Climate Risk is Now an Audited Financial Obligation.
Is Your Board Exposed?
New mandatory climate disclosures are a personal liability for directors
Australian companies above certain size thresholds must now include climate-related financial disclosures in a sustainability report lodged with ASIC as part of their annual reporting obligations. This sits alongside the annual financial report and is subject to formal assurance requirements. Directors must personally sign off on the report, and disclosures that are misleading or cannot be substantiated can attract significant penalties.
Group 1 - Reporting from 1 January 2025
$500m+ gross revenue; $1bn+ assets; 500+ employees; or above NGER greenhouse gas publication threshold
Group 2 - Reporting from 1 July 2026
$200m+ gross revenue, $500m+ assets; 250+ employees; or all other NGER reporters
Group 3 - Reporting from 1 July 2027
$50m+ gross revenue; $25m+ assets; 100+ employees
The new rules apply in three waves based on meeting any two of the three requirements for revenue, assets and employees, or whether the organisation meets NGER publication thresholds:
Are you in scope?
If you’re unsure which group applies to you, call us to discuss. 2027 may feel distant, but establishing governance structures, data systems and baselines can take up to a year to set up properly. Starting now secures your budget and avoids reporting under pressure.
Two traps we see executives walk into
Indefensible precision: Climate data often don’t support the loss forecasts a standard risk process demands. If a number can’t be defended under audit, the Board carries the liability. Knowing when to quantify and when to stress-test qualitatively is the single biggest determinant of a defensible disclosure.
Year-on-year lock-in: The new standards require consistency in reporting over time. An overly complex Year 1 reporting model, often sold as best practice, ties you to the same level of cost and complexity thereafter. Right-sizing Year 1 is a financial decision, not a technical one.
We work with senior climate scientists, engineers, economists and reporting specialists who understand financial risk, not risk consultants or accountants who have moved into climate. The distinction matters: more defensible assumptions, less audit rework, a Year 1 design you won’t regret in Year 3, and practical responses to manage risk built on engineering experience. Our principals have delivered climate risk and disclosure work for a global food company, an international data centre operator and an Australian government company managing critical infrastructure. We don’t operate with large-firm overheads: the experts you meet are the ones doing the work.
Why Danu
60-Minute Executive Briefing, No Charge
In one hour with your CEO and CFO, we will tell you: whether you are in scope, the three or four decisions your Board needs to make in the next 90 days, and a realistic critical path to your first compliant report.
Advisory Firms
If you need senior climate risk capability for a disclosure engagement, including physical risk assessment, adaptation planning or independent review, contact us to discuss associate and subcontract arrangements.