Mandatory climate disclosures are now a legal reality in Australia — with phased implementation starting in 2025 and full coverage expected within a few years. For insurers, brokers, and underwriting agencies, this is not just an ESG trend. It’s a regulatory compliance obligation with real financial and reputational consequences.

At Curium, we recently hosted a practical webinar with James Tilbury, Partner at Linden Sustainability, to demystify the new climate reporting regime and explain what financial services companies — especially in insurance — must do to get ready.

What Are Mandatory Climate-Related Financial Disclosures?

From 1 January 2025, large Australian companies are required to include a climate report as part of their annual reporting suite, in accordance with the International Sustainability Standards Board (ISSB) and Australian Sustainability Reporting Standards (ASRS 1 and 2). These reports must:

• Be audited and director-approved
• Address governance, strategy, risk management, and metrics/targets
• Include Scope 1, Scope 2 and eventually Scope 3 emissions
• Cover climate scenario analysis and financial impacts over short, medium, and long term

The legal foundation sits in the updated Corporations Act, with detailed technical requirements issued by the Australian Accounting Standards Board (AASB) and monitored by ASIC.

Who Is Affected by Australia’s Climate Reporting Laws?

The requirements apply to companies that meet certain thresholds in revenue, assets, or full-time employees (FTEs). Insurance groups — including brokers and underwriting agencies — may fall into:

• Group 1: Immediate reporting (2025) for the largest firms
• Group 2: Required from 2026
• Group 3: Smaller entities (e.g. many brokerages) from 2027 onward

🔎 Note: The threshold is based on revenue (not gross written premium), total assets, and headcount — so even authorised representatives (ARs) with standalone entities may be captured.

Key Actions for Insurance Businesses

Our webinar highlighted that climate disclosure is not just an ESG checkbox — it’s a governance, compliance, and data challenge. Insurers and intermediaries must:

✅ Appoint board-level and executive accountability for climate risk
✅ Update risk registers and compliance frameworks to reflect climate-related risks
✅ Prepare for auditable, financial-grade disclosure
✅ Begin tracking and estimating Scope 3 emissions — including claims costs and supplier emissions
✅ Respond to emissions and risk disclosure requests from larger value chain participants

💡 “This is not a sustainability team project anymore — it’s a finance, risk, and compliance issue,” said James Tilbury.

Technology and Tools: How Curium Helps

At Curium, we enable financial services firms to integrate new obligations like mandatory climate reporting directly into their compliance workflows. Our AI-powered platform:

• Tracks emerging ESG and financial regulations
• Maps obligations to your operating model
• Enables real-time updates, governance oversight, and audit readiness
• Supports climate risk register integration
• Automates documentation and reporting across Group 1–3 stages

We help you get ahead of the law, not just react to it.

What’s Next?

Companies in Group 1 must prepare their first climate reports by April 2026 — and many are already receiving Scope 3 information requests from partners today.

Whether you’re a large insurer or a growing brokerage, now is the time to:

• Review your governance structure
• Understand your reporting group
• Develop a roadmap for compliance
• Invest in the right tools and expertise

📩 Need help? Talk to Curium about your climate disclosure readiness.

Further Reading

• AASB Exposure Draft: ASRS 1 & 2 – Sustainability Reporting Standards
• ASIC Sustainability Reporting Guidance
• IFRS S2 – Climate-Related Disclosures
• Linden Sustainability
• Curium – Compliance Solutions for Insurers