IFRS S2 first-cycle disclosure observatory
Scope of this page
What it covers. What the first mandatory cycle of ISSB-based reporting actually produced. Two kinds of evidence only: findings published by a regulator reviewing real filings, and reports we have downloaded and read in full ourselves.
What it excludes, deliberately. Vendor surveys, press summaries and secondary write-ups. If we have not read the document, it is not here. That makes this page smaller than it could be and means every line on it can be checked.
Where the sample is thin, and why. The regulator evidence below covers 259 filings. The reports we have read in full number 1, and are Australian, because Australia's Group 1 cohort is the largest body of first-cycle reports currently published. Two other companies' report pages refused automated access while this page was being compiled, so they are absent rather than summarised second-hand. This page grows as more are read.
What the regulator found
The Australian Securities and Investments Commission reviewed the first sustainability reports lodged under Chapter 2M of the Corporations Act: 259 reports for financial years ending 31 December 2025, of which 34 came from listed entities and 225 from unlisted entities, as at 6 May 2026. It published early observations in May 2026 and has said final observations will follow in the second half of 2026.
ASIC's overall tone was positive. It welcomed the first reports, noted an increase in the quantity and quality of climate-related financial information, and commended reports using tables, diagrams and other visual aids. It then set out six areas for improvement.
Disclaimers that undercut the report
ASIC found disclaimers, in or near the sustainability report, telling users not to rely on the information for investment decisions or disclaiming responsibility for its accuracy. Its position is that a disclaimer conflicting with the statutory framework may confuse or mislead users.
Climate risks overlooked that the accounts already showed
Entities did not identify climate risks despite having disclosed related impacts elsewhere in their financial reporting. ASIC noted that the reasonable and supportable information available to an entity includes past events and current conditions, not only forecasts.
Judgements and uncertainties left implicit
Judgements, assumptions and measurement uncertainties were not disclosed clearly enough. ASIC’s framing is that users should not have to draw their own conclusions about them.
Voluntary content obscuring mandatory content
Additional voluntary disclosure is permitted, but ASIC observed cases where it obscured the information actually required by AASB S2.
Cross-referencing done loosely
Entities failed to meet the cross-referencing requirements, including references that were imprecise and references pointing to documents outside the entity’s own reporting.
Targets read too narrowly
Approaches to identifying climate targets varied. ASIC noted the definition extends to targets an entity is required to meet by law or regulation, giving emissions targets under the Safeguard Mechanism as an example.
Read together, five of the six are not about emissions data at all. They are about how the disclosure is written, framed and cross-referenced. The one that is about substance, risk identification, is a criticism that entities did not connect what they already knew from their financial reporting to what they said about climate. That is a records and process problem more than a measurement one.
Reports we have read in full
Each entry below records what the document itself says. Observations are things we could point to on a page, not impressions.
Report read in full
Rio Tinto · 2025 Annual Report, climate extract (34 pages)
Financial year ended 31 December 2025 · Australian Group 1, first wave
Reporting under: AASB S2, Corporations Act Chapter 2M, climate statement under s296D
Source document (PDF)
Assurance went beyond the phase-in minimum
KPMG provided reasonable assurance over Scope 1 and Scope 2 emissions, limited assurance over Scope 3 emissions, and limited assurance over progress reporting against the Climate Action Plan. The assurance statement is included in the report. Reasonable assurance on Scope 1 and 2 in a first cycle is well ahead of what the Australian phase-in requires.
Adoption itself appeared as a governance item
The board committee record lists overseeing "adoption and implementation of the Australian climate reporting standards (AASB S2)" among its activities for the year. The act of getting ready to report was itself minuted as oversight.
A group-scope relief was obtained and disclosed
The directors’ declaration records ASIC relief permitting the sustainability report to relate to the Rio Tinto Group as a whole rather than only Rio Tinto Limited and its subsidiaries. A reminder that entity-scope questions are resolved by the regulator, not by the standard.
Scope 3 methodology was pushed into a separate document
Scope 3 is discussed throughout, with the calculation methodology published as a separate emissions methodology addendum rather than inside the climate report.
Amendments not yet adopted were flagged anyway
The report notes proposed updates to IFRS S2 guidance covering energy from power purchase agreements, renewable energy certificates and self-generation, and states explicitly that those revisions have not yet been formally adopted.
What can and cannot be concluded yet
Can be said. The regulator's first pass found the weak points in presentation and framing rather than in the numbers. Cross-referencing, disclaimers and unclear judgements are all failures of disclosure discipline. They are also, notably, the cheapest category of finding to fix and the easiest to avoid with a decent record of how the report was assembled.
Can be said. At least one first-wave reporter obtained reasonable assurance over Scope 1 and 2 in year one, well beyond the phase-in minimum. First-cycle assurance is not uniformly minimal.
Cannot be said yet. Anything about typical practice. 1 report read in full is an example, not a sample, and the regulator evidence is one jurisdiction. Anyone telling you what "most" first-cycle reporters did, on the basis of the reports published so far, is extrapolating further than the evidence goes.
Method
Regulator findings are taken from the regulator's own publication, linked above, not from coverage of it. Company reports are downloaded and read in full; observations record what the document states, with the source document linked so you can check. Where a company's site refuses automated access, the report is left out rather than summarised from a third party. Numbers quoted are the numbers the source gives.
We do not rank, score or grade reporters, and we do not publish criticism of a named company's disclosure. The point of this page is what the first cycle looked like, not who did badly at it.
Related references
For which jurisdiction reports when, see IFRS S2 adoption by jurisdiction. For the assurance standards behind the assurance observations, see the sustainability assurance standards reference. For the reliefs available in a first cycle, see IFRS S2 transition reliefs, and for what a practitioner tests, what auditors check in a first cycle. Templates for the records behind these disclosures are at IFRS S2 working templates.
How to cite this page
Auditably Research. "IFRS S2 first-cycle disclosure observatory." Auditably.
https://auditably.co/blog/ifrs-s2-first-cycle-observatory (accessed [date]).
If you have published a first-cycle report and want it read and recorded here, send the link to [email protected]. We record what the document says, including where it is strong. We do not rank or score anyone.