Group 3 climate reporting timeline and key dates
When Group 3 reporting starts depends on your financial year end. This guide sets out the dates that follow from it: lodgement, the form of directors’ declaration, assurance, and the changes still in progress.
The anchor date. Group 3 reporting applies to financial years commencing on or after 1 July 2027 (s1707B(1)(c)). Everything else, including your lodgement deadline, which form of directors’ declaration applies and the level of assurance, follows from when your first year starts and ends.
Your first Group 3 year and lodgement deadline
The sustainability report must be lodged with ASIC within 3 months after year end for disclosing entities, registered schemes and RSEs, and within 4 months for everyone else (s319(3); RG 280.7). ASIC expects it to be lodged at the same time as the annual financial report (RG 280.95).
| Year end | First Group 3 year | Lodge by (4 months) | Lodge by (3 months)* |
|---|---|---|---|
| 30 June | 1 Jul 2027 – 30 Jun 2028 | 31 Oct 2028 | 30 Sep 2028 |
| 30 September | 1 Oct 2027 – 30 Sep 2028 | 31 Jan 2029 | 31 Dec 2028 |
| 31 December | 1 Jan 2028 – 31 Dec 2028 | 30 Apr 2029 | 31 Mar 2029 |
| 31 March | 1 Apr 2028 – 31 Mar 2029 | 31 Jul 2029 | 30 Jun 2029 |
*Disclosing entities, registered schemes and RSEs. Dates assume you are in Group 3 for that year on your year-end figures. The test is applied at the end of each financial year (RG 280.34), so re-check it every year.
Which directors’ declaration applies
The sustainability report includes a directors’ declaration, made under a board resolution, dated and signed by a director (s296A(6)–(7)). Its wording depends on when the financial year starts (s1707C; RG 280.58–280.59):
- Years starting from 1 January 2025 to 31 December 2027: directors declare whether, in their opinion, the entity has taken reasonable steps to ensure the report is in accordance with the Act and AASB S2.
- Years starting on or after 1 January 2028: directors declare whether, in their opinion, the report is in accordance with the Act, including AASB S2.
So a 30 June or 30 September Group 3 entity gets the reasonable-steps form in its first year. A 31 December or 31 March entity, whose first Group 3 year starts in 2028, goes straight to the full form.
Assurance phasing
ASSA 5010 sets the assurance timetable for each group (ASSA 5010 paras 9(f)–(i) and 10). For Group 3:
| Reporting year | Financial years starting | What the auditor does |
|---|---|---|
| Year 1 | 1 Jul 2027 – 30 Jun 2028 | Review (limited assurance) of governance, risks and opportunities, scope 1 and 2 emissions, and any s296B statement |
| Years 2 and 3 | 1 Jul 2028 – 30 Jun 2030 | Review of all disclosures |
| Year 4 onwards | On or after 1 Jul 2030 | Audit of all disclosures |
If you lodge the short s296B statement, it is reviewed in Year 1 (ASSA 5010 para 10(a)(iv)). Note the phasing follows the financial year your report covers, not the group label alone: a 31 December entity’s first year (starting 1 January 2028) still falls in the Year 1 window. Treasury’s 2026 consultation asked about changes to assurance requirements, so check for updates before you plan the work.
Records
Sustainability records must be kept for 7 years after the sustainability report they relate to is completed (s286A(2)). For a 30 June entity that completes its first report in October 2028, that runs to late 2035.
Changes in progress
- 23 August – 5 October 2026: Treasury consulted on improving the efficiency of climate-related financial disclosures, including assurance changes and guidance on the “no material climate-related risks or opportunities” statement. The consultation has closed; check Treasury’s consultation page for any outcome.
- 19 October – 2 November 2026: Treasury released a draft regulation for consultation on 19 October 2026 proposing that the higher thresholds (A$100m revenue and A$50m gross assets, employees unchanged at 100) apply from financial years starting on or after 1 July 2027 (Treasury consultation; exposure draft, Schs 1–2). It is a draft and not yet law proposed, not law.
Plan on current law until a change is actually made. If it is, entities between the current and proposed thresholds may drop out of Group 3, and the timeline above would no longer apply to them.
A suggested working timeline for a 30 June entity
This is our suggestion, not a legal requirement:
- By early 2027: test Group 3 status on forecasts for the year to 30 June 2028, using the free tester, and brief the board.
- By 1 July 2027: set the reporting entity, time horizons and who owns the work, and start the evidence file.
- July 2027 – March 2028: run the materiality assessment, record the judgements and agree the evidence approach with your auditor.
- April – June 2028: draft the statement or disclosures, and update for any events in the year.
- July – October 2028: re-test status on actual figures, finalise, obtain the auditor’s review, pass the directors’ resolution and lodge with the financial report.
- Every year after: reassess materiality and status (RG 280.76).
Frequently asked questions
When does a 31 December year-end company first report under Group 3?
For the financial year starting 1 January 2028, because that is its first year starting on or after 1 July 2027 (s1707B(1)(c)). If it isn’t a disclosing entity, the report is due by 30 April 2029 (s319(3)).
Is the sustainability report lodged separately from the financial report?
It is a separate report, but ASIC expects the two to be lodged at the same time and cover the same period (RG 280.95).
When does full audit of climate reports start for Group 3?
For financial years starting on or after 1 July 2030. Before that, Group 3 reports are reviewed (limited assurance) under ASSA 5010.
Could the dates change?
Yes. Treasury has consulted on assurance changes and is consulting on raising the thresholds. The threshold change is still a draft, and we know of no change to the Group 3 assurance timetable as at 22 October 2026.
Sources
Pinpoints in this guide: “s” is a section of the Corporations Act 2001; “reg” is a regulation of the Corporations Regulations 2001; “RG 280.x” is a paragraph of ASIC Regulatory Guide 280. All sources were opened and checked on 22 October 2026.
- Corporations Act 2001 (Cth), current compilation, Federal Register of Legislation
- ASIC, Regulatory Guide 280 Sustainability reporting (March 2025)
- AUASB, ASSA 5010 Timeline for Audits and Reviews of Information in Sustainability Reports under the Corporations Act 2001 (compilation, December 2025)
- Treasury consultation, ‘Improving the efficiency of climate-related financial disclosures’ (23 August – 5 October 2026), including the consultation paper
- Treasury consultation, ‘Raising the reporting threshold for large proprietary companies’ (opened 19 October 2026, closes 2 November 2026), with the exposure draft regulation and explanatory statement
More guides
General information only. This is not legal, accounting or assurance advice. The kit and this website don’t take account of your circumstances. Whether your entity has no material climate-related risks or opportunities depends on your own facts and the judgement of your directors. Confirm your approach with your auditor or adviser before relying on it. Using the kit doesn’t guarantee compliance or any audit outcome.
The 2026–27 Budget proposal to lift the thresholds to A$100m revenue and A$50m gross assets is proposed, not law. Law and sources last verified 22 October 2026.