Commonwealth Climate Disclosure Requirements

Commonwealth Climate Disclosure is the Government’s policy for Commonwealth entities and Commonwealth companies to publicly report on their exposure to climate risks and opportunities, as well as their actions to manage them, delivering transparent and consistent climate disclosures to the Australian public.

Non-corporate Commonwealth entities are required to complete climate disclosures.

Corporate Commonwealth entities, and Commonwealth companies who are not required to prepare a sustainability report under section 292A of the Corporations Act 2001, are encouraged to complete climate disclosures. It is intended that the policy is mandated through amendments to section 516A of the Environment Protection and Biodiversity Conservation Act 1999 in the future.

Commonwealth companies that are required to prepare a sustainability report under section 292A of the Corporations Act 2001 are subject to that initiative.

Tranche 1 entities are:

• All Commonwealth entities that are a 'controlling corporation' under the National Greenhouse and Energy Reporting Act 2007.
• All Specialist Investment Vehicles, and the Future Fund Management Agency.
• Entities that fulfill two out of the four thresholds below:
  • Referenced in Part 1 of the Climate Change (Consequential Amendments) Act 2022;
  • Has over 500 employees;
  • The value of total assets at the end of the financial year of the entity/company and any entities it controls is $1 billion or more;
  • The annual expense for the financial year is $500 million or more.
• All Commonwealth entities with responsibility for climate change or climate risk disclosure policy design or implementation, not otherwise covered by the previous criteria.

You can refer to the Commonwealth Climate Disclosure Policy to confirm what year your entity is due to commence reporting.

A range of resources have been developed to help support you in preparing your climate disclosure, which can be found at the bottom of this page. While some resources are available now, others will be progressively developed and published from Q1 2025. All resources available are included on the Application Guidance webpage.

The Application Guidance will include:

• factsheets on specific elements of the criteria
• example disclosures
• links to annual reports produced during the CCD Pilot
• an online module covering the fundamentals s of Climate Disclosure

In addition, the Climate Action in Government Operations Unit within the Department of Finance can perform thematic reviews of entities’ climate disclosure drafts, prior to publication in annual reports. Contact climateaction@finance.gov.au for further information.

The Department of Climate Change, Energy, the Environment and Water (DCCEEW) has also developed a range of tools and guidance to support entities to identify, assess, prioritise, and manage their climate-related risks and opportunities, as part of the Climate Risk and Opportunity Management Program. These include (but are not limited to):

• Climate Risk and Opportunity learning and development modules on APS Academy
• Climate Risk Management Guides, including the Organisation Application Guide
• Climate Risk Digital Tool.

You do not need to have a Chief Sustainability Officer (CSO) however, non-corporate Commonwealth entities are encouraged to consider appointing a CSO as per the Net Zero in Government Operations Strategy. Corporate Commonwealth entities and companies can also consider appointing such a role.

The role of the CSO is to champion initiatives that support climate action in government operations, such as emissions reporting, APS Net Zero (including implementation of emissions reduction actions), climate risk management and disclosure. The CSO responsibilities could be added to an existing role or it could be a standalone role, depending on your entities’ circumstances, and may evolve over time.

A CSO Network has been established to support senior officials in this role, including championing climate-related risks and opportunities across their organisation.

The Commonwealth Climate Disclosure initiative has been designed to work with multiple other programs that support climate action in government operations to reduce duplication and compliance burden for departments, including the:

• Climate Risk and Opportunity Management Program (CROMP) administered by the Department of Climate Change, Energy, the Environment and Water (DCCEEW)
• Greenhouse gas emissions reporting obligations under the APS Net Zero Emissions Reporting Framework
• APS Net Zero by 2030 target

Familiarising yourself with these relevant policies and frameworks will assist you in understanding the Commonwealth Climate Disclosure initiative.

Commonwealth Climate Disclosures are currently not subject to a specific climate disclosure audit and assurance regime. The Department of Finance  is designing a verification and assurance regime in consultation with the Australian National Audit Office (ANAO) and affected entities.