Document ID: chunk:federal_register_of_legislation:F2024L01472:body:0:p78
Version: federal_register_of_legislation:F2024L01472
Segment Type: other
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Character Range: 223417–226397

2.             As described in paragraphs BC79–BC84, some AASB members have concerns that some public sector application issues have not yet been addressed and the benefits of applying AASB S2 may not exceed the costs for some entities. However, they note that these issues will be considered in the future AASB projects described in paragraphs BC82 and BC84, and AASB S2 will be the subject of a post-implementation review which will commence shortly after entities begin application.
 3.             Furthermore, the AASB notes that the Australian Government will conduct a review of climate disclosure requirements in 2028–29. The Treasury Policy Position Statement Mandatory climate-related financial disclosures (January 2024) states that the Australian Government will conduct a review of climate disclosure requirements in 2028–29. The review will be led by Treasury, working with the Council of Financial Regulators. At a minimum, the review will examine the effectiveness of coverage settings (particularly the approach to Group 3 entities), appropriateness of the liability framework and whether there are any other barriers that may be affecting a company's ability to make quality disclosures, including data availability, and supporting materials.

Effective date
 1.             The financial period in which an entity is first required to apply AASB S2 is specified in the Corporations Act as amended by the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024. It specifies three application dates (financial years beginning on or after 1 January 2025, 1 July 2026 and 1 July 2027) for the various classes of entity, based on entity size or, for NGER reporters, on level of emissions.
 2.             To support the Corporations Act requirements, AASB S2 has an effective date of annual reporting periods beginning on or after 1 January 2025. However, entities required to comply with the Standard follow their application date as set out in the legislation. Earlier application is permitted.

Dissenting view

Dissent of Caroline Spencer

DV1 I consider the AASB did what was necessary in the circumstances to develop AASB S2 to support the Australian Government's decision to require certain large businesses and financial institutions to prepare climate-related financial disclosures in annual reporting periods beginning on or after 1 January 2025. However, given this internationally-aligned Standard is developed based on IFRS S1 and IFRS S2, which have been designed for larger for-profit entities to meet their investors' needs, I am not confident that application to smaller and not-for-profit entities in the private and public sectors meets the threshold for my support as an AASB Board member, of being in 'the best interests of the private and public sectors in the Australian economy'.
DV2 In particular, I have concerns around the cost, the usefulness and the auditability of these reporting requirements. As far as