Australia’s First Year of ISSB-aligned Reporting: 4 Lessons for UK SRS Implementation

With UK Sustainability Reporting Standards (UK SRS) approaching, many organisations are looking beyond the technical requirements to understand the practical challenges of implementation. One of the most useful sources of insight is Australia, which has already adopted an ISSB-aligned climate reporting regime.

Australia adopted local equivalents of the ISSB standards through AASB S1 and AASB S2, with the latter introducing mandatory climate-related disclosures focused on climate-related financial risks and opportunities. The regime requires organisations to assess how climate-related matters could affect their prospects over the short, medium and long term.

 In May 2026, the Australian Securities and Investments Commission (ASIC), Australia’s corporate and financial markets regulator, published its early observations from a review of the first sustainability reports submitted under the new requirements. While the initial reports demonstrated improvements in the quality and consistency of climate-related disclosures, ASIC identified a number of recurring challenges that will sound familiar to organisations preparing for UK SRS. These observations offer a practical glimpse into the issues that can arise when organisations move from understanding the requirements to implementing them.

Four themes stood out from ASIC’s review that UK reporters should consider as they begin preparing for implementation. Collectively, they highlight that UK SRS readiness is not simply a reporting exercise, but a broader challenge involving governance, decision-making and accountability.

1. Know the definition of ‘climate targets’

Observation: ASIC observed differing interpretations of what constitutes a climate-related target and reminded entities that the definition includes targets required to be met by law or regulation, as well as targets set by the organisation itself.

What UK entities can learn for UK SRS disclosure: Organisations should establish a clear process for identifying, classifying and monitoring climate-related targets before reporting begins. Clearly distinguish between voluntary climate commitments, internal strategic targets and legally mandated climate obligations.

2. Cross-referencing should be clear

Observation: Many entities failed to meet cross-referencing requirements. Common issues included cross-referencing information on websites, referencing external reports, or failing to specify exactly where the relevant information could be found.

What UK entities can learn for UK SRS disclosure: Treat cross-referencing as a compliance exercise, not just a drafting convenience. Cross-references should direct users to a precise location within an accompanying report rather than a broad document, webpage or external source. A disclosure mapping exercise before publication can help identify gaps and inconsistencies.

3. Separate your material vs. voluntary disclosures

Observation: Some entities included additional voluntary climate information that obscured the material climate-related financial information required by AASB S2.

What UK entities can learn for UK SRS disclosure: Use index tables to set out the location of information contained within the sustainability report to ensure that it is clear how everything fits together. Prioritise material climate-related financial information before supplementary sustainability content. Additional disclosures should enhance understanding rather than distract from information that is most relevant to investors and other report users.

4. Be cautious about the use of disclosures

Observation:  ASIC identified disclaimers suggesting users should not rely on the sustainability report for investment decisions, or that companies were not responsible for certain information. ASIC stated that disclaimers conflicting with the statutory purpose of the reporting framework are not permitted.

What UK entities can learn for UK SRS disclosures: Ensure disclaimers do not undermine the credibility or intended purpose of disclosures. Organisations should focus on clearly explaining assumptions, limitations and areas of uncertainty rather than relying on broad disclaimer language that could be interpreted as reducing management responsibility for reported information.

The biggest lesson here is that reporting quality matters as much as reporting compliance. ASIC’s review demonstrates that sustainability reporting is increasingly becoming a strategic reporting discipline rather than a standalone compliance exercise. The organisations most likely to succeed will be those that embed climate-related reporting into governance structures, risk management processes and business decision-making.

With UK SRS on the horizon, now is the time to move from understanding the requirements to building the processes, controls and governance needed to report with confidence. Our team supports organisations through every stage of UK SRS implementation, from gap assessments and materiality considerations through to disclosure preparation and reporting readiness. Get in touch to discuss how we can support your organisation’s reporting journey.