The transition period is over. As of 2025, Australia’s mandatory climate-related reporting requirements are now in full swing for large organisations, marking a crucial turning point in corporate sustainability reporting. With medium-sized organisations set to begin their reporting journey in 2026, and smaller firms following in 2027, organisations across the country are adapting to this new reality. Here’s what you need to know about the current state of ESG reporting and how to ensure your organisation’s compliance.
Current State of ESG Implementation
Our survey last year, of companies across Australia revealed both progress and persistent challenges in ESG integration:
Resource Allocation Remains Critical
The shift from voluntary to mandatory reporting has pushed organisations to reassess their resource allocation. While some organisations have successfully established dedicated ESG teams, others continue to struggle with distributing responsibilities among staff already working at capacity, creating double hat roles. The mandate has made it clear: ESG can no longer be treated as a side project.
Data Systems Under Scrutiny
With reporting now mandatory, organisations are facing the reality of their data capture capabilities. Organisations with established systems are finding themselves at an advantage, while others are rushing to implement robust tracking mechanisms. The focus has shifted from “Should we track this?” to “How can we track this more effectively?”
Scope 3 Emissions: The Next Frontier
While large organisations are now required to report on their direct emissions, the upcoming Scope 3 reporting requirements have created a new sense of urgency. Companies are actively mapping their value chains and establishing partnerships to ensure accurate tracking of indirect emissions, with the three-year litigation protection period providing some breathing room for refinement.
Meeting Current Requirements
Under the Treasury Laws Amendment Bill, organisations meeting any of these criteria must now comply with mandatory reporting:
- Over 500 employees
- More than $500 million in revenue
- Over $1 billion in assets
The requirements align with International Sustainability Standards Board (ISSB) guidelines and include:
- Detailed climate risk assessments
- Greenhouse gas emissions reporting
- Value chain impact analysis
- Transition planning documentation
The Path Forward
As we move through 2025, we expect several key trends to emerge:
Integration Over Isolation
Leading organisations are moving beyond treating ESG as a separate reporting exercise. Instead, they’re integrating sustainability considerations into core business strategies and operations. As Cecile Walton, Senior ESG Practitioner and Advisor, notes: “It’s about fundamentally changing how you operate your business to play a meaningful role in society.”
Board Capability Requirements
A key governance requirement under the new regulations is demonstrating appropriate climate capability at the board level. Rather than appointing new directors, many organisations are opting for comprehensive training programmes to build internal expertise. This “build versus buy” approach satisfies regulatory requirements while creating internal climate competency.
Technology Investment
Organisations are increasingly investing in sophisticated data management systems to streamline reporting processes. This investment is proving crucial for maintaining accuracy and efficiency in mandatory reporting requirements.
Talent Development
With the demand for ESG expertise at an all-time high, organisations are focusing on both hiring specialists and upskilling existing staff to ensure comprehensive coverage of sustainability initiatives.
Immediate Actions for Organisations
- Audit your current reporting capabilities against mandatory requirements
- Identify and address gaps in data collection systems
- Ensure adequate staffing for ESG initiatives
- Begin preparing for Scope 3 reporting requirements
- Review and update sustainability strategies to align with new regulatory frameworks
Current Market Trends and Looking Ahead
As medium-sized organisations prepare for their 2026 reporting requirements, and smaller firms look toward 2027, we’re seeing several key market adaptations:
Rise of the Interim CSO
A growing trend among companies is the engagement of interim Chief Sustainability Officers on fixed-term contracts. This strategic approach bridges the gap between consulting services and permanent hires, offering:
- Immediate risk mitigation through established frameworks
- Cost-effective execution at 30-50% lower cost than full-time hires
- Knowledge transfer that builds internal capabilities
- Capital-efficient investment with clear ROI metrics
Strategic Implementation Approaches
Organisations are increasingly taking a staged approach to building their sustainability functions:
- Moving beyond high-cost consulting strategies to practical implementation
- Establishing clear frameworks and robust reporting mechanisms before committing to permanent roles
- Developing internal capabilities through knowledge transfer
- Creating sustainable governance structures that protect and enhance shareholder value
Regulatory Evolution
The Net Zero Economy Authority continues to support this transition, particularly in emissions-heavy industries, while encouraging investment in clean energy initiatives. As requirements evolve, organisations are finding that flexible resourcing models allow them to adapt more effectively to changing demands.
How Moir Group Can Help
As these requirements take effect, Moir Group’s ESG Division offers immediate support for organisations navigating the new reporting landscape:
- Access to immediately available interim CSOs and ESG professionals
- Implementation expertise for current reporting requirements
- Strategic guidance on staged capability building
- Support for developing robust reporting mechanisms and governance structures
Contact Moir Group to discuss your organisation’s specific needs and ensure compliance with current requirements.
Moir Group is a specialist finance, accounting and ESG recruitment company. We cover temporary and permanent roles from Assistant Accountant to CFO level. We also recruit Sustainability / ESG Manager roles to Chief Sustainability Officer roles across all industry sectors.
If you have any recruitment needs in your team on a permanent or a temporary basis, we would be delighted to assist. Contact us here.
