This Standard is narrowly focused on greenhouse gas emissions disclosure mechanics and classification within AASB S2. The central concepts are:

• Scope 3 Category 15 and financed emissions: Scope 3 Category 15 refers to value‑chain emissions from investments and financing activities. Paragraph 29A allows an entity, when preparing Scope 3 disclosures, to limit Category 15 to financed emissions attributable to loans and investments (loans, project finance, bonds, equity, undrawn loan commitments). For asset managers, financed emissions include emissions attributed to assets under management. Paragraph 29A also permits excluding emissions attributable to derivatives. If the limitation is applied, paragraph 29B requires explanation of what the entity treated as a derivative and description of the financial activities excluded; paragraph 29C requires disclosure of total Category 15 emissions and the subtotal of financed emissions where Category 15 is included at all.

• Industry classification for disaggregation of financed emissions: Previously, commercial banking and insurance financed‑emissions disclosures required use of GICS 6‑digit codes (see prior B62(a)(i), B63(a)(i)). The amending Standard removes the mandatory GICS instruction in favour of a requirement to select an industry‑classification system that enables users to understand exposure to climate‑related transition risks, and to prioritise a system commonly used by peers for comparability (paragraphs B62A(a)(i)-(ii), B63A(a)(i)-(ii)). Entities participating in both banking and insurance activities need not use the same classification system across both (B62A(a)(i), B63A(a)(i)).

• Measurement methods and jurisdictional relief: The Standard retains the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) as the default method (paragraph 29(a)(ii), B23-B24) but clarifies relief where a jurisdictional authority or exchange requires a different method. Relief is available only for the part of the entity to which the jurisdictional/exchange requirement applies, and only for as long as that requirement applies (B24). The Guidance (B23) also states application of the Protocol only to the extent it does not conflict with this Standard.

• Global warming potential (GWP) aggregation rules and relief: Aggregation into CO2‑equivalent is required (B20). Entities using direct measurement must use GWP values based on a 100‑year time horizon from the latest IPCC assessment at the reporting date, except where a jurisdictional authority or exchange requires different GWP values for part of the entity, in which case the entity may use the jurisdictional/exchange values for that part for as long as the requirement applies (B21). For emission factors, if the chosen factors are already expressed in CO2e the entity need not recalculate them using the IPCC values; if not, the IPCC 100‑year values must be used unless jurisdictional/exchange requirements override for a part (B22).

• Disclosure of measurement approach, inputs and assumptions: Paragraph 29(a)(iii) and guidance at B26 require entities to disclose the measurement approach, inputs and assumptions used, and B28 requires entities to disclose the alternative method used and reasons when a method other than the GHG Protocol is applied for part(s) of the entity.

• Transition reliefs and comparative information: The Standard preserves and clarifies transition reliefs. In particular, C4(b) allows an entity in its first annual reporting period applying AASB S2 to refrain from disclosing Scope 3 emissions (including financed emissions details). C6 requires, unless impracticable, adjustments to comparative information where measurement methods or classification choices change as a result of the amendments.

These concepts operate together. The Standard defines where prescriptive, where permissive, and where a jurisdictional or exchange requirement can alter the measurement or aggregation approach for parts of an entity. It also defines specific disclosure obligations required when entities rely on the available reliefs (29B-29C; B28; B62A/B63A; C6).

The Standard targets entities that prepare climate‑related disclosures under AASB S2. The AASB states the Standard supports Corporations Act requirements for "large businesses and financial institutions" to prepare mandatory climate‑related financial reporting; accordingly, the immediate affected population is entities that fall into those statutory categories and that must apply AASB S2 (Basis for Conclusions; Impact analysis; Effective date and transition). More specifically the Standard affects:

• Entities that report Scope 3 greenhouse gas emissions and, in particular, those that have material Category 15 exposures: entities with loan, investment, asset management, commercial banking, or insurance activities (paragraphs 29(a)(i)(3); 29A; B59-B63A). Asset managers, commercial banks and insurers are explicitly named as needing to disclose additional information about financed emissions unless they apply permitted relief.

• Entities subject to jurisdictional authority or exchange requirements that dictate measurement methods or GWP values for parts of their operations: the Standard permits such entities to use the jurisdiction/exchange‑mandated method or GWP values for the affected part(s) and for as long as the mandate applies (B21-B24).

• Entities that previously applied AASB S2 and now change measurement approaches or classification systems as a result of these amendments: transitional provisions require comparative adjustments unless impracticable (C6).

• Preparers and auditors: the Standard creates new disclosure tasks and documentation requirements (for example, explanatory notes about derivative treatment under paragraph 29B, and selection and justification of an industry classification system under B62A/B63A). Auditors and assurance providers working on sustainability reports will face additional work to confirm compliance with the new disclosure and explanatory requirements.

• Users of general purpose financial reports: while users are not regulated by the Standard, they are the intended audience; the Standard alters the content and comparability profile of disclosures that users rely on for assessing financed emissions and transition‑risk exposure, particularly where entities select different classification systems or rely on jurisdictional reliefs.

• Entities preparing financial reporting across multiple jurisdictions and exchanges: those with parts required to comply with non‑Protocol measurement methods or different GWP values will need to combine differing measurement bases in a single disclosure environment and explain where different bases apply (B21-B24).

Entities not in scope of AASB S2 are not affected by this amending Standard directly. The AASB emphasises that the amendments do not relieve entities from other climate‑related reporting requirements or from providing information about transition risks or climate targets that users may need (Basis for Conclusions, BC6). The Standard also notes alignment with international ISSB amendments to IFRS S2, so entities subject to IFRS S2 elsewhere will see parallel changes (Preface).

The Standard establishes duties (required disclosures and obligations) and rights (permitted reliefs and choices). The key duties and rights are paragraph‑level and specific:

Duties (obligations to disclose or do):

• Disclose absolute gross GHG emissions expressed in metric tonnes of CO2e, aggregated across the seven constituent greenhouse gases (paragraph 29(a); guidance B20). When emission factors are used that are already converted to CO2e the entity need not reconvert (B22).

• Measure greenhouse gas emissions in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004), except to the extent a jurisdictional authority or an exchange requires a different method for part of the entity (paragraph 29(a)(ii); B23-B24).

• Disclose Scope 3 greenhouse gas emissions and the categories included, using the Scope 3 categories from the GHG Protocol Corporate Value Chain Standard (paragraph 29(a)(i)(3); 29(a)(vi)(1)).

• For entities participating in asset management, commercial banking or insurance, disclose additional information about financed emissions (paragraph 29(a)(vi)(2); B59-B63A). Specific duties include disclosing financed emissions disaggregated by Scope 1/2/3 for each industry by asset class (B62(a), B63(a)), and gross exposures for each industry by asset class (B62(b), B63(b)). For funded amounts, gross exposure is the funded carrying amount before loss allowance (B62(b)(i), B63(b)(i)); for undrawn loan commitments the full amount must be disclosed separately (B62(b)(ii), B63(b)(ii)).

• Disclose measurement approach, inputs and assumptions used to measure GHG emissions (paragraph 29(a)(iii); guidance at B26).

• Where alternative methods are used for measuring emissions, disclose for each alternative method (a) the applicable method and measurement approach, and (b) the reasons for choosing it and relationship to the disclosure objective (B28).

• If limiting Category 15 to financed emissions under paragraph 29A, explain what has been treated as a derivative and describe the financial activities excluded (29B). If Category 15 is included in Scope 3, disclose the total Category 15 emissions and the financed emissions subtotal (29C).

• Where an entity selects an industry‑classification system for disaggregation, disclose the system used and information enabling users to understand how the selection fulfils the exposure-to-transition-risk requirement (B62A(a)(ii), B63A(a)(ii)).

• Apply the amendments for annual reporting periods beginning on or after 1 January 2027 (C1B), and disclose earlier application if elected (Application; C1B).

Rights (permitted reliefs and choices):

• Elect to limit Scope 3 Category 15 measurement and disclosure to financed emissions only; in doing so, exclude derivatives and certain financial activities from that measure (29A-29B).

• Use a jurisdictional/exchange‑required measurement method or GWP values for the part(s) of the entity to which the requirement applies, and for as long as the requirement applies (B21-B24).

• Where a commonly used industry‑classification system enables useful information, prioritise that system, but otherwise select any system that meets the requirement to inform users about transition‑risk exposure (B62A(a)(i), B63A(a)(i)).

• Rely on transition reliefs in the first annual reporting period applying AASB S2, notably not disclosing Scope 3 emissions in that initial period if the entity elects the relief (C4(b)).

• For emission factors already expressed in CO2e, avoid recalculating them using the latest IPCC GWP values (B22).

Administrative duties linked to rights:

• The right to limit Category 15 is conditional on explanatory disclosure duties (29B-29C). The right to use jurisdictional/exchange bases is conditional on applying them only to the relevant part and for as long as they apply (B21-B24). The right to select classification systems requires disclosure of the selection and justification (B62A/B63A). Transition reliefs require compliance with C4 and C6 comparative adjustment rules where applicable.

These duties and rights change the compliance perimeter: entities gain specific reliefs that reduce scope in some cases, but the Standard creates new disclosure obligations whenever an entity uses a relief or alternative method. The text is granular about the boundaries of relief (for parts of an entity and for the duration of the external requirement) and about mandatory disclosures that accompany each relief.

The amending Standard itself does not set out civil or criminal penalties. The Standard is made by the AASB under section 336A of the Corporations Act 2001 (prefatory material) and is intended to support statutory disclosure obligations established through the Corporations Act and related Treasury instruments. The document states that the AASB issued AASB S2 to "support the Corporations Act 2001 requirements for large businesses and financial institutions to prepare climate‑related financial disclosures" (Impact analysis; Effective date and transition).

What the Standard records about enforcement and legal effect is limited to:

• statutory footing and alignment: the Standard is issued under the Corporations Act power referenced above (front matter), and the effective/application dates are aligned with the application framework specified in the Corporations Act as amended by Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024 (Effective date and transition). The Standard therefore supplies technical content that entities must follow when they are required to make disclosures under the Corporations Act regime.

• commencement and application dates: the instrument states it commences for legal purposes on 31 December 2026 (Commencement of the legislation) and applies to annual reporting periods beginning on or after 1 January 2027 (Application; C1B). Earlier application is permitted but must be disclosed (Application; C1B).

The Standard does not describe which regulatory body will enforce compliance, what remedies apply for breach, or specific penalty amounts. Those enforcement mechanisms and sanctions, if any, will derive from the Corporations Act and the wider corporate reporting and market regulation framework, not from the Standard itself. The Basis for Conclusions notes the AASB was advised that regulatory impact assessments were performed by Treasury and that the AASB did not need to undertake a separate impact analysis (Impact analysis), but it does not translate that into enforcement modalities.

Practical implication for preparers and advisers: compliance with the Standard is a technical (and potentially litigable) element of compliance with statutory disclosure obligations under the Corporations Act. The Standard contains prescriptive disclosure requirements and conditional reliefs; failure to make required disclosures or to make required explanatory disclosures when relying on reliefs would affect the content of a general purpose financial report prepared in accordance with AASB S2. Any enforcement or sanction consequences must be sought in the Corporations Act and related regulation and policy materials rather than in the amending Standard text.

The Standard is an Australian sustainability reporting standard issued in the context of a statutory regime. The text identifies several statutory and regulatory intersections:

• Corporations Act 2001: The Standard is made under section 336A of the Corporations Act 2001 (front matter). The Basis for Conclusions repeatedly links the Standard to Corporations Act requirements for mandatory climate‑related reporting for large businesses and financial institutions (Impact analysis; Effective date and transition). The AASB expressly positions the Standard as supporting the statutory timetable and coverage set by those legislative amendments (Effective date and transition).

• Jurisdictional authority and exchange requirements: Multiple provisions carve out or permit departures from the default measurement and aggregation rules where a jurisdictional authority or an exchange on which the entity is listed requires a different method or GWP values. The relief applies "only to the part of the entity to which that jurisdictional authority or exchange requirement applies, for as long as that requirement applies to that part of the entity" (paragraphs B21-B24). Practically, this forces entities operating in multiple jurisdictions or with different exchange listings to map which parts of their operations are covered by external mandates and to reconcile and disclose multiple measurement bases.

• Greenhouse Gas Protocols and IPCC: The Standard relies on the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) as default measurement guidance (29(a)(ii); B23-B24). It also requires aggregation into CO2e using IPCC 100‑year GWP values where direct measurement is used or where emission factors are not already expressed in CO2e, except where jurisdictional/exchange mandates require otherwise (B20-B22). Thus the Standard embeds external international technical references while allowing jurisdictional exceptions.

• National Greenhouse and Energy Reporting Scheme (NGERS): The Basis for Conclusions records that stakeholders considered permitting jurisdictional GWP values to align with national frameworks such as Australia’s NGERS a practical solution that reduces duplication of effort (BC2). Although the Standard does not directly amend NGERS, it recognises practical interaction and permits use of jurisdictional GWP values where required for parts of an entity (B21-B22, Basis for Conclusions).

• IFRS S2 / ISSB standards: AASB S2025-1 tracks amendments the ISSB made to IFRS S2 in December 2025; the AASB explicitly notes the amendments are the same as those made by the ISSB and that alignment with IFRS S2 is intended (Preface; Objective; Basis for Conclusions). Entities regulated under both Australian and international regimes will see consistent technical requirements.

• Australian Accounting Standards and GAAP: Paragraph 29B gives an example that an entity could explain derivative treatment by reference to the definition of a derivative "in accordance with the requirements of Australian Accounting Standards or other applicable generally accepted accounting principles or practices (GAAP) used in preparing its related financial statements." That cross‑references existing accounting standards and general purpose financial reporting practices (29B).

Where the Standard permits a jurisdictional/exchange requirement to override default Protocol or IPCC bases for parts of an entity, those external legal or listing requirements will determine the method or GWP values for the relevant part; the Standard requires explanatory disclosure for the remainder of the entity to maintain transparency. The Standard also imposes comparability and disclosure obligations when different bases are used (B28; C6).

Because the amending Standard is technical guidance intended to be followed by entities obliged under statute to make climate disclosures, it sits within the statutory architecture set by the Corporations Act and regulated market listing rules. The Standard itself does not change or create statutory offences or alter the scope of other regulatory regimes; instead it prescribes the content of disclosures that statutory regimes require or that entities elect to make under AASB S2.

AASB S2025-1 is an amending Standard with a short, well documented history in the materials provided:

• AASB S2: The parent Standard, Australian Sustainability Reporting Standard AASB S2 Climate-related Disclosures, was issued in September 2024. AASB S2025-1 makes targeted amendments to that Standard (Preface: "This Standard makes amendments to Australian Sustainability Reporting Standard AASB S2 Climate-related Disclosures (September 2024)").

• ISSB timing and AASB response: The amendments follow ISSB amendments to IFRS S2 in December 2025. The AASB mirrored those ISSB amendments to preserve alignment (Preface; Objective; Basis for Conclusions).

• Issuance date and authority: AASB S2025-1 was issued by the AASB and is dated 15 December 2025, signed by the AASB Chair (Australian Sustainability Reporting Standard AASB S2025-1, dated 15 December 2025; front matter). The Standard states it is made under section 336A of the Corporations Act 2001 (front matter).

• Amendment mechanics and paragraph changes: The Standard lists precise paragraph changes. C1A summarises the amendments and records that the Standard (issued December 2025): (a) amended paragraphs 29(a)(ii), 29(a)(vi)(2), B21-B22, B24, B28, B37, B59, B62(a), B63(a) and C4(b) and the heading before paragraph B26; (b) added paragraphs 29A-29C, B62A, B63A, C1B and C6; and (c) deleted paragraph AusB63.1 (C1A).

• Application and earlier application: The Standard applies to annual reporting periods beginning on or after 1 January 2027 (Application; C1B). Entities may apply it earlier to annual periods beginning on or after 1 January 2025 but before 1 January 2027, subject to disclosure that they did so (Application).

• Commencement for legal purposes: The legislative instrument is recorded as commencing on 31 December 2026 (Commencement of the legislation).

• Transition provisions: The Standard incorporates transition reliefs already present in AASB S2 and adds amendments regarding comparatives (C4; C6). C4 lists permitted reliefs in the first annual reporting period in which an entity applies the Standard; C6 requires, unless impracticable, adjustment of comparative information where measurement or classification has changed as a result of applying these amendments.

• Deleted material: AusB63.1, which had defined the GICS version to August 2024 for certain paragraphs, is deleted by this amending Standard (C1A(c) notes the deletion).

• Consistency with international amendments: The AASB emphasises that the amendments are the same as the ISSB's amendments to IFRS S2, and that alignment was an objective (Preface; Basis for Conclusions).

The amendment history in the text is explicit and paragraph‑specific, enabling practitioners to track exactly which portions of AASB S2 were altered, the new paragraphs to be followed (29A-29C; B62A; B63A; C1B; C6), and the deleted paragraph. The Standard also retains earlier transition reliefs from initial application of AASB S2 while introducing the new targeted reliefs described above.

The amending Standard document and its Basis for Conclusions do not record any litigation history. There are no cases, court decisions, or administrative enforcement proceedings cited in the instrument or accompanying materials. The AASB’s Basis for Conclusions summarises stakeholder consultation and comments (BC1-BC8) but does not reference any litigation or formal disputes.

Although no litigation history is recorded in the source, the Standard contains provisions that are likely to be the subject of interpretative disputes in practice. The Basis for Conclusions records stakeholder concerns and application challenges that motivated the amendments (BC1-BC6). Areas where interpretive disagreements could arise include:

• the scope of the permitted limitation of Category 15 to financed emissions: paragraph 29A defines financed emissions specifically, but what counts operationally as "loans and investments" or which derivatives are excluded may be contested in application. Paragraph 29B requires explanation of what the entity treated as a derivative, which may be the locus of disputes between preparers, auditors and users.

• the meaning of "part of the entity" for which a jurisdictional or exchange requirement applies: B21-B24 allow use of alternative measurement methods or GWP values for the part of the entity covered by external mandates. Disputes could arise over how to map legal, operational or reporting entities to the Standard’s "part of the entity" concept.

• classification system selection and comparability: B62A/B63A allow entities to select classification systems that enable disclosure of exposure to transition risks, with a prioritisation of commonly used systems. Disagreements may appear over whether a system chosen is "commonly used" or whether the disclosed justification adequately explains the system’s suitability.

• use of emission factors already expressed in CO2e: paragraph B22 permits use of emission factors already in CO2e without reconversion. Audit and assurance queries may focus on provenance, vintage and appropriateness of those factors.

Because the Standard is intended to be applied within a statutory reporting framework, legal disputes about compliance, adequacy of disclosures, or the substance of choices made under the Standard (e.g., selection of methods, classification systems, or treatment of derivatives) would likely be litigated or subject to administrative review under the Corporations Act or other applicable legislation, not under the Standard itself. The source does not record any such litigation to date.

This Standard introduces targeted reliefs but also creates precise disclosure conditions and potential practical pitfalls. The following "gotchas" are grounded in the text and highlight operational risks and potential compliance mistakes:

• Relief is part‑specific and time‑limited: jurisdictional/exchange relief from using the GHG Protocol or IPCC GWP values applies only "for the part of the entity to which that requirement applies, for as long as that requirement applies to that part of the entity" (B21, B24). Common mistake: treating the relief as global to the whole group rather than mapping it to the specific legal or operational parts covered by the external requirement.

• Derivatives must be explained if excluded: paragraph 29A permits excluding emissions attributable to derivatives, but paragraph 29B requires the entity to explain what it treated as a derivative and to describe excluded financial activities. Practical risk: failing to document and disclose derivative treatment, or using an unexplained ad hoc definition that auditors or users challenge.

• If you include Category 15, you must split financed emissions and disclose totals: paragraph 29C requires disclosure of the total Category 15 emissions and the financed emissions subtotal. Misstep: disclosing only the financed emissions subtotal without stating the total Category 15 or clarifying whether other Category 15 elements have been excluded.

• Classification system selection carries justification duties: replacing a mandatory GICS rule with a selection duty (B62A/B63A) reduces prescriptiveness but adds a documentation duty. Entities must state the system used and explain why it enables users to understand exposure to transition risk. Practical error: choosing an entity‑specific system that undermines comparability and failing to justify why it provides useful information.

• Deletion of fixed GICS version: AusB63.1 (which fixed the GICS version to August 2024) is deleted (C1A(c)). Entities cannot rely on a fixed GICS version in the Standard; if still using GICS they must state the version and ensure it is the latest appropriate version or justify a different choice under B62A/B63A.

• Emission factors: if emission factors are already in CO2e you need not reconvert using IPCC 100‑year GWPs; if they are not, you must use the IPCC 100‑year values (B22). Risk: misreading B22 and failing to convert or to document the provenance and vintage of emission factors used.

• Transition reliefs may be misapplied or over‑relied upon: C4(b) permits an entity in the first annual reporting period that applies AASB S2 to omit Scope 3 disclosures. This relief applies only in that first period; incorrect continued reliance or failure to disclose that the relief was used will cause disclosure gaps.

• Comparative adjustments are required unless impracticable: C6 requires adjustment of comparative information when measurement methods change due to the reliefs, and also requires restating previous financed‑emissions industry disaggregation to reflect the new classification system selected. Failing to adjust comparatives, or to explain why adjustment is impracticable, will create comparability and audit problems.

• Multiple measurement bases across jurisdictions: where parts of an entity are subject to different jurisdictional requirements, the entity may end up presenting emissions measured under different methods and different GWP bases in the same report. This increases complexity of reconciliation and explanation (B21-B24; B28). Inadequate reconciliation or unclear labelling will confuse users.

• Disaggregation granularity and exposure measures: for commercial banking and insurance financed emissions, the Standard requires disaggregation by Scope 1/2/3 for each industry by asset class, and gross exposure measures for funded amounts and undrawn commitments (B62(a), B62(b); B63(a), B63(b)). Practically, this can be data‑intensive and involves mapping loans and investments to single industry codes and asset classes. Mis‑classification or inconsistent mapping across years can undermine usefulness and trigger audit queries.

• Documentation burden when using reliefs: the Standard’s reliefs are conditional on disclosure and justification. Entities that reduce scope of measurement still face documentation and narrative disclosure duties that may be non‑trivial to satisfy (29B, 29C, B62A, B63A, B28).

• No enforcement detail in the Standard: the Standard does not set out enforcement mechanisms or penalties; those are available in the Corporations Act and related rules. Entities must therefore coordinate legal, statutory and technical teams to ensure disclosures meet statutory obligations that rely on the Standard for technical content (prefatory material; Impact analysis).

• Timing mismatch with reporting cycles: the application date is annual reporting periods beginning on or after 1 January 2027 (C1B), but earlier application is permitted (Application). Entities with multiple reporting calendars, or with subsidiaries on different regulatory timetables, must plan the mechanics of applying the amendments and the comparative restatement rules.

Each of these points arises directly from the Standard’s paragraphs. The practical upshot is that the Standard reduces some measurement obligations but replaces them with specific conditional disclosures, classification choices and reconciliation duties that can be complex to operationalise and to assure.

The Standard contains explicit disclosure requirements, conditional reliefs and transition rules. A practical compliance roadmap, grounded in the Standard’s paragraphs, covers governance, measurement, classification, disclosure text, reconciliations and audit/assurance preparation.

1. Governance and project scoping

   • Identify whether your entity is within the statutory population required to apply AASB S2. The AASB links the Standard to Corporations Act requirements for large businesses and financial institutions; check the specific Corporations Act application date that applies to your entity (Effective date and transition; Impact analysis).
   • Map the entity structure to identify parts subject to jurisdictional or exchange requirements that mandate a measurement method or GWP values. The relief in B21-B24 applies only to the part(s) covered by such external requirements and only while the requirement applies.
   • Establish a cross‑functional team (accounting, risk, legal, finance, sustainability, IT) to plan data collection, classification and disclosure drafting.

2. Decide whether to limit Category 15 to financed emissions

   • Consider the relief in paragraph 29A that permits limiting Scope 3 Category 15 to financed emissions attributable to loans, project finance, bonds, equity investments and undrawn loan commitments.
   • If electing the relief, implement processes to identify financed emissions and to exclude derivatives and other financial activities explicitly. Prepare the explanatory disclosure required by paragraph 29B: define what you treated as a derivative (reference Australian Accounting Standards or other GAAP if helpful) and list the financial activities excluded from the Category 15 measure.
   • If the entity nonetheless includes other Category 15 elements, ensure the disclosure required by paragraph 29C appears: total Category 15 emissions and the subtotal of financed emissions.

3. Measurement method and emission factors

   • Default approach: plan to apply the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) for measuring emissions, except where a jurisdictional or exchange requirement specifies otherwise (29(a)(ii); B23-B24).
   • If parts of your operations are subject to jurisdictional/exchange‑mandated methods, document which part(s) are covered and apply the mandated method for those part(s). For the residual parts, apply the Protocol. Disclose the alternative method(s) and the reasons for choice as required by B28.
   • For direct measurement, adopt IPCC 100‑year GWP values from the latest assessment at the reporting date unless you have a jurisdictional or exchange rule otherwise for a part of the entity (B21). For emission factors, if the factor is already converted to CO2e you can use it as is; if not, convert using the IPCC 100‑year values unless a jurisdictional/exchange requirement applies (B22). Keep provenance, vintage and metadata of emission factors in documented form.

4. Industry classification and financed‑emissions disaggregation

   • If you operate in commercial banking or insurance activities, plan the disaggregation required by B62/B63: absolute gross financed emissions disaggregated by Scope 1/2/3 for each industry by asset class; and gross exposure by industry and asset class (including funded carrying amounts and undrawn commitments).
   • Select an industry‑classification system in line with B62A/B63A. If a commonly used system (e.g., GICS or local equivalents) enables you to provide information about exposure to transition risk, the Standard says you should prioritise that system for comparability; if a different system better meets the disclosure objective you can use it but must disclose the system chosen and explain why it fulfils the requirement.
   • Prepare mapping rules from investees/counterparties to the chosen industry classification and asset classes (loans, bonds, equity, project finance, undrawn commitments). Document exceptions and judgement calls.

5. Disclosures about measurement approach, inputs and assumptions

   • Prepare the disclosures required under paragraph 29(a)(iii) and guidance at B26: measurement approach, key inputs and assumptions, data sources, use of estimates, and any models employed.
   • If an alternative method is used, comply with B28: disclose each alternative method and measurement approach used, and explain the reasons and relationship to the disclosure objective in paragraph 27.
   • If using reliefs (e.g., limiting Category 15), include the accompanying narrative obligations (29B-29C).

6. Transition and comparative information

   • If you are applying AASB S2025-1 earlier than 1 January 2027, disclose that earlier application as required (Application; C1B).
   • If the amendment changes how you measure GHG emissions or how you classify financed emissions, plan to adjust comparative information for the preceding period as required by C6 unless it is impracticable. C6 lists specific circumstances requiring adjustment (changes in measurement method due to jurisdictional relief; restating Category 15 disclosure to show totals and financed subtotals; reflect selected industry‑classification system in prior‑period comparatives for disaggregated financed emissions).
   • If you elect the initial transition relief in C4(b) not to disclose Scope 3 in the first reporting period, document that election and ensure it is used only in the permitted first annual reporting period.

7. Records and audit readiness

   • Maintain documented evidence for all measurement choices: data sources, emission factors (including whether already in CO2e), GWP values used and their provenance, mapping to industry codes, and the rationale for any chosen alternative classification system.
   • Prepare reconciliations between parts of the entity measured under different methods or GWP bases, with clear labelling in the report of which parts use which methods and why (B21-B24; B28).
   • For derivatives and excluded financial activities, maintain legal and accounting documentation that supports the entity’s delineation and the public explanation required by 29B.
   • Anticipate assurance queries about the selection of classification systems and the appropriateness of measurement approaches; ensure the Board or equivalent governance body has formally approved the chosen approaches and the disclosures.

8. Disclosure drafting checklist (minimum items to cover in the sustainability/notes section)

   • Absolute gross GHG emissions in metric tonnes CO2e and aggregation approach (29(a); B20).
   • Scope 3 categories included and whether Category 15 is limited to financed emissions (29(a)(i)(3); 29A-29C).
   • If alternative methods or GWP values are used for parts of the entity, identify the parts and disclose the method/GWP values and justification (B21-B24; B28).
   • The measurement approach, key inputs and assumptions, provenance of emission factors, and how estimates were determined (29(a)(iii); B26).
   • For financial activities: financed emissions by Scope and industry by asset class, gross exposures (B62-B63).
   • The industry‑classification system used, and explanation of how it enables users to understand exposure to transition risk (B62A/B63A).
   • If early application occurred, disclose that fact (Application; C1B).
   • Comparative restatements and explanations of any impracticability to restate (C6).
   • Explanations of derivative treatment and excluded activities where paragraph 29A relief has been used (29B).

9. Practical sequencing and timing

   • Start early: mapping loans/investments to industries and asset classes typically needs time and coordination with credit/portfolio teams.
   • Prioritise data governance for financed emissions: data quality, counterparty identification, and consistency over time are critical to satisfying the disclosure objective.
   • Coordinate legal review of jurisdictional/exchange mandates to determine whether parts of the entity are subject to alternative measurement methods or GWP values.

10. Assurance and disclosure controls

    • Put internal control procedures around source data and conversions, ensure versioning of emission factors and classification mappings, and prepare a summary of key judgements for auditors.
    • Where multiple methods/GWP bases are applied across parts of the entity, develop a reconciled roll‑forward and labelling protocol so report readers and assurance providers can trace totals and subtotals back to source systems.

These steps follow the Standard’s explicit paragraphs (29A-29C, B21-B28, B37, B59-B63A, C1A-C6) and the Basis for Conclusions which describes the stakeholder feedback that motivated these particular amendments (Basis for Conclusions). Implementing them will create an auditable trail and satisfy the narrative and numerical disclosure obligations the Standard imposes when reliefs are used.