Are you considered an asset owner for Group 2 climate reporting purposes?

Are you considered an asset owner for Group 2 climate reporting purposes?

On 27 March 2024, the Australian Government introduced climate reporting legislation into Parliament. The Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill (Bill) outlines a roadmap to mandatory climate reporting in Australia, including, who must report, and by when. One of the types of entities required to prepare climate statements in the second phase (referred to commonly as ‘Group 2’ entities), are ‘asset owners’.

Who is an ‘asset owner’?

‘Asset owners’ is a term used in the Government’s Policy Statement to denote entities with $5 billion or more of assets under management, however, it is not defined anywhere else, including in the Bill.

Exposure draft proposals

The Government’s 12 January 2024 climate reporting exposure draft initially proposed to mandate climate reporting for Group 2 entities if the value of their assets at the end of the relevant financial year is $5 billion or more. This ‘asset owners’ test was to be independent of the size threshold and the NGER reporters test shown in the table below and also applied to all types of investment vehicles, regardless of whether they were publicly or privately held.


Large entities and their controlled entities meet at least two of three criteria (size threshold test)

National Greenhouse Energy Reporting (NGER) reporters

Asset owners


Consolidated revenue

End of financial year consolidated gross assets

End of financial year employees



Group 2

$200 million or more

$500 million or more

250 or more

All other NGER reporters

$5 billion assets under management or more

Requirements in the Bill

We are pleased to see that the ‘asset owners’ test in the Bill only applies to:

  • Registered schemes
  • Registrable superannuation funds, and
  • Retail corporate collective investment vehicle (CCIVs).

These are the usual types of investment vehicles used for public investing.

Private family investment companies with $5 billion or more in assets will only have to prepare mandatory climate statements if they meet two out of the three size thresholds shown in the table above.

How BDO can help 

Our sustainability reporting experts can help you determine your climate reporting obligations during the phase in period, and get you started on your sustainability reporting journey.

Contact us today.