ASRS Compliance for CFOs
The finance leader's guide to mandatory climate disclosure
ASRS climate disclosures are financial disclosures, subject to the Corporations Act, integrated into annual reports, and requiring assurance. As CFO, you're accountable for data systems, controls, and board-ready reporting.
CFO ASRS Responsibilities
Climate disclosure sits at the intersection of finance, risk, and sustainability
Data & Controls
Establish robust systems for emissions data collection, validation, and reporting with audit-ready controls.
Financial Integration
Integrate climate risks into financial statements, impairments, provisions, and going concern assessments.
Assurance Readiness
Prepare for limited and reasonable assurance requirements with appropriate documentation and audit trails.
Budget & Resources
Allocate appropriate budget and resources for ASRS compliance activities and ongoing reporting.
Financial Statement Impacts
Climate risk flows through to financial statements in multiple ways
Asset Impairments
Climate-vulnerable assets may require write-downs as transition risks crystallise
e.g., Property exposed to physical climate risk, stranded fossil fuel assets
Provisions
Provisions for transition costs, decommissioning, and remediation
e.g., Decarbonisation capex, site remediation, workforce transition
Going Concern
Assessment of business model resilience under climate scenarios
e.g., Revenue model viability in 1.5°C or 2°C transition scenarios
Useful Life
Asset depreciation assumptions in low-carbon transition
e.g., ICE vehicle fleets, gas infrastructure, high-emission equipment
Contingent Liabilities
Climate litigation and regulatory penalty exposure
e.g., Greenwashing claims, environmental remediation orders
ASRS Budget Guide
Typical costs for mid-market companies ($10M-$500M revenue)
| Category | Typical Range | Description |
|---|---|---|
| Governance Setup | $5,000 - $15,000 | Frameworks, decision rights, board reporting |
| Emissions Baseline | $10,000 - $30,000 | Scope 1, 2, material Scope 3 measurement |
| Climate Risk Assessment | $15,000 - $40,000 | Physical and transition risk analysis |
| Disclosure Preparation | $10,000 - $25,000 | Documentation, narratives, sign-off |
| Assurance Preparation | $5,000 - $15,000 | Controls, documentation, audit support |
| Ongoing Annual Costs | $20,000 - $50,000 | Data updates, reporting, governance |
Fractional CSO Alternative
A Fractional CSO at $8,000-$15,000/month often provides better value than fragmented consulting by coordinating all ASRS activities, building internal capability, and ensuring board-ready outcomes.
CFO ASRS Checklist
Key actions for CFOs to ensure ASRS readiness:
- Confirm ASRS group and compliance deadline
- Assess current emissions data capability and gaps
- Review financial statement climate risk integration
- Establish cross-functional governance with sustainability
- Budget for compliance activities and resources
- Engage appropriate external support (Fractional CSO, consultants)
- Prepare board and audit committee briefings
- Plan for assurance readiness and external audit
CFO Liability Warning
ASRS disclosures fall under the Corporations Act. False or misleading climate disclosures can expose directors, including CFOs, to personal civil liability.
Maximum individual penalty:Up to $1.565 million
Maximum corporate penalty:Up to $15.65 million, or 10% of turnover, whichever is higher (capped at $782.5 million)
Need ASRS Support for Your Finance Team?
Book a free 30-minute strategy session to discuss your ASRS compliance requirements and explore how Fractional CSO support can help your finance function.