Will ASIC grant relief from having to prepare a mandatory sustainability report?

Date of relief instrument decision

Relief given or refused

Reasons for ASIC’s decision

Conditions for relief

Duration of relief

19 June 2025

Granted relief to three wholly owned Group 1 entities of a registered superannuation entity (RSE) so that they don’t have to prepare a sustainability report for the first mandatory reporting year.

All three wholly owned entities are unlisted companies, have no material external operations, and primarily provide internal support services to entities within the RSE group.

The RSE satisfies the sustainability reporting threshold for Group 2 and is, therefore, only required to prepare a mandatory sustainability report in the following year.

Under AASB 10 Consolidated Financial Statements, the RSE is required to prepare consolidated financial statements that include wholly owned entities.

The wholly owned entities do not require relief in subsequent reporting periods because the RSE intends to elect to prepare a consolidated sustainability report for the consolidated group under section 292A(2).

ASIC were satisfied that the costs of preparing standalone audited sustainability reports for just one financial year would impose unreasonable burdens on the wholly owned entities. This is because:

• The three wholly owned entities primarily perform internal support services to the RSE group
• The cumulative greenhouse gas emissions of the three wholly owned entities represented approximately less than 1 per cent of the group’s absolute greenhouse gas emissions, and
• The climate-related financial disclosures of the three wholly owned entities would only be available for one reporting period if relief were refused.

The financial reports of each of the subsidiaries contain a summary of the relief provided.

One financial year

19 November 2025

Refused relief from the requirement to prepare sustainability reports for four entities within an Australian corporate group for the financial year ended 31 December 2025.

Each of the four entities is a large proprietary company that currently lodges individual Chapter 2M financial reports and meets the sustainability reporting requirements in its own right.

Relief was sought because one of the four entities will prepare a sustainability report that includes the other three entities. That is, emissions within the value chain are better represented through a combined sustainability report at this proposed level.

None of these entities controls the other three entities. Relief was required because these entities do not (and do not propose to) prepare consolidated financial reports under AASB 10.

ASIC was not satisfied that compliance with the relevant sustainability requirements would impose unreasonable burdens on each entity. This is because:

• Allowing the companies to prepare a consolidated sustainability report for a group of entities that does not prepare corresponding consolidated financial reports is inconsistent with the connected information requirements in AASB S2.
• The artificial consolidation of sustainability information, without one of the entities having control of the others under AASB 10, is inconsistent with the requirements of section 292A(2).

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Refused relief to five separate applicants from the requirement to prepare a sustainability report for the financial year ended 31 December 2025.

The applicants were all foreign-owned large proprietary companies required to lodge Chapter 2M financial reports.

Relief was sought on the basis that:

• They lodge their foreign parent-level sustainability reports in compliance with the Task Force for Climate-related Financial Disclosures (TCFD) recommendations

• The costs required for the Australian-level reporting is disproportionate to the value for primary users of the sustainability report
• Users would be more interested in global consolidated sustainability reports than Australian-level sustainability reports, as climate-related risks, opportunities, strategies and targets are managed at the global-level.

ASIC was not satisfied that compliance with the relevant sustainability requirements would impose unreasonable burdens because:

• Relief would reduce the consistency and comparability of climate-related financial disclosures because the TCFD recommendations are not equivalent to AASB S2.
• Relief is inconsistent with the connected information requirements in AASB S2 (users of the Australian subsidiaries’ financial reports will not be able to understand connections between the subsidiaries’ financial reports and disclosures provided by the foreign parent-level sustainability report)
• Ongoing compliance costs of preparing and lodging sustainability reports at the Australian subsidiary level are considered costs of doing business using a corporate structure in Australia, and
• The fact that the reporting entity is privately owned or has limited known external users does not mean reporting is inappropriate in the circumstances.

21 November 2025

Refused relief to three entities from the requirement to prepare sustainability reports for the financial year ended 31 December 2025.

The entities are large proprietary companies, and each lodge individual Chapter 2M financial reports.

Relief was sought on the basis that their parent, an Australian partnership, prepares a consolidated sustainability report for the Australian corporate group.

The partnership comprises three Australian and three foreign incorporated entities with equal interests, and as such, control is not vested in any single corporate partner.

The parent prepares financial reports under a partnership agreement, and there is no legal requirement for partnerships to prepare and lodge general-purpose financial reports or sustainability reports with ASIC.

ASIC was not satisfied that compliance would impose unreasonable burdens on each entity because:

• Allowing the partnership parent to prepare a consolidated sustainability report for the Australian corporate group would be inconsistent with the connected information requirements in AASB S2 because it would not correspond with each of the individual entities’ financial reports, and the parent does not prepare Chapter 2M financial reports
• The partnership is not a legal entity and cannot act as a parent for the purposes of consolidation under the Australian Accounting Standards.

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24 November 2025

Refused relief to an entity from the requirement to prepare a ‘standalone’ parent only sustainability report for the financial year ending 31 December 2025 (FY25). As permitted under section 292A(2), the entity intended to lodge a ‘standalone’ parent-only rather than a consolidated sustainability report in FY25. The entity is the parent company of an Australian group that lodges consolidated financial reports under Chapter 2M. It also had one subsidiary that is a Chapter 2M reporting entity and is not required to prepare sustainability reports until the financial year ending 31 December 2026 (FY26).

The entity argued that because it would be the only entity required to report in FY25, and its subsidiary would not be required to lodge sustainability reports until FY26, the administrative burden of preparing a standalone parent-only sustainability report justified relief.

ASIC was not satisfied that compliance with the relevant sustainability requirements would impose unreasonable burdens on the parent entity because:

• The entity could have avoided the administrative costs and complexity of a ‘standalone’ parent sustainability report by preparing a consolidated sustainability report for the group in FY25
• The burdens arise solely from the entity’s decision to defer consolidation for a year.

28 January 2026

Refused relief to a parent entity and its two wholly-owned ‘Group 1’ subsidiaries from the requirement for each of them to prepare a consolidated sustainability report (at the intermediate parent level) for the financial year ended 31 December 2025.

The two wholly-owned subsidiaries also have wholly-owned subsidiaries that meet the ‘Group 3’ threshold for sustainability reporting.

The applicants each wanted to prepare standalone sustainability reports instead of a consolidated sustainability report, on the basis that they operate independently with distinct businesses, and that standalone sustainability reports would better reflect how sustainability is managed.

ASIC refused relief on the basis that relief was not required.

Paragraph 292A(2)(b) of the Corporations Act provides the parent entity of a consolidated group with the option to prepare a sustainability report for the consolidated group, or the parent entity alone. The applicants’ proposed approach reflects an election available under the Corporations Act, rather than a basis for relief.

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4 February 2026

Granted relief to allow an entity that is a part of a stapled group not to prepare a sustainability report for the financial years ending 31 December 2025 and 31 December 2026.

The stapled group is listed on the ASX and comprises the entity, which is a company that is stapled to a trust, and its respective controlled entities. The responsible entity of the trust is a wholly-owned subsidiary of the entity.

The entity is a public company that does not meet the ‘Group 1’ size threshold for sustainability reporting but does meet the ‘Group 1’ emissions threshold because it is a registered corporation under the National Greenhouse and Energy Reporting Act 2007 and manages assets owned by the registered scheme.

The registered scheme (trust) meets the ‘Group 2’ value of assets threshold for sustainability reporting as an asset owner and therefore is not required to prepare a sustainability report until the financial year ended 31 December 2027.

ASIC granted relief to allow the entity not to prepare a sustainability report separate to the stapled group because it was satisfied it would impose unreasonable compliance burdens:

• The entity would need to establish systems, processes and incur audit costs for only two reporting periods, before its operating activities are incorporated into the stapled group’s consolidated sustainability report in the financial year ended 31 December 2027, and
• The incremental benefit to primary users of the entity’s financial reports would be outweighed by the costs of preparing the entity’s standalone sustainability reports for only two reporting periods.

The financial report for the stapled group contains a summary of the relief provided.

Two financial years

10 February 2026

Refused relief from the requirement to prepare a sustainability report for the financial year ending 31 December 2025 (FY25) and onwards to a large proprietary company that prepares and lodges financial reports under Chapter 2M.

Relief was sought on the basis that preparing a sustainability report would either:

• Be misleading because the entity operates as a holding company with only an indirect ownership interest in the underlying operating companies (i.e. it does not have operational control over those companies, a number of which are foreign-incorporated companies that operate overseas), or
• Inappropriate in the circumstances and unreasonably burdensome because the disclosures would be partly duplicative of disclosures in the sustainability report that will be prepared under the Corporations Act by another Australian entity within its corporate group.

ASIC was not satisfied that complying with the relevant sustainability reporting requirements would make the sustainability report misleading, be inappropriate in the circumstances, or impose unreasonable burdens because:

• The financial reporting and sustainability reporting requirements in Chapter 2M are intended to apply to entities that have reached a size of economic significance to the Australian economy, including holding companies that have no direct operations of their own
• AASB S2 requires disclosure of material information about climate-related financial risks and opportunities that could reasonably be expected to affect the reporting entity’s prospects, regardless of where the underlying operations are located globally, or the level of control that the entity has over those operations, and
• Reporting entities are required to prepare financial and sustainability reports reflecting their own financial position, financial performance and cash flows, even where there are other reporting entities with similar financial interests or risk exposures. This may result in duplication across entities’ Chapter 2M reports, but it is not necessarily an unintended consequence of the legislation.

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13 February 2026

Granted relief to 46 subsidiaries from having to prepare standalone sustainability reports for the financial years ended 31 December 2025, 31 December 2026 and 31 December 2027 because they will be included in the parent entity’s dual listed company (DLC) consolidated sustainability report prepared in accordance with AASB S2.

The parent entity has individual financial reporting relief to enable it to prepare and lodge DLC-consolidated financial reports. As an ASIC instrument (and not the Australian Accounting Standards) permits the parent entity to prepare consolidated financial statements, the parent entity cannot elect to prepare a consolidated sustainability report under s292A(2)(b) of the Corporations Act for the DLC structure. Therefore, ASIC also granted relief to allow the parent entity operating under a DLC structure to prepare and lodge a DLC-consolidated sustainability report (instead of a single entity sustainability report).

ASIC granted relief because it was satisfied that requiring 46 subsidiaries to each prepare a standalone sustainability report would impose unreasonable burdens when users can benefit from a consolidated sustainability report prepared in compliance with the requirements in the Corporations Act and AASB S2.

This is consistent with s292A(2), which allows an Australian parent entity to prepare consolidated sustainability reports on behalf of its group where it is required to prepare consolidated financial statements.

In this case, the parent entities under the DLC arrangements operate together as a single economic enterprise and are required to prepare consolidated financial statements for the DLC.

The relief ensures that the parents’ financial and sustainability reporting obligations will be treated in a consistent manner.

The parent entity lodges its DLC-consolidated sustainability report with ASIC.

The report contains a summary of the relief provided.           

Three financial years

10 April 2026

Granted relief to allow a ‘Group 1’ Australian subsidiary of a Canadian parent listed on the Toronto Stock Exchange to lodge its parent company’s global group consolidated sustainability reports instead of an individual stand-alone sustainability report for two financial years on the basis that those sustainability reports will be:

• Prepared in accordance with a sustainability standard equivalent to AASB S2, and

• Subject to assurance in accordance with an auditing standard equivalent to ASSA 5000 General Requirements for Sustainability Assurance Engagements (ASSA 5000).

The Australian subsidiary is also the holding company for unlisted wholly owned New Zealand incorporated entities, with all of its material operations conducted in New Zealand.

ASIC granted relief because it was satisfied that complying with the relevant sustainability requirements would impose unreasonable burdens on the subsidiary:  

• The parent will prepare a sustainability report for the global consolidated group in accordance with a standard equivalent to AASB S2, and that report will be assured under an auditing standard equivalent to ASSA 5000
• The Australian subsidiary’s climate-related risks and opportunities arise primarily from its New Zealand operations, which are material to the parent, and
• It is unlikely a standalone report would provide material additional information about the subsidiary’s climate-related risks and opportunities that is useful to primary users of the subsidiary’s financial reports.

The subsidiary lodges its parent’s global group consolidated sustainability report with ASIC.

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