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RIAA thanks the Australian Government for the opportunity to comment on the exposure draft of and explanatory statement for the Corporations Amendment (Proprietary Company Thresholds) Regulations 2026.
RIAA does not outright oppose changing the reporting threshold for large proprietary companies where there is a legitimate and robust policy rationale for doing so. We do not comment on the appropriateness of the specific proposed increases to the revenue and gross asset thresholds as sufficient information to assess the suggested thresholds, or the potential impact of those thresholds, has not been provided. RIAA’s interest is to ensure that changes to the proprietary company thresholds do not have unintended consequences for the coherence of Australia’s mandatory climate-related financial disclosure (CFRD) regime.
RIAA is particularly concerned about the potential effect on entities subject to the National Greenhouse and Energy Reporting Scheme (NGERS). Financial size and climate significance are distinct considerations. An entity may fall below the revised financial-size thresholds while continuing to have NGERS reporting obligations arising from its greenhouse gas emissions, energy production or energy consumption. This distinction is relevant to institutional investors. The usefulness of climate-related financial information is not determined by an entity’s financial size alone. Where an entity continues to have significant emissions or energy-related activities, investors may continue to require information about the associated climate-related risks and opportunities to assess portfolio exposures and make informed investment and stewardship decisions. RIAA considers that the implications for these entities warrant separate consideration and, consistent with evidence that NGERS status was an important basis for bringing climate-significant entities within the CRFD regime, the Government should ensure that changes to the proprietary company thresholds do not inadvertently remove NGERS reporting entities from the CRFD regime.
Summary of recommendations
RIAA makes the following recommendations prior to settling the final form of the changes to reporting thresholds:
Recommendation 1: Ensure that changes to the proprietary company thresholds do not remove NGERS reporting entities from mandatory climate-related financial disclosure solely because they cease to meet the applicable financial-reporting threshold.
Recommendation 2: Assess the broader effect of any changes to proprietary company thresholds on the coverage and coherence of the climate-related financial disclosure regime, including investor access to comparable climate-related information.
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