---
title: "Mandatory Climate Disclosures: What Insurers and Brokers Must Know"
url: "https://getcurium.com/news/mandatory-climate-disclosures/"
published: "5 June 2025"
author: "Michael Teh, Head of Operations"
publisher: "Curium"
description: "Mandatory climate disclosures are now law in Australia. For insurers, brokers and underwriting agencies, this is a compliance obligation with real consequences."
---

# Mandatory Climate Disclosures: What Insurers and Brokers Must Know

Mandatory climate disclosures are now law in Australia. For insurers, brokers and underwriting agencies, this is a compliance obligation with real consequences.

**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](https://getcurium.com/events/webinar-mandatory-climate-reporting/) with **James Tilbury**, Partner at [Linden Sustainability](https://www.lindensustainability.com), 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](https://www.getcurium.com "https://www.getcurium.com/"):

- 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](https://getcurium.com/book-demo/) 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](https://www.lindensustainability.com "https://www.lindensustainability.com/")
- [Curium – Compliance Solutions for Insurers](https://www.getcurium.com "https://www.getcurium.com/")