Samantha Zebrowski, principal, business advisory for William Buck, outlines some of the early lessons from Australia’s first year of compulsory sustainability reporting.
**This story originally appeared in the April 2026 edition of AMT Magazine**
With changes to the Corporations Act enforcing mandatory sustainability reporting coming into effect last year, the question for many is how to build a report that stands up to stakeholder scrutiny and actually improves the business.
That’s the focus of William Buck principal, business advisory, Samantha Zebrowski, who will lead a session at Australian Manufacturing Week session titled Navigating Mandatory Climate Reporting and Your First Sustainability Report.
The rollout of the new sustainability reporting framework began on January 1, 2025, affecting companies with two of three of either a consolidated revenue of $500 million, consolidated gross assets of over $1 billion or over 500 employees.
The second stage of the rollout – to companies with two of three of either $200 million in revenue, $500 million in assets or 250+ employees – is set to start from 1 July this year.
A third group, earning $50 million or more, with assets of $25 million or more and with 100 or more employees, will start their reporting obligations on 1 July 2027.
With that in mind, Zebrowski says the biggest shock for many organisations has been the breadth of new information required and the systems required to collect it.
“The new climate reporting rules were quite onerous on businesses, because it’s a completely new role of reporting,” she says.
“One of the hardest parts was actually working out what businesses needed to do. It’s asking for a lot of information that businesses haven’t historically had access to or haven’t necessarily had a reason to track.”
Zebrowski says for manufacturers, first‑year readiness has often hinged on the development of the data infrastructure behind the disclosures.
“A lot of processes had to be put in place to be able to collect the data, to be able to do the reporting,” she says.
“It impacted so many elements of the business, so it was finding someone to own it and really drive it… It was quite a compliance burden in terms of resourcing and costs as well.”
The standards themselves are clear on what belongs in scope: Preparing climate-related financial statements requires disclosure of climate‑related risks and opportunities that could reasonably be expected to affect cash flows, access to finance, or cost of capital over the short, medium or long term—structured around governance, strategy, risk management, and metrics and targets.
Zebrowski says that while companies “at the top end of town” have already started their climate reporting, supply‑chain effects mean many smaller firms will feel the pull sooner than they expect.
The fact that the second stage of the rollout is to take place in July means it’s important to start getting recording processes in place now, she adds.
“You’ve got to capture the data for 12 months. So, if you don’t know what data you need to capture, you’re going to miss the start of the year,” Zebrowski says.
A theme Zebrowski has observed in early adopters is the shift from tick‑box compliance to using the process to sharpen their own operations.
“Some people have been able to make some really good improvements within their business in terms of efficiencies with machinery and energy efficiencies,” she says.
“They’ve been using another way to get ahead, as opposed to just: ‘I need to do this and I’m going to tick a box.’”
A practical approach for first‑time preparers starts with leadership and literacy, she adds.
“What we’re recommending… is to really educate themselves and align their leadership,” Zebrowski says. “That can be with the support of an advisor or someone that they trust, because we don’t expect them to know it all. It’s very new. It’s very complicated.”
From there, she advocates a classic readiness sequence: gap analysis against the four pillars, mapping the current state to the requirements; a roadmap with sequencing and resourcing; data and technology decisions; and a pilot or dry run before the start of the first in‑scope year.
“Some pilot testing—does this actually work? Is it giving us the data that we need before 1 July? If it is, great; if it’s not, reassess, adjust,” she says.
Many plants already measure throughput, quality and uptime at fine resolution; but the challenge is that climate‑reporting data cuts differently across facilities, fleets and suppliers, Zebrowski says.
“Manufacturers are usually good at collecting data. It’s just that this kind of data is quite different from anything that they’ve been required to collect in the past,” she says.
She points to company vehicle fleets as a relatable example – saying there will need to be a high level of specificity: “Work out what the standards require you to report on and through that process identify gaps…”
“If we need to collect data on a supply chain fleet, we’re going to need some tracking mechanisms, or we’re going to have to keep fuel receipts per car, and if we weren’t doing that before, so we’re going to have to create a new process,” she says.
For manufacturers not directly in scope, the reality is they may still be asked—repeatedly—to supply data, even if they will never be large enough to be compelled to report.
“You might be in neither of group one, two or three, but you might be in the supply chain of a group one, two or three, and they’re coming to you saying, I need this information because you’re in my supply chain and I have an obligation to report about you,” Zebrowski says.
In practice, many suppliers will receive templated data requests from multiple customers, each aligned to the customer’s reporting calendar and assurance needs and broadly sitting within the annual report ecosystem – and being prepared to those standards. The implication for suppliers is straightforward: prepare once, reuse often—but ensure consistency and an audit trail.
“It’s going to be really interesting to see what the finished product actually looks like, kind of across the board, and compare and see how that changes—potentially—the approach for group two companies,” she says.
As ASX-listed companies publish their first sustainability reports on the new timetable, the market will quickly form a view on best practice, clarity of methods, and the level of integration with strategy and capital planning.
So, what does a practical first‑year plan look like for a manufacturer about to begin?
First, educate and align leadership—board, executive and operational. Directors are already being briefed that this is the most significant change to corporate reporting in a generation and that early preparation is essential. Treat it as a capability build, not a one‑off compliance sprint.
Second, run a gap analysis against the four pillars. Map current governance oversight; inventory climate risks and opportunities specific to your footprint and supply chain; define processes for identifying, assessing and managing those risks; and catalogue metrics, targets and data sources. Include scenario analysis planning—requirements expect disclosure of the analytical basis, and guidance indicates at least two scenarios.
Third, design a 12‑month data plan that can withstand assurance. Clarify organisational boundaries, facilities, fleets and suppliers; select methodologies and factors; implement controls; and ensure evidence is captured contemporaneously. Decide what you will estimate and how you will improve precision over time. Build a single source of truth to answer multiple customer requests as supply‑chain asks escalate.
Fourth, pilot. Before your first in‑scope year starts, conduct a dry run of the processes, from data capture on the shop floor through consolidation, review, and draft disclosures. Use the pilot to identify missing data, ambiguous ownership, process bottlenecks and control gaps—then remediate before the first day of reporting.
Finally, plan for assurance and liability settings. Understand what will be subject to limited assurance initially and what will step up to reasonable assurance; brief directors on the transitional declaration and modified liability framework for specific forward‑looking disclosures; and ensure legal, finance and sustainability are aligned on wording and evidence.
Zebrowski’s message to manufacturers is intentionally pragmatic: The focus will be on getting started, Zebrowski says, adding that she expects the first cycle to be the steepest, after which processes will stabilise and capability compound.