Which reporting group am I in, and when is my first report due?

How your first reporting year is determined

Mandatory climate reporting under the ASRS regime phases in by reporting period commencement. An entity is caught for the first annual reporting period that begins on or after its group's start date.

You need at least two of the three size criteria, and you fall into the earliest group whose test you meet.

The reason those two columns belong side by side is that reading the second one as a year-end date, or substituting a financial year label for it, produces a wrong answer almost every time. Two worked examples:

A Group 2 entity with a 30 June year end. The first period beginning on or after 1 July 2026 is 1 July 2026 to 30 June 2027. So the first report covers FY27, not FY26.

A Group 2 entity with a 31 December year end. The year beginning 1 January 2026 commenced before 1 July 2026, so it is not caught. The first period is 1 January to 31 December 2027, and the first lodgement falls in 2028.

Both entities are in Group 2, and their first reporting periods sit six months apart, which is simply what different year ends produce. The part that matters is which period each one skips.

The June entity's year beginning 1 July 2025 is out, because it began before Group 2 starts. The next year is in. The December entity's entire 2026 calendar year is out, because it began on 1 January 2026, six months before Group 2 starts, so its first reporting year is 2027.

Lodgement then follows the same timing as your financial report. Disclosing entities, registered schemes and registrable superannuation entities lodge within three months of year end; other reporting entities get four. Listed entities also have a three month obligation under the ASX Listing Rules. The common error is assuming the four month window applies.

How to apply the size test

Everything is consolidated. Revenue, gross assets and headcount cover the entity and everything it controls. Testing the parent's standalone accounts is the most reliable way to produce a false negative.

The measurement dates differ. Revenue is the figure for the year. Gross assets and headcount are measured at year end. So a late acquisition or a headcount step-up in the final quarter counts.

The test runs every year. This is not a once-in-always-in classification. Growth can pull your first reporting year forward, and an entity that later falls below two criteria can fall back out. Practically, that means the assessment belongs in your annual close calendar rather than being done once and filed.

Casual employee treatment varies. Part-time staff count as a fraction of a full-time equivalent. Casual treatment varies across the market and there is no single answer. If headcount is one of your two criteria and casuals are material to the count, agree the approach with your auditor before you rely on the conclusion rather than after.

Size is not the only route in. Registration under, or an obligation to register under, the NGER Act brings you into scope regardless of size, which catches energy and emissions-intensive businesses well below the revenue thresholds.

Meeting a threshold and being the entity that lodges are different questions. Group structures, subsidiaries with an Australian parent, subsidiaries of foreign parents, trusts and joint ventures all change who files what.

Proposed threshold changes: not yet law

The 2026 to 2027 Federal Budget proposed lifting the large proprietary company thresholds to $100m consolidated revenue and $50m consolidated gross assets, leaving the 100 employee criterion alone. If legislated, that would take a band of entities out of the reporting framework altogether, and it would bite hardest on Group 3.

It has not been legislated, no start date exists, and the current figures still determine whether you are in scope.

What evidence you need

Your group determination is one of the first things an auditor asks you to substantiate, and it is far easier to defend if it was written down at the time rather than reconstructed afterwards.

1. A short determination memo: which group, which two criteria you met, and the date of the assessment
2. The consolidated revenue and gross assets figures, tied to the statements they came from
3. The headcount with the full-time equivalent calculation shown, including how part-time and casual staff were treated
4. A group structure map showing every controlled entity in the consolidation
5. Your NGER registration status at year end, including a documented negative where you are not registered
6. Written confirmation from your auditor of the conclusion, obtained before the reporting year rather than after it
7. A board or audit committee minute recording that the determination was considered and accepted

Common mistakes

• Using a financial year label as shorthand for a group. "Group 2 is the FY26 cohort" is true for some year ends and wrong for others.
• Answering from last year's audited financials. They tell you your history, not your obligation. The test is applied at the end of the current year.
• Testing the parent company alone. The figures are consolidated.
• Treating one criterion as enough, or believing all three are needed. Both errors are common and both give the wrong answer. It is at least two of three.
• Treating the proposed threshold increase as settled. It is a Budget announcement, not law, and standing down preparation on the strength of it forfeits a reporting period you cannot recover.
• Leaving the question to year-end planning. By then the reporting year you needed to prepare during has already run.

Trace's viewpoint and approach

Because the test is applied at year end, the only useful way to answer it is forward-looking.

Our rule of thumb is that if you were within roughly 20% of two of the three criteria in the prior year, prepare on the basis that you are in scope. The reason is asymmetry rather than caution. Preparing a year early costs some effort that carries over. Discovering in month eleven that you were in scope from month one costs you a governance record that cannot be rebuilt, because the evidence had to exist while the year was running.

On the proposed threshold increase, we plan against the law as it stands. Relief may well arrive for entities between $50m and $100m of revenue, but it is not legislated and the phase-in dates are unchanged.

The conclusion itself is your auditor's to sign, since it turns on your year-end position, your group structure and in some cases your NGER status. Getting that in writing before the reporting year starts is worth considerably more than settling it accurately afterwards, because only one of those outcomes leaves you a year in which to comply.

Frequently asked questions

Q: We have grown a lot this year. Could we move from Group 3 to Group 2? Yes. Your group reflects the thresholds you actually meet, assessed at the end of each financial year, so growth can pull your first reporting year forward. Forecast consolidated revenue, gross assets and full-time equivalent headcount against both group tests early in the year rather than answering from last year's audited numbers, then reassess at each period end.

Q: We only crossed a threshold right at the end of the year. Are we caught? Yes, for that year. Assets and headcount are measured at year end, so a late acquisition, a strong revenue year or a headcount step-up brings you into scope with very little runway. The same applies if you become an NGER registered corporation during the year.

Q: The Budget raised the thresholds. Are we out of scope now? Not yet, and possibly not at all. The proposal requires legislation and has no effective date. Until then the current figures apply. If you sit in the affected band, keep preparing and treat any relief as upside.

Q: Our parent is reporting. Do we still need to? It depends on whether your parent is an Australian entity preparing a consolidated report that covers the group, and a foreign parent's report does not discharge your obligation. The answer turns on your group structure rather than your size.

Q: What actually gets assured in our first year? A defined subset rather than the whole report, and the scope widens each year.