Summary
Details
- Australia
RG 280 itself is not a statute, but entities subject to ASIC oversight should assume RG 280 reflects the standard ASIC will benchmark against when assessing sustainability reporting quality and misleading conduct risk.
Smaller entities may be outside early phase-in thresholds for mandatory reporting, but still face ASIC and market conduct risk if they make sustainability claims to investors or consumers.
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What’s Required
RG 280 emphasises that reporting entities need mature controls, policies, procedures, and systems for sustainability reporting, and that these capabilities are expected to develop over time. For compliance, this means sustainability reporting must be treated like financial reporting: defined ownership, documented methodologies, internal controls, and evidence retention.
RG 280 highlights evolving director expectations and references a director declaration requirement for financial years commencing on or after 1 January 2028. This signals that ASIC expects boards to build competence early, establish governance, and actively test readiness rather than relying on management assurances.
A defensible program typically includes:
Scope and boundary governance: how the entity determines reporting perimeter, subsidiaries, financed emissions relevance, and data consolidation rules.
Methodology governance: documented choices for emissions factors, scenario assumptions, and materiality judgments.
Data lineage and audit trails: traceability from source systems to final disclosures with change control.
Disclosure review: legal review for misleading statements risk, and finance review for consistency with financial statements and impairment logic.
Third-party reliance controls: due diligence on consultants and data providers, including contractual warranties and audit rights.
Important Deadlines
Director declaration reference point: RG 280 indicates a director declaration applies for financial years commencing on or after 1 January 2028, making 2026–2027 a practical runway period for governance maturity and trial reporting.
Current Status
RG 280 is published ASIC guidance (31 March 2025) and should be treated as an active supervisory statement of expectations, especially for entities in early phases of mandatory climate reporting.
Penalties for Non-Compliance
RG 280’s enforcement relevance is indirect but real: weak controls increase the risk of defective reporting and misleading statements, which can trigger ASIC regulatory action under corporations and market conduct frameworks.
Examples of Known Violations
Common reporting-control failures that ASIC typically focuses on include:
Boilerplate disclosures disconnected from actual risk exposures.
Unsubstantiated targets and transition plans.
Weak evidence for key assumptions (scenario inputs, carbon price sensitivities).
Inconsistent emissions numbers across different reports (annual report vs sustainability report vs investor deck).
Poor oversight of outsourced reporting drafts.
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