major undertaking that cuts across finance, risk, legal, and operations.
This is not a task that can be left until the last minute. It requires new processes, new data, and new levels of governance rigour. Use this checklist to hold a mirror up to your organisation, identify your biggest gaps, and build a practical implementation roadmap.
Governance & Oversight
This is where it all starts. Without strong leadership from the top, your readiness program will falter. The board and executive team must be actively engaged.
Accountability: Have we formally confirmed which reporting group we fall into and what our mandatory start date is?
Board Mandate: Is there a designated board committee (e.g., Audit & Risk) with a clearly documented mandate to oversee climate risk and ASRS implementation?
Board Competency: Have we assessed the current level of climate literacy on our board? Is training scheduled to bridge any gaps?
Executive Ownership: Is there a single, accountable executive (e.g., CFO, CRO) responsible for driving the ASRS readiness project?
Strategy & Risk Integration
ASRS requires you to explain how climate change impacts your strategy and decision-making. This means integrating climate into your core business processes.
Risk & Opportunity Assessment: Have we conducted a structured assessment to identify and prioritise climate-related risks and opportunities across short, medium, and long-term horizons?
Scenario Analysis: Have we started the process of using climate scenario analysis to test the resilience of our business strategy against different warming pathways (e.g., 1.5°C vs 3°C)?
Financial Integration: Have we begun to quantify the potential financial impacts of our material climate risks and opportunities on our financial position and performance?
Transition Planning: If we have emissions reduction targets, do we have a documented transition plan that details the decarbonisation levers and associated capital expenditure?
Data, Metrics & Targets
This is the engine room of your reporting. Your disclosures will only be as good as the data that underpins them. The processes for gathering this data need to be robust enough to withstand an audit.
GHG Accounting: Can we accurately measure our Scope 1 and Scope 2 greenhouse gas emissions in accordance with the GHG Protocol? Is the data of 'assurance-ready' quality?
Scope 3 plan: Have we conducted a screening exercise to identify which of the 15 Scope 3 categories are material to our business? Do we have a plan to gather data for these categories?
Data Systems & Controls: Do we have defined processes, systems, and internal controls for collecting, storing, and managing sustainability data? Is it clear who owns the data?
Other Metrics: Beyond emissions, have we identified the other metrics we will need to track, such as capital deployed towards climate opportunities, or assets exposed to physical risk?
Internal Capability & Resourcing
ASRS implementation is a team sport. It requires a cross-functional effort and dedicated resources.
Project Team: Have we established a cross-functional working group (including finance, risk, legal, sustainability, operations) to manage the implementation project?
Skills Gap Analysis: Do we have the right mix of skills and expertise in-house? Where will we need external support from advisors, consultants, or technical experts?
Budget: Have we allocated a specific budget for ASRS readiness, covering advisory fees, data systems, and staff training?
Stakeholder Engagement
Your ASRS report will be a key communication tool for investors, lenders, insurers, and customers.
Investor Relations: How will our Investor Relations team use these new disclosures to engage with the market? Are they prepared for detailed questions from analysts?
Supply Chain: Have we started communicating with our key suppliers about our need for their emissions data to calculate our Scope 3 footprint?
The bottom line
Preparing for ASRS is not simply a reporting exercise; it's a strategic transformation project that will touch every part of your organisation. The work required is significant, and the deadlines are firm. By starting now and using this checklist to guide your efforts, you can ensure your organisation is not just compliant, but genuinely prepared for a business environment where climate performance is financial performance.
