Comprehensive guide to ESG Reporting in New Zealand and Australia

Developed, built and supported exclusively for New Zealand and Australia

Australia and New Zealand are global leaders in ESG reporting, combining robust regulatory mandates with sector-driven voluntary frameworks. The ESG landscape now requires companies to engage with multiple standards, ratings, and disclosures – each targeting different aspects of environmental, social, and governance performance. This guide, using a structure inspired by in-depth policy summaries, outlines every major aspect of ESG reporting that New Zealand and Australian companies should know.

ESG Reporting

What are the ESG Reporting Standards and Frameworks?

ESG (Environmental, Social, and Governance) reporting is the process by which companies disclose information about their performance and impact in three principal areas: environmental sustainability, social responsibility, and corporate governance. This reporting practice allows organizations to communicate their non-financial performance to stakeholders – including investors, regulators, customers, employees, and broader society – offering transparency around how they manage sustainability risks and seize related opportunities.

The core purpose of ESG reporting is to provide structured, quantifiable insights into a company’s sustainable practices. It aims to improve transparency, build stakeholder trust, identify both risks and opportunities, and help companies meet regulatory requirements or voluntary commitments. While ESG reporting often supports a company’s broader corporate social responsibility (CSR) strategy, its emphasis is on measurable outcomes and data suitable for external evaluation.

The key components of ESG reporting cover three main pillars. The environmental dimension measures issues like resource use, climate change impact, carbon emissions, waste management, pollution, biodiversity, and energy efficiency. The social dimension addresses labor practices, workplace diversity, employee relations, human rights, community engagement, and supply chain responsibility. Governance factors include board composition, executive remuneration, business ethics, transparency, data privacy, anti-corruption measures, and rights of shareholders.

ESG reporting frameworks help organizations present information in a standardized and comparable way. These frameworks generally fall into three categories, as shown below:

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CATEGORYDESCRIPTIONEXAMPLES
RegulatoryMandated by governments/regulators; require specific disclosures for legal complianceCSRD, CRD, ASRS, NGER, SECR, SFDR
Benchmark / VoluntaryOptional frameworks offering guidance tailored to specific industries or prioritiesCDP, GRESB, GRI, SASB, TCFD, WEF, UN SDGs

Benchmark frameworks use structured scoring to enable performance comparison across sectors, while regulatory frameworks set compulsory standards under rules of specific jurisdictions, such as the EU’s CSRD or the US SEC’s climate disclosures. Voluntary frameworks, on the other hand, provide flexibility and are often used to supplement regulatory disclosures or enhance transparency.

Several influential ESG reporting frameworks and standards are widely recognized globally. The Global Reporting Initiative (GRI) offers a broad base for sustainability disclosures targeting diverse stakeholder groups. The Sustainability Accounting Standards Board (SASB) provides industry-specific standards focused on financially material ESG topics. The Task Force on Climate-related Financial Disclosures (TCFD) concentrates on risks and opportunities associated with climate change. The Corporate Sustainability Reporting Directive (CSRD) is an EU regulation requiring standardized sustainability disclosures, and the International Sustainability Standards Board (ISSB, including IFRS S1 and S2) establishes global benchmarking standards. Other notable examples include the CDP (Carbon Disclosure Project), with its emphasis on environmental impacts and benchmarking, and the World Economic Forum (WEF), which sets out comprehensive metrics covering governance, planet, people, and prosperity.

ESG Reporting in Australia and New Zealand

Australia’s regulatory framework for sustainability reporting is established through the Australian Sustainability Reporting Standards (ASRS), issued by the Australian Accounting Standards Board (AASB). These standards mandate phased climate, environmental, and sustainability disclosures for large listed companies, proprietary entities, and regulated financial organisations. AASB S2 aligns closely with IFRS S2, focusing on climate disclosure, and AASB S1, which will soon become mandatory, covers a broader range of sustainability issues. The ASRS requires comprehensive disclosures on areas such as strategy, governance, risk management, metrics – including Scope 1, 2, and 3 greenhouse gas emissions – scenario analysis, targets, and assurance.

In New Zealand, the Climate-Related Disclosures (CRD) regime is implemented through standards NZ CS 1–3, overseen by the External Reporting Board. CRD requirements apply to registered banks, large insurers, fund managers, and listed issuers with more than NZ$60 million in market capitalization or NZ$1 billion in assets under management. The NZ CS framework is strongly aligned with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), requiring detailed climate disclosures from 2023 onward.

There are several key differences between the New Zealand Climate Standards (NZ CS) and Australia’s ASRS framework:

Regime Scope and Applicability:

The New Zealand system (NZ CS) primarily targets financial entities such as listed companies, licensed banks, insurers, and fund managers, based on the expectation that climate-related impacts will be channeled through the financial system. In contrast, Australia’s ASRS regime has a broader initial scope, extending to incorporated companies above certain size thresholds (for example, AUD 25 million in assets), including some non-financial sectors right from the start.

Standards Alignment and Approach:

NZ CS, developed earlier, is rooted in the TCFD recommendations and adopts a more principles-based, flexible approach focused specifically on climate-related disclosures. ASRS is closely modeled on IFRS S1 and S2, making it more detailed and prescriptive, with strict financial reporting rules and elaborate disclosure requirements.

Scenario Analysis:

NZ CS requires analysis of three scenarios – 1.5°C, 3°C or greater, and an additional scenario relevant to the reporting entity. The ASRS framework, on the other hand, mandates assessment of two scenarios: 1.5°C and a “well above 2°C” or greater scenario.

Strategy Disclosures:

NZ CS calls for broad, simpler strategy disclosures without strict requirements for quantitative detail or in-depth contextualization. ASRS demands a wider scope, including both quantitative and qualitative data, with risks and opportunities rigorously linked to the business model.

GHG Emissions Measurement:

The New Zealand framework allows some flexibility in the methodology for measuring greenhouse gas emissions. Australia’s ASRS requires emissions to be measured according to the Greenhouse Gas (GHG) Protocol or the Australian National Greenhouse and Energy Reporting (NGER) Determination.

Assurance Requirements:

Under NZ CS, assurance is only currently required for GHG emission inventories. ASRS takes a phased approach, gradually expanding assurance requirements to cover more aspects of disclosures over time.

Director Liability:

NZ CS imposes more immediate responsibility and legal liability on directors for the accuracy of climate disclosures. ASRS introduces a more gradual approach to director liability, offering a transition period and temporary “safe harbour” protections for the initial three years.

There are additional distinctions as well. For example, ASRS requires financed emissions disclosures for relevant sectors (such as asset management and banking), while NZ CS does not. ASRS also includes annual requirements for climate resilience assessments and mandates revision of comparative disclosures when estimates change. In contrast, NZ CS requires climate reporting entities to disclose anticipated financial impacts before transition planning, whereas ASRS requires disclosure after accounting for planned climate responses.

Overall, while both frameworks aim to elevate climate and sustainability transparency, Australia’s ASRS features a broader scope, more granular disclosure demands, and a phased approach toward assurance and director liability, compared to the more targeted and flexible, climate-specific NZ CS regime.

AspectNew Zealand Climate Standards (NZ CS)Australian Sustainability Reporting Standards (ASRS)
ApplicabilityFinancial entities (listed companies, banks, insurers)Broader corporate entities over size thresholds
Standards BasisTCFD-based, principles-based and flexibleIFRS S1/S2-aligned, detailed and prescriptive
Scenario Analysis3 scenarios (1.5°C, 3°C+, 3rd relevant)2 scenarios (1.5°C, well above 2°C)
Strategy DisclosureSimpler, broader, less quantitativeDetailed, both qualitative and quantitative
GHG ReportingFlexible methodologyMandated GHG Protocol or NGER standards
AssuranceLimited to GHG inventoriesPhased approach toward comprehensive assurance
Director LiabilityImmediate liabilityGradual with safe harbour period
Other NotablesNo financed emissions disclosureFinanced emissions disclosure required

These differences highlight that while the two frameworks share a common foundation and objectives, the Australian ASRS is more detailed, broader in scope, and aligned more closely with financial reporting approaches, whereas the New Zealand NZ CS is an earlier, more flexible regime focused specifically on financial entities and climate-specific disclosures.

A number of global, voluntary, and sectoral frameworks guide sustainability and ESG reporting alongside local regulations. GRESB (Global Real Estate Sustainability Benchmark) is widely regarded as the leading ESG benchmark for real assets, with a particular focus on property and infrastructure. While participation in GRESB is voluntary, it is often required by global investors and major property funds. The assessment covers areas such as governance, environmental and social performance, risk management, targets, stakeholder engagement, and formal certifications of assets.

Green Star, managed by the NZGBC and GBCA in New Zealand and Australia respectively, is a prominent green building rating system that evaluates both the construction and operational performance of assets. Certification levels range from 4-stars, signaling best practice, to 6-stars, denoting world leadership. To earn a Green Star rating, projects must achieve points across a comprehensive range of sustainability outcomes, including energy and water use, materials, occupant health, greenhouse gas emissions, resilience, and social impact.

NABERS (the National Australian Built Environment Rating System) is another sector-specific standard that measures the energy, water, waste, and indoor environmental quality of buildings. NABERS certification is mandatory for commercial property larger than certain thresholds in Australia, but is also widely adopted on a voluntary basis for leasing, property transactions, and demonstrating environmental performance.

Additionally, a variety of other frameworks are commonly used for broader stakeholder and investor reporting or as supplementary to local compliance. These include the Global Reporting Initiative (GRI), CDP (Carbon Disclosure Project), and the United Nations Sustainable Development Goals (UN SDGs). Newer or complementary frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD), WELL building standards, and Climate Active are increasingly being incorporated into GRESB and Green Star assessments, reflecting the evolving landscape of sustainability metrics and expectations.

Why ESG reporting matters

Meeting ESG and sustainability reporting requirements serves several critical business purposes. Legal compliance is paramount, as adhering to frameworks such as CRD, ASRS, and national laws helps organisations avoid civil penalties, director liability, fines, and reputational risks that can result from non-compliance. Investor confidence is another major driver; ESG performance now sits at the heart of investor relations, influencing capital access and index inclusion, with frameworks like GRESB and Green Star increasingly acting as prerequisites for institutional investment. Robust ESG disclosures also support risk mitigation and resilience by enabling proactive management of environmental, social, and governance risks, driving climate adaptation measures, and strengthening business continuity planning. Finally, by benchmarking against and striving to exceed industry standards, companies can achieve competitive advantage through higher asset valuations, improved tenant retention, and enhanced stakeholder trust and reputation.

How does ESG reporting work?

ESG reporting works by setting out requirements and structures – both regulatory and voluntary – that organisations must follow to disclose their performance on environmental, social, and governance (ESG) matters. The scope and applicability depend on whether the regime is regulatory or market-driven.

Under regulatory regimes such as the Australian Sustainability Reporting Standards (ASRS) in Australia and Climate-Related Disclosures (CRD) in New Zealand, reporting is mandatory for entities that cross certain thresholds (such as revenue, asset size, or market capitalisation). For example, in Australia, all large private, listed, and regulated financial entities are required to report on both climate and broader ESG matters, with staging between 2025 and 2027 based on revenue, asset size, number of employees, and emissions metrics. Reporting must address strategy, governance, risk management, relevant metrics, and disclosure targets. In New Zealand, registered banks, large insurers, fund managers, and listed issuers above NZ$60 million market capitalisation or NZ$1 billion in assets must report following a TCFD-style framework, covering governance, strategy, risk, scenario analysis, emissions, and targets.

Alongside these, voluntary or market-driven schemes such as GRESB (for real assets and funds), Green Star (for building projects), and NABERS/NABERSNZ (for buildings in Australia and New Zealand) play a major role. While participation is market-driven, major investors often require them. GRESB provides ESG self-assessment and benchmarking for property and infrastructure, Green Star assesses entire buildings and developments across their lifecycles, and NABERS or NABERSNZ are used for operational performance ratings in energy, water, waste, and indoor environment quality.

Comprehensive sustainability reporting frameworks align around governance, strategy, risk management, and metrics pillars, while building performance rating systems like NABERS focus primarily on operational metrics and measurable outcomes. Green Star bridges these approaches by combining performance metrics with operational management requirements, though its management components are more procedural than strategic.

Data integrity is ensured by the use of internationally recognised standards – such as the GHG Protocol Corporate Standard (mandated by ASRS and others) – and by requiring third-party verification or audits for declared results. This requirement also extends to Green Star, NABERS, and is woven into the GRESB methodology, with CRD/NZ CS embedding similar expectations for climate disclosures in New Zealand. Initially, limited assurance is required for new reporters, escalating to reasonable assurance over time, much like financial reporting audits. Importantly, company directors retain legal accountability for the accuracy of all mandatory disclosures, including voluntary ESG metrics contained in investor or public filings.

Step-by-Step Guide for ESG Reporting

Mapping Applicability

Determine all overlapping regulatory and voluntary frameworks, deadlines, and audience (regulator, investor, public).

Scoping and Data Inventory

Review asset and entity coverage; match with frameworks (e.g. which assets need GRESB or NABERS, which entities fall under ASRS/CRD).

Team Assembly and Governance

Appoint responsible Directors, CFO/sustainability lead, and cross-functional teams.

Double Materiality Assessment

Engage internal and external stakeholders to set material issues for each regime: climate, gender, building health, etc.

Data Platform Set-up

Integrate systems for GHG, waste, water metrics; centralize documentation for third-party audits.

Disclosures Preparation

  • Write climate statements for ASRS/CRD.
  • Complete/submit GRESB portal self-assessments and documentation.
  • Register Green Star/NABERS assessments through their respective portals.

Assurance

Seek external assurance for GHG data, Green Star/NABERS ratings, and voluntary frameworks if claimed in public reporting.

Filing and Benchmarking

  • Lodge regulatory disclosures; use Green Star/GRESB/NABERS for deals, leasing, or investor communications.
  • Review benchmarks and peer scores for improvement.

Continuous Improvement

Use benchmarks and assurance/audit feedback to enhance performance and future reporting.

What are the common mistakes with ESG Reporting?

ESG reporting has become increasingly complex as stakeholders demand greater transparency and accountability. While regulatory compliance remains important, effective ESG reporting requires a broader strategic approach that considers sector-specific requirements, data quality, alignment across assets, and genuine integration into business operations. Understanding common pitfalls can help organizations develop more robust and credible ESG programs.

Strategic Approach and Scope Issues

Many organizations take too narrow a view of what effective ESG reporting entails:

Focusing solely on regulatory requirements – Overlooking sector-specific schemes such as GRESB or Green Star, which are often essential for investor confidence and benchmarking, while concentrating only on mandatory regulatory compliance

Data Quality and Completeness Problems

Poor data infrastructure and gaps undermine the reliability of ESG disclosures:

  • Data gaps or poor data quality – Particularly problematic when it comes to Scope 3 emissions or portfolio- and supply chain-level disclosures, which can undermine the reliability and completeness of reports
  • Inadequate data collection systems – Failing to establish robust processes for gathering comprehensive ESG data across all business operations and supply chains

Asset and Portfolio Alignment Issues

Inconsistencies between different levels of sustainability claims create credibility problems:

  • Misalignment between asset and group-level claims – When there is disconnect between the sustainability credentials of externally registered assets and the broader, group-level sustainability claims made by the company
  • Lack of portfolio-wide consistency – Failing to ensure ESG approaches and standards are applied consistently across all assets and operations

Certification and Standards Management

Poor timing and outdated approaches compromise ESG program effectiveness:

  • Late engagement with certifiers or assessors – Delayed involvement of third-party validators can result in missed requirements and implementation challenges
  • Failing to update approaches – Not keeping pace with the latest standards and requirements as expectations become more stringent each year
  • Inadequate standards monitoring – Missing updates to certification requirements and emerging best practices in ESG reporting

Governance and Integration Problems

Weak governance structures limit the effectiveness and credibility of ESG programs:

  • Insufficient board involvement – Lack of adequate board-level oversight and accountability for ESG performance and reporting
  • Failure to integrate ESG into business strategy – Not fully embedding ESG considerations into overall business strategy, which weakens oversight and reduces the effectiveness and credibility of disclosures
  • Siloed ESG management – Treating ESG as a separate function rather than integrating it across all business operations and decision-making processes
  • Focusing on point solutions rather than comprehensive suites – Choosing fragmented, single-purpose tools instead of integrated platforms that can handle the full ESG workflow and provide consistent, reliable data across all reporting requirements

Key Success Strategies

To avoid these pitfalls and develop effective ESG reporting:

  • Adopt comprehensive reporting approach – Go beyond regulatory minimums to include sector-specific schemes and standards that matter to investors and stakeholders
  • Invest in software early – Build comprehensive data collection and management systems that can reliably capture Scope 3 emissions and supply chain information, implementing software solutions early to complete the full capture/transform/report/act process across ESG
  • Ensure portfolio-wide alignment – Maintain consistency between asset-level sustainability credentials and group-level claims and strategies
  • Engage certifiers and assessors early – Involve third-party validators early in the process and stay current with evolving standards and requirements
  • Strengthen governance and integration – Ensure strong board involvement and fully integrate ESG considerations into core business strategy and operations
  • Focus on materiality and stakeholder value – Prioritize ESG initiatives and disclosures that deliver genuine value to stakeholders and support business objectives

Effective ESG reporting becomes a strategic tool for building stakeholder confidence, accessing capital, and driving sustainable business performance.

How BraveGen can help

For organisations managing extensive property portfolios, effective ESG reporting and compliance can be both complex and resource-intensive. BraveGen provides a comprehensive solution built specifically to address these challenges, combining automation, expert support, and advanced analytics to transform ESG obligations into real strategic advantage.

Trusted by Industry Leaders

BraveGen is a cloud-based sustainability platform relied upon by over 170 leading organisations across New Zealand, Australia, and internationally – including major property owners, managers, and corporate occupiers – for compliance and ESG leadership.

Purpose-Built for Complexity

The platform is specifically designed to meet the unique compliance, data management, and operational needs of businesses with large, diverse property portfolios, simplifying sustainability management at scale.

Automated Data Collection

BraveGen automates ESG data capture for emissions, energy, water, waste, and utility usage across multiple assets, sites, tenants, and partners, integrating all records into a single, validated system.

Effortless Compliance Reporting

The system enables seamless compliance with frameworks such as ASRS (Australia), CRD (NZ), GRESB, NABERS, and Green Star, offering centralised data and one-click reporting to streamline both mandatory and voluntary disclosures.

Significant Efficiency Gains

Customers experience up to 95% reduction in ESG reporting admin time and 45% faster turnaround, eliminating manual spreadsheets and duplicate processes.

Audit-Ready Outputs

Reporting outputs meet stringent Big 4 audit and third-party assurance requirements, providing directors and boards with clear traceability, transparency, and confidence in compliance.

Powerful Analytics & Oversight

Integrated dashboards deliver real-time, portfolio-wide visibility, allowing executives to benchmark assets, monitor climate risk, and pinpoint opportunities for energy or emissions savings.

Scenario & Net Zero Tools

BraveGen supplies climate scenario planning and Net Zero alignment tools, helping organisations model strategies, set credible reduction targets, and confidently adhere to evolving regulatory mandates.

Continuous Improvement Support

Automated anomaly detection alerts teams to usage issues and inefficiencies, supporting ongoing optimisation and higher asset ratings (e.g., NABERS, Green Star).

Expert Advisory Services

The BraveGen team brings deep expertise in large-scale audits, multi-site management, Scope 3 emissions, and ESG governance integration, helping turn complex reporting into a strategic asset.

Frequently Asked Questions

Who is required to report on ESG?

In Australia, the Australian Sustainability Reporting Standards (ASRS) apply to large listed and proprietary companies, financial institutions, and regulated entities above defined size thresholds relating to assets, revenue, employees, or emissions. In New Zealand, Climate Reporting Entities (CREs) such as listed companies, registered banks, insurers, and fund managers are required to report once they exceed thresholds of NZ$60 million in market capitalization or NZ$1 billion in assets under management. Beyond these mandatory requirements, many building owners, asset managers, REITs, funds, and corporates also engage with voluntary ESG schemes like GRESB, NABERS, or Green Star, often in response to investor expectations.

The starting point is understanding whether your company falls under the mandatory reporting rules of ASRS or New Zealand’s Climate-Related Disclosures regime. Once regulatory obligations are confirmed, many organisations will also need to consider sector-specific frameworks. Property and infrastructure entities may need to comply with GRESB, NABERS, or Green Star, while general corporates often use GRI, SASB, CDP, or ISSB standards. Organisations increasingly rely on a mix of regulatory frameworks for compliance and voluntary or sectoral schemes to strengthen transparency, demonstrate climate leadership, and meet investor requirements.

While there is overlap in the core data reported across different frameworks – such as emissions, energy, and governance indicators – no single report can cover everything. Asset-focused frameworks like NABERS, Green Star, and GRESB require their own dedicated reporting processes, verification, and certifications. Companies generally create a central ESG reporting system that allows them to capture data once and tailor it into multiple formats depending on the audience or framework.

In Australia, the ASRS requires phased assurance, beginning with limited assurance and moving toward reasonable assurance, similar to financial reporting standards. New Zealand currently requires limited assurance for greenhouse gas inventories, and is expected to broaden assurance requirements over time. Voluntary ESG schemes also typically require some form of independent verification – GRESB assessments, NABERS ratings, and Green Star certifications depend on third-party assessors to validate results. In every case, early preparation and formal processes make assurance smoother and lower the risk of non-compliance or reputational issues.

Voluntary reporting signals transparency and leadership, and can strengthen relationships with investors, customers, tenants, and employees. However, companies should be mindful that voluntary disclosures are closely scrutinized. Overstatements or inconsistencies risk reputational damage or accusations of greenwashing. Credibility depends on robust data systems, consistency across frameworks, and independent verification of metrics.

Major institutional investors rely on ESG data to assess performance, manage risk, and satisfy their own regulatory requirements. In property and infrastructure, participation in frameworks like GRESB, NABERS, or Green Star is often a precondition for investment. For listed companies, ESG performance influences access to capital, valuations, and index inclusion, making reporting not simply about compliance but a key part of investment strategy and risk management.

New Zealand’s Climate Standards are principles-based, closely aligned to the TCFD, and apply mainly to financial entities, with a strong focus on climate-specific disclosures. Australia’s ASRS, by contrast, applies to a broader group of companies, is more detailed and prescriptive, and is aligned to the new global IFRS sustainability standards. The Australian approach goes further in requiring quantitative disclosures, mandated methodologies, financed emissions reporting, and a phased assurance roadmap. Directors in New Zealand already carry significant liability for disclosures, while Australia provides a temporary safe-harbour for directors during the initial phases of reporting.

Common challenges include collecting reliable data on Scope 3 emissions across supply chains, managing overlapping frameworks with different disclosure requirements, and ensuring board-level engagement given growing director liability. Sector-specific requirements can also catch companies by surprise if investor-driven schemes like GRESB or NABERS apply to their assets. Ensuring data is assurance-ready from the start avoids costly corrections later in the reporting process.

Many organisations turn to ESG software platforms and advisory providers to simplify the process. Cloud-based systems, such as BraveGen, integrate sustainability data into a single platform that can produce reports aligned with ASRS, CRD, GRESB, and NABERS, while maintaining audit-ready documentation. These systems automate data collection from suppliers and internal systems, support scenario analysis and Net Zero pathways, and provide dashboards for executives and boards. Combining software with expert advisory ensures ESG reporting is consistent, reliable, and embedded into broader governance.

The immediate steps include confirming whether mandatory reporting applies, mapping any voluntary or sector-specific schemes that investors expect, and building an internal governance structure with director involvement. Companies should also establish reliable data capture processes, conduct materiality assessments, and engage assurance providers early. Preparing now helps organisations meet current obligations while strengthening resilience, investor confidence, and long-term strategic positioning.

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