Related registered schemes can include sustainability disclosures in one sustainability report
Related registered schemes can include sustainability disclosures in one sustainability report
In good news for related registered schemes, ASIC has provided sustainability reporting relief similar to that available for presenting financial statements of multiple related schemes in a single annual report. This relief will reduce unnecessary duplication of sustainability disclosures where the same information applies to multiple related registered schemes.
What is a related registered scheme?
A registered scheme is related to another registered scheme if they share the same responsible entity, or if their responsible entities are wholly beneficially owned by the same entity.
Financial reporting by related registered schemes
Section 292(1)(d) of Chapter 2M of the Corporations Act 2001 requires a registered scheme to prepare, have audited, and lodge financial statements with the Australian Securities and Investments Commission (ASIC). These are generally for an individual scheme, unless AASB 10 Consolidated Financial Statements requires consolidated financial statements, such as when the scheme has control over other entities or schemes.
If a single responsible entity administers a number of similar schemes (related schemes), it may wish to present the financial statements of all related schemes in a single annual report. For example, this could take the form of the primary financial statements and notes presented in adjacent columns, with other narrative disclosures typically common across all schemes.
ASIC Corporations (Related Scheme Reports) Instrument 2025/438 (LI 2025/438) permits the financial statements of related schemes to be presented in one annual report. However, LI 2025/438 previously contained no similar exemption for the sustainability report.
Sustainability reporting by related schemes
ASIC Corporations (Amendment) Instrument 2026/313 (LI 2026/313) amends LI 2025/438 to provide relief so that sustainability disclosures of related schemes can also be included within a single sustainability report.
The relief is only available where all of the following requirements are met:
- The related schemes are already relying on the financial reporting relief in LI 2025/438
- The sustainability reports of the related schemes are audited or reviewed by the same auditor
- The sustainability report contains a prominent statement that the relief is being relied upon and what this means for the way the sustainability report is presented within the annual report (i.e. the effect of the relief)
- The sustainability report contains a prominent statement identifying where the sustainability disclosures, notes and directors’ declarations can be found for each scheme
- Where the directors’ declaration regarding the sustainability report covers more than one registered scheme, each declaration must be presented in a way that enables each scheme to be readily identified, and
- If one of the reported schemes does not have the same responsible entity as the others, the additional requirements in condition 6A(2)(e) are met.
AASB S2 disclosures required for all related schemes
Applying the relief in LI 2026/313 does not reduce the sustainability reporting requirements under the Corporations Act 2001 and AASB S2 Climate-related disclosures. All required disclosures must be included for each entity.
Some disclosures can be labelled as applying to all related schemes, such as for governance and risk management. However, other disclosures may be specific to individual schemes. For example, the risks, opportunities, targets and metrics may be different from one scheme to another, and must clearly identify which entity they relate to. Using tables is a good way to present this information, with each column specifying the relevant entity to which the information relates.
More information
You can find practical guidance about how best to comply with your sustainability reporting obligations in the Australian Securities and Investments Commission’s (ASIC’s) Regulatory Guide 280 Sustainability reporting, which also explains ASIC’s approach to supervision and enforcement, particularly in the early years.
Need help?
The mandatory sustainability reporting rules are new and complex, and different to what finance teams are familiar with for financial reporting. Our sustainability reporting experts are always available to assist with your sustainability reporting journey. Contact us for help.
