The Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024 introduced mandatory climate-related financial disclosure requirements for certain entities under Chapter 2M of the Corporations Act. 

Organisations falling within scope will be required to lodge sustainability reports aligned with the AASB S2 standard, which is largely aligned to the framework developed by the International Sustainability Standards Board (ISSB).

On 31 March 2025, the Australian Securities and Investments Commission (ASIC) released Regulatory Guide 280 (RG 280) to assist entities in understanding and complying with their new obligations. 

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Overview of ASIC Regulatory Guide 280 (RG 280)

RG 280 sets out ASIC’s expectations for climate-related financial disclosures. Entities that meet prescribed thresholds must prepare and lodge sustainability reports that include:

• Climate statements prepared in accordance with AASB S2, encompassing governance, risk management, metrics & targets, and scenario analysis.
  
  
• Supporting notes and assumptions, including those relating to emissions estimates and transition risks.
  
  
• A Director’s Declaration confirming the integrity of the disclosures.

The regime also introduces phased assurance requirements, beginning with limited assurance and moving toward reasonable assurance by 2030. 

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Reporting thresholds and timelines: where oil, gas and mining companies are likely to land 

Given the scale of most oil, gas and mining operations, many companies will fall into Group 1 or Group 2, and therefore fall into the below reporting schedule:

In addition, entities reporting under the National Greenhouse and Energy Reporting (NGER) Act may be captured, regardless of size. This is particularly relevant for operators with high direct (Scope 1) emissions. 

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What is the impact on contractors, service providers and joint ventures in the oil, gas and mining sectors?

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While direct obligations apply only to entities that meet the reporting thresholds. Non-reporting entities such as equipment suppliers, drillers, logistics providers and site contractors form part of the reporting entities’ supply chains. As such, they may be asked to do the following to to enable their customers to meet their reporting requirements:

• Providing emissions data for Scope 3 reporting, particularly from transport, purchased goods, and capital equipment
• Supporting climate scenario analysis, especially in carbon-intensive regions or projects
• Demonstrate climate-related controls and risk frameworks, such as mitigation policies and site-level exposure tracking.
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This broader reach means that multiple tiers of suppliers across the oil, gas and mining value chain may need to develop systems for data collection and climate risk assessment.

How should businesses prepare for compliance?

Australian organisations should assess whether Sustainability Reporting requirements apply to them (whether directly or indirectly) and begin laying the groundwork for compliance. 

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Priority actions for the oil, gas and mining sector

• Confirm Sustainability Reporting thresholds and any NGER obligations
• Review governance structures for climate-related disclosure oversight
• Implement emissions data collection and assurance systems
• Map alignment between financial and sustainability disclosures, especially for capital projects, impairments and reserves
• Engage assurance providers early, given phased audit requirements and sector complexity.
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What resources are available?

To support implementation, Fair Supply has published a practical guide designed for reporting entities, ESG professionals, and compliance teams. It includes a checklist for readiness, sector-specific considerations, and tools for aligning disclosures with regulatory expectations.

Download the guide to help ensure your organisation is prepared for this next phase of climate reporting accountability.