--- title: "Mandatory Climate Disclosures" description: "Mandatory Climate Disclosures The capability to deliver mandatory climate disclosure doesn’t sit in any single team. That’s the problem. Group 2 reporting start 1 July 2026. Preparation should already be underway. Materiality assessment, data infrastructure and governance documentation take longer than most organisations expect. Group 3 reporting start 1 July 2027. A year feels long. […]" url: "https://talentnation.com.au/mandatory-climate-disclosures/" date_modified: "2026-05-05T12:25:21+10:00" --- # Mandatory Climate Disclosures The capability to deliver mandatory climate disclosure doesn’t sit in any single team. That’s the problem. --- ## Group 2 reporting start 1 July 2026. Preparation should already be underway. Materiality assessment, data infrastructure and governance documentation take longer than most organisations expect. ## Group 3 reporting start 1 July 2027. A year feels long. Scenario analysis, Scope 3 mapping and assurance readiness cannot be built in the final quarterly assessment, data infrastructure and governance documentation take longer than most organisations expect. ## The talent constraint Mandatory reporting commenced January 2025. No candidate has more than 18 months of direct AASB S2 experience. The market is thin and the right hire is not obvious. --- ## What the standard requires ## AASB S2 is structured around four pillars. Here is what each one operationally requires. The standard follows the same framework as TCFD — Governance, Strategy, Risk Management, and Metrics & Targets. But the obligations under mandatory reporting are materially more demanding than voluntary disclosure. Disclosures sit inside the annual report, are subject to assurance, and are signed off by directors with personal liability for material misstatement. Understanding the operational demands of each pillar is the starting point for understanding what capability your organisation needs to build. ## 01 ## Governance - Board oversight of climate risk — roles, responsibilities, review cadence - Management's role in identifying and managing climate-related risks - How climate risk integrates with existing risk frameworks - Board competency in climate — and how it is being developed *R**equires someone who can work directly with the board and audit committee to document governance structures in assurance-ready language.* ## 02 ## Strategy - Climate risks and opportunities across short, medium and long-term horizons - How risks affect the business model, value chain and financial position - Scenario analysis — including at least a 1.5°C and a physical risk scenario - Quantified financial impacts where material — not narrative description *Re**quires scenario analysis capability combined with the ability to translate outputs into quantified financial language an auditor can verify**.* ## 03 ## Risk Management - Process for identifying and assessing physical and transition climate risks - How climate risk is prioritised relative to other enterprise risks - Integration of climate risk management with existing risk management frameworks - Documented materiality thresholds — what was included and why *Requires fluency in enterprise risk frameworks and the ability to embed climate risk in a way that can be audited and defended.* ## 04 ## Metrics & Targets - Scope 1 and 2 GHG emissions — compiled to GHG Protocol standard - Scope 3 value chain emissions across all material categories - Climate-related targets and progress against them - Emissions intensity metrics and cross-industry climate metrics *Requires GHG accounting expertise and data infrastructure capability — typically where the largest gap between current state and the standard’s requirements is found.* --- ## Honest counsel ## Metrics & Targets Because AASB S2 is new, the right hire for your organisation is not a standard brief - it is a considered recommendation. *AASB S2 is still being interpreted in practice. Regulatory guidance is being refined, and direct AASB S2 experience is rare — the standard has only been mandatory since January 2025.* *What we can offer is a clear-eyed view of what the standard requires, an honest assessment of what exists in your organisation, and a considered recommendation on how to close the gap. That recommendation may be a permanent hire, an interim engagement, or a fractional role — and the right answer depends on factors specific to your organisation.* #### *We start with a conversation, not a brief.* --- ## How we work ## The scoping conversation is part of the engagement - not a prelude to it. Most recruitment engagements start with a brief. Ours start earlier. Before we search, we need to understand what you have, what the standard actually requires of your specific organisation, and what structure of engagement will close the gap most effectively. ##### **01. Understand your obligations** We work through what AASB S2 requires for your specific entity — your group, your sector, your value chain complexity, and your existing reporting obligations. **This is not a generic briefing. The standard applies differently depending on your organisation’s profile.** ##### **02. ****Assess internal capability** We review what exists inside your organisation — across finance, sustainability, risk, and legal — against the four pillars of the standard. **Most organisations have more transferable capability than they realise, and specific gaps that are more acute than they expect.** Both matter for getting the hire right. ##### **03. ****Recommend the right structure** Based on your current capability, your timeline, and what you are building toward, we recommend whether a permanent hire, an interim engagement, or a fractional role is the right structure — and why. **We will tell you honestly if the answer is a combination, or if the priority is not what you initially assumed.**. ##### **04. ****Search across the right pools** With a scoped brief, we search across the five talent pools that produce AASB S2-capable candidates — simultaneously, not sequentially. **Because the right profile spans disciplines, we do not limit the search to the sustainability market.** We know what adjacent experience looks like and which direction the learning curve runs. --- ## The three structures ## Permanent hire. Interim engagement. Fractional role. Each serves a different need. The right structure is not a preference — it follows from your timeline, your existing capability, and what you are building toward. This is the recommendation that comes out of the scoping conversation. ## 01 ## Permanent Hire **Right for organisations building internal capability for the long term.** The role is defined against year two and beyond — not just the first report. Typically sits within finance or risk, and is benchmarked against a remuneration market that has moved significantly since ISSB adoption. - Sourced from across all five talent pools — not just the sustainability market - Remuneration benchmarking provided during the role brief to align with internal banding - Executive search methodology underpins all appointments - Project managed from role scoping through to offer acceptance *Most appropriate for Group 2 and 3 organisations with a clear long-term ESG function in view.* ## 02 ## Interim Engagement **Right for organisations that need to get the first report across the line.** - Deployable significantly faster than a permanent search - Sourced from Group 1 reporting teams, audit, and ESG consulting - Can run in parallel with a permanent search if required - Establishes the framework your permanent hire will inherit *T**he most common structure for Group 2 entities. Addresses immediate deadline pressure without a long-term commitment.* ## 03 ## Fractional Role **Right for organisations that need senior expertise without a full-time commitment.** - Appropriate where the full-time workload does not yet justify a permanent hire - Provides access to senior expertise at a level the market would not otherwise sustain - Can be structured around specific deliverables — materiality assessment, scenario analysis, first report - Often used by Group 3 organisations beginning early preparation *Increasingly common as organisations recognise they need senior judgment, not just execution capacity.* --- ## Start the conversation ## We start with your situation - not a brief. Tell us where your organisation sits. We will come to that conversation with a clear understanding of what AASB S2 requires, and an open mind about what structure best serves your needs. There is no commitment in having the conversation. 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