Can Trace write my AASB S2 disclosure for me?

The Standards in Practice

AASB S2, the climate standard within the Australian Sustainability Reporting Standards (ASRS), sets out what your entity must disclose, but it does not say who has to write it. You can draft it in house, work with an adviser such as Trace, or combine the two.

What does not change is who is accountable. Under section 296A(1) of the Corporations Act, your sustainability report must include a declaration by your directors about the climate statements and notes. In it, your directors give their opinion that the report complies with the Corporations Act and AASB S2.

For financial years commencing between 1 January 2025 and 31 December 2027, the declaration is modified. Directors instead declare that the entity has taken reasonable steps to ensure the sustainability report is in accordance with the Corporations Act and AASB S2.

Either way, your directors make the declaration, whoever prepared the draft. Using an adviser does not transfer that obligation. So a draft from Trace, or anyone else, still needs to be reviewed, checked for accuracy and approved by your management and board before it is signed.

Trace's viewpoint and approach

Accountability for your Sustainability Report always stays with you. Our job is to make it a job you can stand behind.

We think the right question is not "who writes it?" but "can we show how every statement was reached?". A report drafted with help, built on documented decisions and linked to its evidence, is more defensible than one written entirely in house from memory.

Our philosophy: AI where it helps. Experts where it matters.

AI is very good at carrying context, keeping decisions consistent and connecting text to its sources. It is not a substitute for the judgement of the people accountable for the report, which is why every draft is reviewed by an expert and owned by you.

We are wary of disclosure text that appears without a trail. That is why Tracey will not produce it on request, and why we recommend against generic AI tools for anything that goes into the lodged report.

How Trace supports drafting

Trace combines our AI platform with climate experts, to ensure your Sustainability reports is ready for Audit.

Context is carried forward. The AI in the Trace platform works from your own material: your governance review, climate risk assessment (CRA) workshops, risk register, emissions inventory and the decisions recorded along the way. The disclosure reflects what your organisation actually decided, not a generic description of what companies like yours usually do.
Decisions are remembered. Materiality calls, scenario choices, boundary decisions and the reasons for them are recorded as they are made. When the draft is written, and again in Year 2, those decisions are not re-litigated or quietly changed.
Statements link to their source. Disclosure text is connected to the documentation it rests on, so your reviewers, your board and your assurance provider can check a claim against its evidence without a hunt. This is also what makes a "reasonable steps" declaration easier to give.
Experts review what the AI drafts. AI does the heavy lifting on structure and first drafts. Trace's experts check the judgement calls, the wording and the fit with AASB S2 before anything reaches your board.

"It was the best, most well laid out and structured sustainability report I have reviewed across all my clients so far.”

Feedback from Big Four audit partner on a Trace-drafted AASB S2 report

Common mistakes when writing your disclosure

Treating the drafter as the owner. Management signs off text it has not interrogated because "the consultant wrote it". The directors' declaration is still theirs, and so are the questions from the assurance provider.
Pasting generic AI output into the draft. A confident but wrong paragraph reference or requirement ends up in a lodged report, and nobody can say where it came from. Generic AI tools are useful for summarising, restructuring and first-pass editing of material you already trust. Using one to generate disclosure content from scratch shifts the risk onto your directors without them knowing.
Losing the link between words and evidence. The final report is edited in a separate document and the connection to source material is lost. Every claim then has to be re-evidenced under time pressure.
Leaving board review to the last meeting. Directors see the disclosure once, days before lodgement, which makes a genuine "reasonable steps" position hard to evidence.

Why Tracey will not draft disclosure text on request

The Trace Sustainability Agent, Tracey, answers questions about the ASRS regime, AASB S2 and how Trace works but she will not write disclosure paragraphs, climate statements or directors' declarations on demand, even if asked directly.

This is deliberate: A disclosure paragraph written in a chat window has none of the things that make drafted text safe to sign: your decisions, your evidence, expert review and a record of how it was produced. Producing it anyway would be the same risk this article cautions against.

If you want help with drafting, Tracey can explain what a section needs to cover, what evidence supports it and how Trace's drafting support works, and point you to your Trace team.

To learn more about Trace's product and services read here.

Frequently asked questions

Q: If Trace drafts our disclosure, who is responsible if something is wrong? Your entity and your directors. The sustainability report is prepared by your entity and your directors sign the declaration that it complies, or in the first three years that reasonable steps were taken to ensure it does. Using Trace, or any adviser, does not transfer that. What Trace can do is give you a clear record of how each statement was reached and what it rests on, so your directors can show the steps they took.

Q: Can I just use ChatGPT or another AI tool to write our climate disclosure? You can use AI tools to summarise or tidy material you already trust, but we recommend against using them to generate disclosure content. Generic tools can state wrong requirements, dates or paragraph references with complete confidence, they do not know your organisation or what your auditor expects, and they leave no record of how the text was produced. Those are exactly the gaps an assurance provider and your board will probe.

Q: Can Tracey write a section of our disclosure for us? No. The Trace Sustainability Agent, Tracey, answers questions about the ASRS regime, AASB S2 and how Trace works, but it will not write disclosure paragraphs, climate statements or directors' declarations on request. Text written in a chat window has no link to your decisions or evidence and no expert review. If you want drafting support, Tracey can explain what a section needs and put you in touch with your Trace team.

Q: We're short on time. Is it safer to have Trace draft it or to do it ourselves? Either can work if the drafting sits on documented decisions and evidence, and your management and board genuinely review it. The risk is not who drafts it, it is text that nobody has checked or can trace back to its source. Trace's drafting support is designed to keep that trail intact and to take much of the workload off your team, while leaving the judgement calls with you.