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RIAA thanks the Productivity Commission for the opportunity to comment on its inquiry into the efficiency and value of non-financial business reporting requirements in Australia.

RIAA members, including Australia’s largest institutional investors, engage with business reporting requirements in several capacities. They use investee company disclosures to inform investment, stewardship and risk-management decisions. Some members also prepare disclosures as asset owners, asset managers or reporting entities, or provide information to related entities, regulators and clients. This gives RIAA an interest in both the decision-usefulness of reported information and the efficiency and proportionality of its preparation.

RIAA supports practical reforms that reduce unnecessary burden, duplication and inefficiency for business reporting. The Commission should assess the purpose and impacts of reporting requirements across the whole reporting system, including the costs borne by preparers and the value of reported information to investors, regulators and other users. It should also consider whether removing or reducing public reporting would shift costs to users through requiring additional data acquisition, bilateral requests, estimation or due diligence.

Non-financial reporting is market infrastructure, not merely a compliance activity. An efficient and productive economy requires the availability of decision-useful information about business performance, risks, opportunities and impacts. This supports capital allocation, stewardship, regulatory oversight and the development of appropriate public policy. The Commission should therefore distinguish unreasonable reporting burden from material information that necessarily imposes a cost to produce. Reform should aim to improve net system value through proportionate requirements, aligned definitions, data reuse, digital interoperability and well-sequenced implementation. The objective should be better reporting at lower total system cost, not simply less reporting.

This approach is consistent with the Australian Government’s emphasis on on adopting innovation, supporting investment, developing skills and delivering regulatory reforms that improve the efficient operation of the economy (p. xvi of the 2026 Intergenerational Report). It also builds on RIAA’s previous position (Pillar 5 submission) that productivity analysis should consider the costs of delay and inaction, support coherent whole-of-government policy and recognise the value of reliable sustainability information. We apply those principles here to the design and reform of business reporting requirements.

Summary of recommendations

Recommendation 1: Assess the net system value of reporting requirements, including preparer costs, user benefits and any costs that would be shifted to investors, regulators or other information users.

Recommendation 2: Prioritise harmonisation, interoperable digital reporting and a genuine “tell us once” approach, including consistent definitions, entity identifiers and reporting periods where policy objectives align.

Recommendation 3: Protect material, decision-useful information and data continuity where user value is established or plausible, while simplifying or removing requirements that are demonstrably little used relative to their cost.

Recommendation 4: Preserve international interoperability and improve the accessibility, navigability and connectivity of reported information, including through structured digital formats and clear cross-referencing.

Recommendation 5: Preserve reliable assurance outcomes and minimise transition costs through proportionate, well-sequenced implementation, practical guidance and adequate lead time.

Recommendation 6: Avoid duplicating or pre-empting legislated reviews of the climate-related financial disclosure regime, while addressing cross-regime interactions and implementation inefficiencies within this inquiry.

Recommendation 7: Apply a full productivity lens that includes the financial and economic costs of climate-related risk, delayed action on adapting to climate change and nature loss and the loss of information needed to identify, price and manage those risks.

General submissions

The inquiry should focus on better reporting, not simply less reporting

RIAA supports reducing regulatory cost where reporting objectives can be achieved more efficiently. However, removing widely accessible information may shift rather than eliminate costs if investors, lenders, regulators or other users must source it somehow, for example, by recreating it through bilateral requests, third-party datasets, estimates or additional due diligence. The Commission should therefore test carefully whether any proposed reform reduces total system cost or transfers cost to users while reducing comparability or reliability.

This approach would be consistent with the inquiry’s terms of reference which recognise that non-financial reporting enables investment to be directed towards businesses that align with stakeholder interests and manage risks holistically. They also require the Commission to consider the value of data to workers, directors, investors and broader stakeholder groups.

High-quality sustainability information supports capital allocation and market integrity

Investors need high-quality, comprehensive and comparable information to assess material risks and opportunities, inform valuation and stewardship and make capital-allocation decisions. RIAA continues to support reporting frameworks that improve consistency, reliability and comparability of this information and align Australia with credible international standards.

Australia’s statutory climate-related financial disclosure regime provides a current example: the Australian Government has acknowledged that the mandatory climate-related financial disclosure regime supports greater transparency about Australia’s largest companies’ exposure to material climate-related financial risks and opportunities. It also states that stronger risk management will require forward-looking analysis and climate-adjusted data because historical trends are no longer reliable indicators of future conditions (p. 74, Intergenerational Report 2026). ASIC’s first review of the regime (REP 839) observed that the quality, quantity and consistency of climate-related information increased compared with voluntary disclosures. ASIC also observed examples of entities revisiting governance structures and risk-management processes, while identifying areas where reporting quality should improve.

Climate change presents a material and systemic financial risk across investment portfolios. financial risk facing investments today. Investors need access to comparable information that shows how companies are navigating this risk. Reporting on climate change financial risks should not be seen as “non-financial reporting” as climate disclosures are core to understanding the information needed to understand an entity’s financial position and prospects and not purely a compliance obligation. Any changes or improvements to Australia’s climate-related financial disclosure regime should be considered in the context of the legislated 2028 review, and RIAA looks forward to contributing to this review.

The direct costs of producing reporting should be considered alongside the consequences of inadequate, inaccessible or unreliable information. For investors, these consequences may include:

• mispricing of material risks and opportunities;
• weaker capital-allocation and stewardship decisions;
• additional expenditure on third-party data, estimation and due diligence;
• difficulty assessing compliance with applicable obligations; and
• delayed identification of climate, nature, workforce, supply-chain and other material risks.

The Commission should consider these user-side and system-wide consequences when assessing whether individual reporting requirements impose a net burden or provide sufficient value.

RIAA recognises the Commission’s focus on understanding the costs of reporting as an important way to understand how businesses interact with reporting obligations and to ensure the costs are proportionate to the benefits of having the information available. As the Commission considers these costs, it is important to acknowledge the significant risks associated with investors not having access to sound information on areas such as climate, nature, modern slavery to inform investment decisions. For investors, these consequences may include:

• Financial loss and increased volatility
• Regulatory sanctions in other jurisdictions such as the EU
• Stranded assets
• Misjudged exposure to risks such as climate change, nature loss, regulatory risks relating to issues such as deforestation and modern slavery.

The Commission should consider these user-side and system-wide consequences when assessing whether individual reporting requirements impose a net burden or provide sufficient value.

Efficiency should come from coherent architecture and data reuse

Reporting efficiency should be pursued through coherent architecture and data reuse. RIAA supports:

• common definitions, classifications, entity identifiers and data standards where reporting objectives align;
• secure reuse of information already provided to government;
• appropriate data sharing between regulators;
• interoperable digital reporting formats; and
• better alignment of reporting periods and implementation timetables.

The Australian Government’s long-term productivity analysis in the Intergenerational Report 2026 identifies regulatory reform as a key contributor to productivity growth, alongside innovation, investment and skills development (p. xvi). The suggestions above can reduce duplicated effort while preserving the value of information.

RIAA has heard from members that unnecessary burden can be a result of identified fragmentation, inconsistent approaches and misaligned reporting cycles. For investors, reform should target these sources of avoidable cost rather than reduce access to material information needed for investment decisions.

International interoperability is a productivity issue

Australian entities operate in international capital markets and global value chains. Reforms should not reduce domestic compliance cost while increasing the cost of preparing additional information for international investors, counterparties or parent entities. Aligning with credible international standards can improve comparability and reduce duplicate reporting.

RIAA recommends that material proposals affecting sustainability reporting be assessed for international interoperability, including whether they would require Australian entities to prepare additional information for global investors, counterparties or parent entities. Australia should align with credible international baselines where alignment supports comparability and reduces duplication, while retaining Australian requirements where necessary to preserve decision-useful information, market integrity and effective risk governance.

Usability, integration and guidance should be priority reforms

The usefulness of non-financial information depends not only on the information disclosed but also on its accessibility, structure and connection to financial reporting. RIAA supports clear cross-referencing, navigational tools such as index tables, consistent terminology, connected financial and sustainability information, and practical guidance.

This has been reflected in the Intergenerational Report 2026 which has observed that effective management of climate-related risks will increasingly require forward-looking analysis and climate-adjusted data because historical trends may no longer provide reliable indicators of future conditions (p.74). This highlights the importance of reporting frameworks that deliver consistent, accessible and decision-useful information rather than focusing solely on reducing reporting volumes.

The Commission should retain a full productivity lens

In many cases, the medium or longer-term costs of inaction far outweigh the immediate costs of action. This submission builds directly on assertions set out in RIAA’s Pillar 5 submission (informed by consultation through RIAA’s significant member base of large institutional investors) that productivity analysis should not assess the cost of action without proportionate consideration of the costs of delay and inaction. In this inquiry, that principle applies to the information infrastructure through which investors, businesses and governments identify, price and manage material risks and opportunities. Reducing or delaying decision-useful reporting may create wider economic costs if risks are identified later, compared less reliably or managed less effectively.

The significant direct productivity and fiscal impacts of climate change have already been identified by the Australian Government: higher temperatures will reduce worker productivity, while increasingly frequent and severe natural disasters are expected to cause lost economic activity, infrastructure damage, higher insurance costs and rising government expenditure. Investment in disaster-risk reduction and resilience will be critical to reduce losses, improve insurance affordability and support faster recovery (Intergenerational Report 2026 pp. 69-70).

The modelling by the Government highlights that climate-related risks have measurable economic consequences, including reduced labour productivity, infrastructure damage, higher insurance costs and increased public expenditure associated with natural disasters (Intergenerational Report 2026, pp. 68-70). Reliable information does not eliminate these consequences, but it supports earlier identification, more effective pricing and better management of the underlying risks.

The Commission should therefore assess whether reducing or delaying decision-useful reporting could create wider economic costs by causing material risks to be identified later, compared less reliably or managed less effectively.

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