Five things you need to know

At Below Baseline, we worked alongside Group 1 reporters to deliver first-cycle disclosures. The five lessons below are what we saw first-hand.

Start early

It’s not a process that can be done overnight, and your organisation will get more value if you take the time to deliver a deep uplift within each workstream.

• ✓Build the reporting calendar backwards from your assurance sign-off date, not forwards from “when we feel ready”.
• ✓Sequence the uplift rather than running everything in parallel — governance and risk management processes need to be operating before you can credibly describe them, so lock these down first.
• ✓Set an internal “dry run” date at least 60–90 days out from the real deadline, so there’s time to close the gaps it exposes.

Understand where your current processes fit the framework

Map your current business processes to the framework so you can see where the gaps are. These are the key areas to work on in Year 1.

• ✓Do a structured gap analysis against all four pillars — Governance, Strategy, Risk Management, and Metrics & Targets — rather than jumping straight to the metrics.
• ✓Assign a process owner to each disclosure requirement, not just each pillar — “who owns the data” and “who owns the narrative” are often different people.
• ✓Separate the disclosures you can answer today from those needing new process or data — that split is your Year 1 priority list, and worth revisiting monthly.

Know why the disclosures exist

Understanding why the disclosures have been implemented and what purpose they serve gives all your workstreams clarity and direction.

• ✓Run a short kick-off session with every workstream lead explaining the purpose of ASRS/AASB S2 — decision-useful climate risk information for capital allocation — before diving into requirements.
• ✓Tie each disclosure back to a genuine risk or opportunity the organisation already tracks — reviewers and auditors can tell when a disclosure is manufactured purely for compliance.
• ✓Revisit the “why” whenever scope creep or fatigue sets in mid-project — it’s usually the fastest way to re-align a workstream that has drifted into generic disclosure language.

Understand your organisation’s limitations

This is specialist subject matter, and it’s unlikely you can complete it all on your own.

• ✓Identify early which disclosures need specialist input — scenario analysis, Scope 3 estimation, physical risk assessment — as these have long lead times and shouldn’t be discovered as gaps late in the project.
• ✓Don’t default to “we’ll figure it out internally” for scenario analysis specifically — this is the area where reporters most commonly underestimate the technical uplift required.
• ✓Where external expertise is engaged, embed it early enough to shape data collection design, not just to review a finished draft.

Engage your auditors early and keep tight document traceability

The limited assurance process requires evidence for every statement made within the disclosures.

• ✓Set up your evidence trail as you go, not retrospectively — every quantitative and qualitative statement needs to be traceable to a source.
• ✓Hold a pre-assurance walkthrough with your auditor on methodology — especially for Scope 3 and scenario analysis — before finalising your approach.
• ✓Maintain a single evidence register mapping each disclosure to its source documents from the outset, rather than assembling it retroactively under deadline pressure.