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Sustainability reporting

How and when to lodge your sustainability report

An entity that is required to prepare a sustainability report (reporting entity) under Chapter 2M of the Corporations Act 2001 (Corporations Act) must lodge the sustainability report and auditor’s report on the sustainability report with ASIC: see s319 of the Corporations Act.

When sustainability reports must be lodged

Reporting entities must lodge their sustainability report and the auditor’s report on the sustainability report with ASIC:

  • within three months after the end of the financial year for disclosing entities, registered schemes and registrable superannuation entities (RSEs); and
  • within four months after the end of the financial year for other reporting entities,

see s319(3) and s1232(1) of the Corporations Act.

For reporting entities that have a financial year that ends on 31 December 2025, their sustainability report and the auditor’s report on the sustainability report must be lodged by:

  • 31 March 2026 for disclosing entities; and
  • 30 April 2026 for other reporting entities.

For reporting entities that have a financial year that ends on 30 June 2026, their sustainability report and the auditor’s report on the sustainability report must be lodged by:

  • 30 September 2026 for disclosing entities; and
  • 31 October 2026 for other reporting entities.

If a sustainability report is amended after it is lodged with ASIC, the amended report must be lodged with ASIC within 14 days after the amendment and a copy of the amended report must be given free of charge to any member who asks for it: see s322(1) of the Corporations Act.

For more information about the timing of the commencement of the sustainability reporting requirements, see Who must prepare a sustainability report? and Section B of ASIC Regulatory Guide 280 Sustainability reporting (RG 280).

How to lodge sustainability reports

The sustainability report and auditor’s report on the sustainability report must generally be lodged directly with ASIC.

However, a reporting entity that is a listed entity relying on ASIC Corporations (Electronic Lodgement of Financial and Sustainability Reports) Instrument 2016/181 may alternatively lodge those reports electronically with the relevant market operator (i.e. ASX, NSX or SSX). In these circumstances, the relevant market operator has been appointed as agent for ASIC to receive the reports on ASIC’s behalf.

When lodging the sustainability report and auditor’s report on the sustainability report directly with ASIC:

  • Form 398 Copy of sustainability report and auditor’s report must be completed;
  • both reports should be lodged online via the company officeholder, registered agent or auditor portals. Registration is required to obtain access (you only need to register once); and
  • the annual financial report, directors’ report and auditor’s report on the financial report for the same reporting period should be lodged at the same time using Form 388 Copy of financial statements and reports: see paragraph 95 of RG 280 and paragraph 64 of Appendix D of AASB S2 Climate-related Disclosures (AASB S2). For more information on lodging financial reports, see Information sheet 31 Lodgement of financial reports (INFO 31).

Providing sustainability reports to members (or otherwise making them available)

If the reporting entity is a company, disclosing entity, registrable superannuation entity (RSE) or registered scheme, it must provide the sustainability report and auditor’s report on the sustainability report to members: see s314(1)(a) and s314AA(1) of the Corporations Act. This must generally be done:

  • by the earlier of 21 days before the next AGM after the end of the financial year or 4 months after the end of the financial year, if the reporting entity is a public company or otherwise a disclosing entity that is not a registered scheme or retail CCIV;
  • within 3 months after the end of the financial year if the reporting entity is a registered scheme, RSE or retail CCIV; or
  • within 4 months after the end of the financial year if the reporting entity is a large proprietary company,

see s315 and s1232J of the Corporations Act.

Reporting entities that are companies, registered schemes, or retail CCIVs may rely on ASIC Corporations (Disclosing Entities) Instrument 2016/190 for relief from the requirement to report as a disclosing entity if they cease to be a disclosing entity before the reporting deadline for a financial year.

If the reporting entity is a public company, it must lay the sustainability report and the auditor’s report on the sustainability report before members at its annual general meeting (AGM): see Note 1 to s250N(3) of the Corporations Act.

If a reporting entity is not required to provide the sustainability report to members, it must ensure that the sustainability report is publicly available on its website on and after the day on which the sustainability report is lodged with ASIC: see s316B(1) of the Corporations Act.

However, reporting entities that are RSEs must make a copy of their sustainability report and auditor’s report on the sustainability report publicly available on their website on and after the day on which those reports are lodged with ASIC: see s314AA(2) of the Corporations Act.