Australia is often discussed as though mandatory climate disclosure is a novel undertaking — a regime being built from first principles, with no precedent to draw on. That's not quite right. Other markets in the region have been requiring some form of mandatory sustainability or climate-related disclosure for years, and the practical lessons from operating inside those regimes are directly relevant to Australian companies now building their own reporting capability, even where the specific rules differ.
My own experience with this sits on two distinct foundations, and they teach different lessons.
The capital-markets lesson: disclosure as a condition of the deal, not an add-on
As CFO of an Indonesia Stock Exchange-listed palm oil producer, I led the process that took the company to Indonesia's first plantation-sector global USD bond issue in over a decade — a $300 million transaction, four times oversubscribed. That bond could not have proceeded without a rigorous environmental and sustainability disclosure and vetting process, conducted by international underwriters and demanded by the investors ultimately buying the paper.
This wasn't a compliance formality bolted onto the transaction. It was a condition of investor participation. Underwriters and institutional investors examined the company's environmental practices with the same seriousness they applied to its financial position, because by that point in the market's evolution, sustainability performance was understood to carry real financial and reputational risk if it turned out to be poorly evidenced.
The lesson for Australian companies now facing AASB S2 is that this level of scrutiny is not new, even if the specific Australian statutory framework is. Capital markets have already been pricing sustainability disclosure quality into transactions for years, in jurisdictions that never had a mandatory climate reporting standard at all. Treating AASB S2 compliance as the ceiling of what's expected — rather than the floor — misreads where capital markets scrutiny is actually heading.
The domestic lesson: reporting as a routine, recurring discipline
The second foundation is different in kind. Under Indonesia's mandatory sustainability reporting regime for publicly-traded companies — in place since 2019 for financial institutions and listed companies — I personally prepare the company's annual Sustainability Report for submission to the Indonesia Stock Exchange, alongside its Annual Report, each year.
What this teaches isn't a technical methodology point so much as an operating one: sustainability reporting stops being a project and becomes a routine business process once it's been through a few reporting cycles. The first year is always the hardest — establishing what data exists, where it sits, who owns it and how to model it. By the third or fourth year, if it's been built properly, it becomes a known, repeatable exercise that slots into the same annual rhythm as financial reporting.
Build the first year's process as infrastructure for the fifth year's process.
Where the comparison stops
It would be a mistake to overstate the read-across. Australia's regime goes further than either of these precedents in two important respects. It extends well beyond listed companies — any large business meeting the applicable Group 1, 2 or 3 size thresholds is captured, regardless of whether its shares trade on an exchange. And it requires forward-looking climate scenario modelling — assessing outcomes under multiple future climate pathways — as a mandatory disclosure element, a discipline neither the bond-market vetting process nor routine Indonesian listed-company reporting required in the same form.
That combination of hands-on reporting discipline and capital-markets-grade rigour is a genuine foundation. But it's a foundation to build on, not a template to copy. Australian companies — and the advisers helping them — need reporting infrastructure and scenario modelling capability purpose-built for a broader, more technically demanding requirement than the ones the region's earlier movers have generally faced.
The practical takeaway
Markets that adopted mandatory sustainability disclosure earlier than Australia offer two things worth taking seriously: proof that rigorous disclosure can become a normal, repeatable part of annual reporting rather than a perpetual fire drill, and a reminder that capital markets have been scrutinising sustainability performance for longer, and more seriously, than a single domestic statute might suggest. Neither lesson reduces the size of the task in front of Australian companies now. Both are useful evidence that the task is doable, and worth doing properly the first time.
This article summarises lessons from mandatory sustainability reporting regimes in other regional markets and does not constitute legal, accounting or assurance advice. Entities should confirm their specific reporting group and obligations with appropriately qualified advisers. Regulatory basis last reviewed August 2026.