Is ASRS S2 Really That Hard???
Or how I grew to love translating climate risk to $

So if you mix in sustainability circles or a member of a financial team within your organisations hopefully by now you should be aware of the new mandatory climate related reporting. Having met with a lot of groups grappling as first year respondents the same question comes up, what do we have to provide. And to say there is a some trepidation would be an understatement.
Like most legislation it comes with guidelines but not an instruction booklet. This means organisation need to work out what and how they will report largely for themselves and as everyone is just beginning there are no previous examples to refer to.
So where does this leave us? Well having sat in front of some quite large consultancy firms and listen to them presenting on ASRS it is clear that not everyone has a particularly clear idea. However this blog entry and
this section
of the Sustainable Healthcare website are dedicated to providing assistance in navigating this complex but not inherently difficult process.
So why do I say not inherently difficult. Well simply because it is. Not dissimilar to many of the major sustainability reporting regimes internationally, ASRS which is largely derived from TCFD documentation, simply asks a series of questions. The difficulty is in developing quality responses. Obviously that is only part as ASRS poses both quantitative and qualitative questions of which depending on how you split them up number close to 100.
So here is a very high level rundown of the approach you should be taking to ASRS:
- Review the legislation and confirm all the key deliverables that you need to be providing a response to OR leave it to someone like Sustainable Healthcare to conduct a full organisational risk assessment tying the legislative requirements to your organisations profile, and provide a detailed gap analysis and path forward.
- Conduct a climate risk assessment (more on that in a sec) which you can attempt to do yourself or seek the services of firms that have specialist capacity to do this. In house climate risk assessment can be done, but the quality of the outcomes can be questionable and given that at least some of what you report will be publicly available it is worth considering if this an appropriate strategy. Equally for assets located outside metropolitan areas or in areas with multiple climate related risks, publicly available climate risk data is often scarce, limited or out of date.
- Quantify what that risk translates to over time as the climate risk assessment should be providing you with quantified levels of risk by asset over time, this is its primary purpose, however depending on what you have asked for it may not directly provide a translation of that risk into dollars.
- Determine your transition risks and how that may impact your organisation.
- Produce your report.
Yes sounds easy. It's not, but there are a few things to consider when you start ASRS reporting:
- Reporting doesn't get better or easier if you ignore it, even for those organisations who are not required to report in 2026 (for 2025) you have the luxury of time so use it.
- Whilst there will be some benefit from seeing what others have done, there is no certainty that their approach is right or suitable for you.
- Even if you wait, at some point you will still have to do it and most of the legislative requirements don't necessarily get easier because others have gone before.
- There is a likelihood that as responding to the legislation matures the government will be more stringent in terms of the quality and accuracy of responses.
- Commit. Whether you think ASRS and/or sustainability generally is hogwash doesn't really matter, a bit like the saying "facts don't care how you feel", ASRS doesn't either and there are robust penalties for those who choose to ignore or report poorly. You have been warned.
If you have got this far thank you, and equally you were probably hoping for some answers. We're a consultancy not a nunnery, but we are cost competitive so please drop us a line and we are happy to come out and at least run you through the process (and in a way that will give you a realistic, tangible and most of all, a clear understanding) and obviously assist with developing a strategy to address ASRS and help with the development of a robust report that fully addresses requirements, should you so require.
Cheers Matt


