One of the more practical problems sitting underneath AASB S2 is a question that sounds simple: which entities actually have to report, and when?
The answer is not as easy to find as it should be. ASIC has published cohort lists, but they exist as PDFs with no machine-readable format, and the boundary conditions for Group 1, Group 2, and Group 3 have shifted enough during the transition period that many compliance teams, advisers, and investors are working with incomplete information about who is actually in scope.
This post explains how the cohorts are defined, what the thresholds look like in practice, and why knowing which of your counterparties or clients sits in which group matters for how you use their climate disclosures.
How ASIC has structured the reporting cohorts
AASB S2 mandatory reporting is being phased in across three groups based on entity size and type. The thresholds use a two-of-three test across employees, revenue, and assets.
| Group | Employees | Revenue | Assets | Mandatory from |
|---|---|---|---|---|
| Group 1 | 500+ | AU$1B+ | AU$500M+ | 1 Jan 2025 |
| Group 2 | 250+ | AU$500M+ | AU$250M+ | 1 Jul 2026 |
| Group 3 | TBC | TBC | TBC | 2027 (expected) |
Group 1 covers the largest entities and has been mandatory since the first reporting period beginning on or after 1 January 2025. These are entities with at least 500 employees, at least AU$1 billion in revenue, or at least AU$500 million in consolidated assets. Many ASX 200 companies fell into this group.
Group 2 covers the next tier and becomes mandatory for reporting periods beginning on or after 1 July 2026. The thresholds drop to 250 employees, AU$500 million in revenue, or AU$250 million in assets. This is where the volume sits. Approximately 3,000 entities are estimated to fall into Group 2, including large proprietary companies, foreign-controlled entities above the threshold, and additional listed companies not captured in Group 1.
Group 3 covers smaller listed entities and is expected to become mandatory from 2027, with the precise thresholds and scope still subject to finalisation.
The two-of-three structure means that a company sitting below one threshold can still be in scope if it exceeds the other two. This is where a number of mid-sized entities have been surprised.
Why the cohort question matters beyond your own reporting
If your organisation is not in Group 2 itself, you might assume the AASB S2 question is not yours to worry about yet. That is not necessarily true.
Investors and lenders with significant exposure to Group 2 entities have a data quality problem coming. The AASB S2 disclosures from Group 2 entities will vary in quality, in methodology, and in the reliability of the underlying data. Knowing which of your portfolio or counterparty entities are in Group 2, what their reporting obligations look like, and whether their disclosures can be trusted requires knowing who is in scope and when.
Advisers and auditors working across large client bases face a related problem. Keeping track of which clients are in Group 1, which are in Group 2, and which have edge cases at the threshold boundary is a manual process without a reliable structured data source. ASIC's cohort lists need to be parsed, maintained, and cross-referenced against entity identifiers.
Supply chain and procurement teams at large Group 1 entities are also starting to require Scope 3 data from suppliers. The logical starting point for that request is knowing which of those suppliers has a mandatory reporting obligation already.
What the data problem looks like
ASIC has published lists of entities in each cohort, but these are PDF documents with no API and no stable structure. Matching an entity on the list to an ABN, an ACN, or an ASX ticker requires manual lookup or custom parsing.
The result is that most organisations trying to answer the "who is in scope" question are doing it by hand. Someone in the team finds the ASIC PDF, searches for a company name, and tries to reconcile it with their internal entity records. At small scale this is tedious. At the scale of an investment manager with hundreds of portfolio companies, or a bank with thousands of commercial counterparties, it is not a workable process.
What Tech Compass is building
The entity cohort mapping layer we are building on top of the NGA Factors API does three things.
It maps ASIC cohort classification to ABN and ACN identifiers, so you can look up an entity by its registered business identifiers rather than a company name string. It tracks Group 1 and Group 2 status against the effective reporting dates, so you know not just whether an entity is in scope but when their obligation starts. And it flags threshold boundary cases where an entity's classification is not clear-cut from the published lists.
This sits alongside the existing NGA Factors endpoint. The calculation layer and the entity scope layer are the two foundational pieces that most compliance, advisory, and investment workflows need before they can do anything else with AASB S2 data.
What this does not include
It is worth being direct about the boundaries of what this product covers.
We do not extract or structure the disclosure content from AASB S2 reports themselves. Those filings exist as unstructured PDFs on ASIC Connect. Reliable extraction of Scope 1, Scope 2, and Scope 3 figures from unstructured annual reports and sustainability reports requires an LLM extraction pipeline with human quality assurance, and that is not something we are shipping in this phase.
If you need structured emissions data from existing AASB S2 filings, the options currently are manual extraction, commercial ESG data providers such as Sustainalytics or MSCI ESG, or waiting for ASIC's planned move toward structured XBRL reporting, which will make machine-readable extraction significantly more reliable.
What we provide is the regulatory scope layer and the auditable emission factor layer. Those are the two pieces that are genuinely missing from current tooling.
When the cohort mapping will be available
We are scoping and building the entity cohort mapping layer now, targeting availability before the Group 2 mandatory filing date in July 2026.
If you are working on AASB S2 compliance, advising entities in Group 2, or need to track reporting obligations across a portfolio, the waitlist and documentation are at techcompass.com.au. The NGA Factors API is live now and available on the free tier while the cohort layer is in progress.
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