Preparing your club for mandatory climate reporting

Recent legislative commentary and its impact on the requirements for clubs

With AASB S2 climate‑related disclosures now being mandated across Australia, clubs are increasingly seeking clarity on what mandatory climate reporting means for their governance, operations and long‑term strategy.

While there is a lot of discussion around proposed legislative changes, most large registered clubs – such as leagues, RSL and community clubs registered as companies limited by guarantee - meet the criteria for financial and sustainability reporting and will still need to lodge sustainability reports to comply with current regulatory requirements. It’s important to note that the proposed legislative changes in the Budget Papers, specifically reference private companies, not public companies limited by guarantees. Therefore, at face value, the current thresholds haven’t changed.

What we know so far

The proposed legislative changes have doubled the thresholds for revenue ($50 million to $100 million) and assets ($25 million to $50 million), however employee numbers have remained the same at 100 employees. There are two critical points here:

• There is no clarity on whether the proposed changes impact companies limited by guarantee – even though it would make sense to align them. BDO is closely monitoring this and will publish updates on any changes.
• If the changes were to be filtered down to companies limited by guarantee, including registered clubs, the change in thresholds is not likely to have a significant impact on the number of club groups in scope for reporting. The reality is that most venues that have greater than $50 million of revenue and were in scope for Group 3 reporting, will likely have greater than $50 million of total assets and more than 100 employees. As a result, the doubling of the revenue threshold is unlikely to dramatically shift the number of entities in scope.

Given the regulatory environment in which clubs operate, staying up to date on these changes matters, and lodging a sustainability report containing climate-related disclosures to comply with the updated requirements of the Corporations Act 2001 can be a lengthy and complex process for club finance teams. As such, gaining a strong understanding of the requirements and starting the preparation journey is vital to meeting your organisation’s first reporting deadline.

Mandatory sustainability reporting: the four pillars AASB S2

Australia’s mandatory climate reporting regime commenced on 1 January 2025, with most clubs expected to fall within Group 3 and begin reporting for periods ending in 2028. Clubs can begin to prepare by aligning to the four AASB S2 pillars of governance, strategy, risk management, and metrics and targets:

1. Confirm governance arrangements and board oversight
2. Identify climate-related risks and opportunities, and determine the strategy to address these
3. Embed climate risk management into existing processes
4. Build reliable metrics and targets.

The AASB S2 standard mirrors global IFRS S2 expectations and is designed for investor-grade, auditable disclosure. For clubs, this means sustainability reporting will soon sit alongside annual financial reporting as part of annual reporting to members.

To position your club for success under Australia’s mandatory climate reporting requirements, consider these practical steps:

1. Assess your club’s readiness for AASB S2 by undertaking a gap assessment
2. Begin to build awareness among the Board, senior leadership team and finance team through training
3. Develop a detailed roadmap and plan, which sets out when and how the technical work will be undertaken and will feed into your first report. 

After you have set this foundation, you will be ready to begin the technical work which includes undertaking a climate risk and opportunity assessment, climate scenario analysis, and carbon emissions measurement. These inputs, along with the underlying working papers, can then be used to draft your first AASB S2 sustainability report and be ready for assurance.

Carbon accounting for clubs

Value‑chain mapping and boundary setting determine which emissions must be captured and disclosed under AASB S2. Establishing these foundations enables accurate, auditable emissions measurement, strengthens analysis of resources, relationships, impacts and dependencies, helps identify risks and opportunities across the value chain, and ensures climate-related disclosures are consistent and defensible under assurance.

Understanding carbon accounting is essential for clubs seeking to accurately measure emissions across their varied operations, including hospitality, gaming, accommodation, community services and expanding non-core activities. Addressing common hurdles such as data quality, completeness and the intricacies of value‑chain emissions, a structured ten-step carbon accounting methodology can assist clubs with clear source identification, robust data collection, the use of appropriate emissions factors, and consolidated, report‑ready outputs.

Activities clubs need to undertake to prepare include:

• Mapping business model and value chain to identify where emissions arise across upstream, operational and downstream activities
• Prioritising material emissions sources to support Scope 1 and 2 reporting and prepare for future Scope 3 requirements
• Defining clear organisational and operational boundaries, including which entities, activities and emissions sources fall within boundary
• Classifying emissions consistently across Scope 1 (direct), Scope 2 (purchased energy) and Scope 3 (value chain)
• Establishing core carbon accounting processes, including data collection, emissions factors, scenario analysis, consolidation and reporting.

With the right systems and processes in place, clubs can move beyond one-off data gathering and build carbon accounting into their regular finance and operational rhythms, creating the reliable emissions data needed for consistent, assurance-ready climate reporting.

Integrating sustainability reporting into finance operations

Building capability takes time. With reporting requirements approaching and club operations and investments becoming more diversified, starting early is critical. Uplift is needed across finance systems, procurement, operational data, and board‑level oversight to ensure climate reporting is reliable, repeatable and ready for assurance.

To effectively meet emerging requirements, clubs must take proactive steps to strengthen their carbon accounting and climate reporting foundations:

• Establish clear ownership across governance, finance, sustainability and operations, with defined roles for data collection, review and oversight
• Develop standardised processes for emissions measurement, risk assessment, scenario analysis and reporting, aligned to the financial reporting cycle
• Invest in fit‑for‑purpose systems to capture, consolidate and report emissions data, supported by strong data governance and audit‑ready controls
• Review and uplift governance and risk management pathways that integrate climate reporting into existing decision‑making and oversight structures.

Embedding climate reporting into daily club operations is essential for AASB S2 compliance. This isn’t a one‑off task, but an ongoing process that demands consistent procedures, supported by appropriate people, robust systems and strong governance.

How BDO can help

BDO is committed to supporting clubs at every stage of their climate reporting journey. Our club specialists are available to guide you through establishing clear ownership across governance, finance, sustainability and operations. We can help you define roles for data collection, review and oversight, ensuring your team is prepared for the evolving requirements of carbon accounting and climate-related disclosures. Reach out to the BDO clubs specialists to start your preparation and strengthen your reporting foundations.

For practical guidance on key developments and best practices, register for our AASB S2 Sustainability Reporting Workshop. Our workshop will help you understand what’s required and how to approach implementation, with practical examples and guidance to support your reporting.