Australia's new climate rule (AASB S2) is hitting mining first. We just published a worked example of what the disclosure actually looks like. A$8.6bn of assets, 18% of group value, exposed by 2050.

Australia mandated AASB S2 for its biggest listed companies starting FY2025. Around 10,000 entities phase in across three tranches. Civil penalty cap A$15m. We just published a sector-specific worked example of what an AASB S2 mining disclosure looks like, anchored on a fictional reference company (Meridian Resources Group).

Most published samples from the big accounting firms skip the central number. The rule has a paragraph (29c) that asks companies to disclose the carrying amount of assets exposed to physical climate risk, in dollars. Sample disclosures from EY (Quality Holdings Resources) and KPMG's first-30 reporters review both leave that line blank. Our mining example fills it in.

The number: A$8.6 billion of assets on a A$48 billion base. 18% of Meridian's group, exposed to flood, cyclone, sea-level rise, storm surge, drought or bushfire by 2050 under a high-emissions scenario. Annualised expected loss runs A$80 to A$220 million depending on the scenario. Six named sites carry the bulk:

* Pilbara North (cyclone)

* Karratha Energy (sea-level rise + storm surge)

* Carajás-East (river flood)

* Mt Coolah (river flood + bushfire)

* Atacama Norte (drought + water stress)

* Mpumalanga South (river flood)

The disclosure runs asset-by-asset, not group-level narrative.

The Australian rule tightens the global ISSB standard (IFRS S2) in two ways. First, it requires companies to use the IPCC's Sixth Assessment as the science basis. Second, Australian company law sets a minimum of two scenarios: one capped at 1.5°C of warming, one well past 2.5°C. Our sample uses the lowest and highest of the IPCC's scenario set.

The rule also requires companies to disclose the capex they spend defending those sites (paragraph 29e). Our example shows A$145 million a year through a 'Climate Resilience Fund':

* Cyclone defences: A$45m (Pilbara, Karratha)

* River flood defences: A$32m (three sites)

* Coastal resilience: A$28m (Karratha)

* Heat-resilient infrastructure: A$18m

* Water management: A$22m

Honest gap: the damage maths for wind, wildfire and drought is still industry-wide guesswork. Our sample discloses cyclone capex but no quantified wind-loss figure exists yet. The sample describes compound events (drought + heat + wildfire arriving together) qualitatively only, because peer-reviewed damage curves don't exist.

For Australian sustainability and ESG advisory teams: how is your team landing on the physical-risk dollar figure for the first reporting cycle? Qualitative narrative, partial quantification with named sites, or a full asset-level breakdown?

Full sample: https://continuuiti.com/disclosures/aasb-s2/mining-and-materials/

Posted May 11, 2026, 5:22 AM UTC

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