Barry Li | Climate Reporting & Assurance

Insights on climate reporting, carbon markets, and sustainability assurance.

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Barry Li

PhD candidate in Accounting and Finance at the University of Newcastle, Australia, researching climate reporting, carbon markets, and sustainability assurance. An auditing practitioner with over 10 years’ experience, sharing insights at the intersection of academia and practice.

    • Welcome to My Blog

      Hello, and welcome!

      This site is a space where I will share reflections, updates, and resources from my research and professional practice in climate reporting, carbon markets, and sustainability assurance. As both a PhD candidate at the University of Newcastle and an auditing practitioner with over a decade of experience in the public sector, I am interested in how assurance practices are evolving and how complex topics like carbon accounting are made auditable.

      My plan is to post short “briefings” on developments in standards, regulations, and practice, along with insights from my research journey. These posts will aim to bridge academic thinking with practical challenges in audit and assurance.

      Thank you for visiting, and I hope you will find these updates useful and thought-provoking. Please feel free to connect with me on LinkedIn if you would like to continue the conversation.

    • Building Capability for a Low-Carbon Future: Reflections from Recent Climate Training

      It’s been a big month of learning. Across the public and private sectors, climate-related reporting and assurance training has accelerated — a clear sign that Australia is moving from policy design to practical delivery. I was fortunate to take part in several technical programs recently, which deepened my understanding of both greenhouse gas (GHG) assurance and climate-risk assessment.

      Without sharing any confidential content, I want to reflect at a high level on what stood out — and why it matters.

      1. Climate risk is now a governance issue, not a niche

      A recurring theme across all programs was that climate risk is no longer an environmental add-on. It’s being embedded into enterprise risk management, financial planning and audit oversight. Public agencies and listed entities alike are being trained to treat climate risk using the same rigour as other strategic risks — complete with defined responsibilities, accountability structures and periodic reviews.

      The message: governance drives credibility. Board and executive oversight of climate-related risks is becoming mandatory, not optional.

      2. Greenhouse gas reporting is becoming standard audit territory

      Training in GHG accounting underscored how much attention is shifting to data quality, boundary setting, and assurance readiness.
      Even at a conceptual level, it’s clear that the next few years will see rapid growth in sustainability assurance — from limited to reasonable assurance engagements under ASSA 5000, mirroring financial audit practice.

      For practitioners, the implications are practical: learning to interpret activity data, apply emission factors correctly, and understand materiality in the context of non-financial reporting. For entities, it’s about building systems robust enough to withstand audit testing.

      3. Proportionality and scalability are key

      Not every organisation has the same exposure, resources, or data maturity. Training discussions emphasised the concept of proportionality — ensuring that climate-related disclosures and assurance work are scaled appropriately to entity size and complexity, while still meeting the spirit of the standard.

      This idea will help smaller organisations participate meaningfully without being overwhelmed, and help auditors focus effort where the greatest risks lie.

      4. Adaptation and resilience are gaining attention

      Beyond emissions and compliance, climate-risk practitioners are talking more about adaptation pathways — structured, staged approaches to resilience planning. Rather than one-off assessments, entities are encouraged to design “pathways” that trigger action as new information or thresholds are reached. This type of forward-looking planning connects sustainability reporting with long-term service continuity and asset resilience.

      Why this matters

      For both the public and private sectors, these capability-building efforts mark a shift from awareness to competence. Climate risk and emissions assurance are no longer theoretical — they are becoming day-to-day professional responsibilities.

      As auditors, accountants and analysts, we’re being asked to translate complex environmental data into reliable, decision-useful information. That requires not just technical skill but judgement, scepticism and ethical awareness — the same principles that define our profession.

      The work ahead is challenging, but it’s meaningful. Every training session, every new framework, brings us closer to a profession that can help navigate Australia’s low-carbon transition with integrity and confidence.

    • When Life Reminds Us Why Climate Work Matters

      I’m a little late with this week’s post. A close family member has just been diagnosed with cancer — and we’ve been told there may not be much time left. It’s hard news to process. Moments like this make you stop and think about time, purpose, and what difference we really make in the brief years we have.

      As I sat with this, I couldn’t help but reflect on how often human activity has been described as a kind of cancer on the planet — consuming, spreading, and disrupting the natural systems that sustain life. But I don’t actually believe the Earth itself will die from climate change or any other human-made crisis. The planet is far more resilient than we are. Over billions of years it has survived impacts, ice ages, and extinctions. What is truly at risk is us — and the millions of other living creatures that share this moment in Earth’s long story.

      That realisation changes the way I think about climate work. The point is not to “save the planet” in some abstract sense; it’s to make life on this planet endurable and ethical for those who are here now and for those who come after.

      Even in technical fields like accounting and auditing, our choices shape that future. The systems we design to measure, disclose, and assure environmental impacts are not just compliance tools — they are moral and social instruments. They define what counts, what matters, and what is seen as progress.

      Some people cause damage and never get the chance to repair it. The rest of us, while we can, should do the best we can — whether that means challenging flawed metrics, strengthening climate reporting, or ensuring integrity in the information societies rely on to act.

      I don’t know if my loved one will live to see a more sustainable world. But I do know that our professional work — the patient, evidence-based, sometimes invisible work of building trustworthy systems — can help bring it a little closer.

    • Climate Disclosure Countdown: Key October 2025 Milestones for Australian Reporting

      1. ACCU Scheme review consultation opens

      On 20 October 2025, the Climate Change Authority (CCA) formally opened its public consultation for its statutory review of the Carbon Credits (Carbon Farming Initiative) Act 2011—the legislative foundation for Australia’s ACCU Scheme. The consultation invites feedback on the Scheme’s operation and broader role in a decarbonising economy. Submissions close at 5 pm AEDT on 8 December 2025.

      📘 For more details see: CCA ACCU Scheme Reviews (Climate Change Authority)

      This consultation arrives at a critical juncture: Australia’s new 2035 emissions-reduction target (-62 to -70 % below 2005 levels) places greater expectations on the ACCU Scheme to deliver credible abatement. The questions posed by the CCA—covering methodology governance, supply/demand dynamics, and market integrity—signal that the regulatory eye is shifting from voluntary offsets to mandatory disclosure and verification.

      2. New ACCU method-development process launched

      In mid-October, the Department of Climate Change, Energy, the Environment and Water (DCCEEW) published an update on how the ACCU Scheme is evolving its methodology development processes. The new “proponent-led” route replaces earlier government-only prioritisation and invites industry ideas for innovative abatement methods.

      📘 See: Developing new ACCU Scheme methods – DCCEEW (DCCEEW)

      Key points:

      • Several methods (for soil carbon, milking-cow feed additives, industrial waste-gas reductions) are now being fast-tracked.
      • Projects under older methods nearing expiration must plan for continuity or transition.
      • The message to smaller practitioners is clear: the Scheme is opening—and so are the risks of being left behind.

      For auditors and reporting teams, this is a signal that methodological risk (i.e., which carbon credit method a project uses) could matter for disclosures, especially when credits are referenced or retired in climate-related financial statements.

      3. National Climate Risk Assessment Report released

      October also saw the release of Australia’s first National Climate Risk Assessment Report, paired with the new National Adaptation Plan, addressing ten priority hazards—including flooding, bushfires, drought and ocean warming—across multiple time horizons (+1.5 °C, +2 °C, +3 °C).

      📘 Source: Australia’s first National Climate Risk Assessment Report (Clayton Utz)

      While this is more adaptation-than-disclosure focused, the report feeds directly into the climate strategy and risk-management pillar of AASB S2. For reporting entities, the implication is clear: climate-risks are no longer theoretical or long-term—they’ll need to be disclosed in financial statements under the new regime. It also raises questions for auditors about how advised scenario-analysis, sensitivity testing and disclosures should respond to such national-level evidence.

      Practical take-aways for preparers & auditors

      • If you’re involved with ACCUs or offsets, the consultation from the CCA is your chance to influence future policy—but also your signal to review any exposure now (method choice, expiry risk, documentation).
      • Audit & assurance teams should start factoring in method-risk assessment for carbon-credit-related disclosures: which method, who approved it, what documentation supports it?
      • Smaller entities not yet in scope for full climate disclosure should still track these developments: adaptation-risk reporting cue-cards and offsets market reforms hint at future expectations.
      • Boards and audit committees should ensure minutes reflect discussion around scenario-analysis and adaptation risks, especially as national assessment data becomes publicly available and integrates with disclosures.

      Final thoughts

      October 2025 reaffirmed that the intersection of mandatory climate disclosure (via AASB S2) and carbon-credit markets (via the ACCU Scheme) is becoming increasingly integrated. For reporting entities and assurance practitioners, this means moving beyond “Would we need it?” to “How do we prepare now?” The policy signals are unmistakable: method integrity, transparency, market dynamics and adaptation risk are now part of the disclosure and assurance agenda.

      As always, stay tuned for next month’s update—more developments are already in motion.

      🔗 Further reading:

      Note: This article reflects my interpretation of public information and does not constitute professional or financial advice.

    • ACCU Scheme Review Kicks Off: What Australia’s 2026 Consultation Means

      The Climate Change Authority (CCA) has opened its public consultation for the 2026 review of the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) — the legislation that underpins the Australian Carbon Credit Unit (ACCU) Scheme.
      Submissions are open until 5 pm AEDT, 8 December 2025 via the CCA Consultation Hub 💬.

      This review marks a pivotal moment for Australia’s climate policy architecture. It’s the first comprehensive review since the Safeguard Mechanism reforms, and comes as the nation ramps up ambition toward a 62–70 % reduction in emissions by 2035.
      The consultation paper — Enhancing the ACCU Scheme to Support Australia’s 2035 Emissions Reduction Target — asks how the scheme can evolve to maintain integrity, scalability, and credibility in a decarbonising economy.

      What’s in focus

      1. Strengthening the scheme’s role in meeting the 2035 target

      The CCA’s framing is clear: the ACCU Scheme remains a “high-integrity, high-impact tool,” but it must now deliver abatement at a scale that supports net-zero alignment.
      As Australia’s industrial emitters rely more heavily on offsets through the Safeguard Mechanism, the review will examine whether the supply of high-quality credits can keep pace — without discouraging direct decarbonisation.
      📘 Official source: CCA Issues Paper (October 2025, PDF)

      2. Methodologies – the engine room of the scheme

      Methodologies determine how carbon projects earn ACCUs — from soil carbon and environmental plantings to energy efficiency and landfill gas conversion.
      The CCA notes that several methods expired in 2025 and more will lapse in 2026, creating potential supply constraints. Four new methods are being developed, and a proponent-led method process is underway to accelerate innovation.

      However, the consultation flags three persistent challenges:

      • Slow method approval due to technical complexity and governance bottlenecks.
      • Transparency in how methods are reviewed and endorsed.
      • Scalability barriers for smaller or regional proponents.

      📘 See more: Clean Energy Regulator – ACCU methods list

      3. Market dynamics and price signals

      As the government steps back from being the main buyer, Safeguard Mechanism entities now dominate demand for ACCUs.
      Prices remain below the cost-containment threshold of $82.68 per tonne (for 2025/26), but analysts expect demand — and price — to rise steadily through the 2030s.
      Interestingly, the market is showing price differentiation: ACCUs with biodiversity or community co-benefits often attract premiums, while generic industrial offsets trade lower.

      📈 Market data: Reputex ACCU Market Dashboard and Jarden Carbon Market Report.

      The CCA is inviting comment on how to design the right incentives:

      • What role should government still play in purchasing or guaranteeing demand?
      • How can co-benefits (biodiversity, social impact, durability) be priced in fairly?

      My take: the assurance and legitimacy angle

      From an audit and assurance perspective, this consultation is fascinating.
      It signals that the integrity architecture of the carbon market — methodologies, monitoring, and verification — is under as much scrutiny as the credits themselves.
      For auditors, this raises several implications:

      • Auditability of carbon credits: When corporates include ACCUs in climate disclosures or offset statements under AASB S2, assurance practitioners will need to understand how each credit’s integrity is established.
      • Legitimacy through accounting: The consultation’s focus on transparency and public confidence echoes what I explore in my research — how assurance practices make markets legitimate by defining what counts as “real” abatement.
      • Future overlap with S2 assurance: As sustainability audits mature under ASSA 5000, ACCU verification processes may evolve toward shared assurance principles.

      Put simply: this review isn’t just about carbon farming — it’s about who gets to define credible carbon accounting in Australia’s next policy era.

      What businesses and auditors should do now

      • Engage early: If your organisation buys, sells, or reports on ACCUs, consider making a submission through the CCA’s Consultation Hub.
      • Map exposure: Identify which of your decarbonisation or reporting strategies rely on offsets — and which methodologies those credits come from.
      • Track method updates: Projects using soon-to-expire methods should plan for transition or re-registration.
      • Prepare for enhanced scrutiny: As integrity and transparency reforms advance, expect more robust documentation and assurance expectations in future reporting cycles.

      Final thoughts

      The ACCU Scheme has always been a cornerstone of Australia’s climate policy — but it’s also been controversial.
      This fifth review gives policymakers, industry, and auditors a chance to strengthen trust in the system before it scales further.
      By participating in the consultation, stakeholders can help shape a scheme that balances integrity, efficiency, and inclusiveness — one that rewards genuine abatement rather than paperwork.

      🔗 Further reading:

      This post reflects my interpretation of public documents and does not constitute professional or financial advice.

    • Scaling Climate Disclosure: How AASB’s Proportionality Guidance Helps Smaller Entities

      In September 2025, the AASB published a guidance note titled “Proportionality Mechanisms in AASB S2” (9 September), clarifying how entities should apply judgement so that climate disclosures are scaled sensibly to size, complexity, and capacity.
      This move helps signal that while the standard is mandatory in scope, not every disclosure has to be equally elaborate.

      What the proportionality guidance says (in practice)

      • The mechanisms allow entities to use reasonable and supportable information available at the reporting date — without undue cost or effort. (ESG Broadcast)
      • Entities can adopt more scaled-back approaches in areas like scenario analysis, methodologies, or quantification when full technical work is impracticable given their resources. (ESG Broadcast)
      • Importantly, proportionality does not remove disclosure obligations. Entities must still meet all core objectives of AASB S2, but can manage how deeply or quantitatively to go in each section. (ESG Broadcast)
      • The guidance identifies which parts of the standard are more amenable to proportional judgment (governance, risk identification, value-chain scoping, financial effect estimates, scenario work). (ESG Broadcast)

      This clarification is a strong signal: the Board expects flexibility, but wants clear documentation of judgments, method limitations, and rationale.

      Why this matters (especially for smaller or mid-tier entities)

      • Many organisations fear that compliance with S2 will require heavy modeling, climate science expertise, or third-party consultants. The proportionality guidance offers breathing room.
      • It helps bridge a capability gap: firms with limited data, technical staff, or budget can still comply meaningfully without being penalised for not doing everything at “Big 4 level.”
      • The guidance supports the phased rollout to Group 2 and 3 reporters in 2026–27 by setting expectations of scalability rather than uniformity.
      • However, the flipside: those who adopt minimal disclosures too early risk being judged harshly by auditors, regulators, or stakeholders if their rationale is opaque.

      What preparers and auditors should do now

      • Map out which portions of S2 you will scale back (e.g. limited scenario modelling, qualitative risk impact descriptions) and document why you adopted those choices.
      • Use the proportionality guidance to defend judgment calls if auditors query your methodological shortcuts.
      • Don’t over-simplify: even scaled disclosures must still respond to all four pillars (governance, strategy, risk management, metrics/targets).
      • Prepare for future benchmarking: as more entities disclose, the bar for minimal acceptable practice will evolve, so build your disclosure capability progressively.
      • Audit teams should treat proportional disclosures as red-flag areas — check whether the judgment is defensible, transparent, and consistent with your entity’s context.

      Closing (my take)

      This proportionality guidance is a smart, necessary balancing act. It signals that AASB expects inclusivity — letting smaller or less sophisticated entities comply in ways that match their capacity — while preserving the core disclosure goals.

      However, not all practitioners will interpret “proportionate” the same way. The real test will lie in assurance practice, regulator reviews, and peer benchmarking. In my upcoming research, I’ll be watching how proportionality is implemented, challenged, and rationalised — especially where scaled approaches verge on minimalism.

      📘 Source: AASB Proportionality Mechanisms in AASB S2 (9 Sept 2025) (AASB)
      Additional contextual reporting framework: KPMG’s summary of Australia’s sustainability reporting regime (KPMG)

    • Climate Disclosure Countdown: The September 2025 Milestones for Australian Reporting

      September was a busy month for Australia’s evolving climate reporting landscape. With the first mandatory disclosures under AASB S2 Climate-related Financial Disclosures due from 1 January 2025, regulators and standard-setters spent the month issuing guidance, educational materials and reminders to help companies and auditors get ready.

      Below is a concise recap of what changed or was clarified in September 2025—and what it means for reporting entities as the regime moves from policy to practice.

      1. AASB guidance on proportionality: scaling S2 for smaller entities

      On 9 September 2025, the Australian Accounting Standards Board (AASB) released guidance explaining how the “proportionality mechanism” in AASB S2 should work.
      The document outlines how entities can apply judgement to make their disclosures commensurate with size, complexity and climate exposure.

      The message is clear: the standard applies to everyone in scope, but not every disclosure needs to look the same. Smaller or less complex entities may use simplified scenario analysis or more qualitative data—so long as they still meet S2’s disclosure objectives.

      For practitioners, this guidance provides welcome clarity. It reinforces that “one size fits all” reporting was never the intent. Instead, scalability is built in, supporting the phased rollout for Group 2 and Group 3 reporters in 2026–27.

      📘 Source: AASB Proportionality Mechanism in AASB S2 (9 Sept 2025).

      2. Educational material on greenhouse gas (GHG) disclosures

      Earlier in the month, the AASB issued educational guidance on GHG emissions disclosure under S2 (2 September 2025).
      This resource supports preparers facing the technical challenge of measuring and reporting emissions consistently with S2 and the Greenhouse Gas Protocol.

      Key themes include:

      • Clarification of Scope 1, 2 and 3 boundaries (Scope 3 required from year two).
      • Emphasis on credible measurement methods and estimation techniques where data gaps exist.
      • Alignment between NGER data (for entities already reporting under the National Greenhouse and Energy Reporting Act) and the numbers disclosed in the financial report.
      • Encouragement to reference industry-based metrics (e.g. SASB or ISSB guidance) where relevant.

      The AASB also reiterated the transition relief on Scope 3 emissions: companies must describe their approach in year one but only disclose figures in year two.
      For auditors, this educational material is equally valuable—it clarifies what constitutes acceptable methodology and estimation uncertainty for assurance planning.

      📘 Source: AASB Educational Material on GHG Disclosures (2 Sept 2025).

      3. Implementation reminders, liability relief and director attestations

      Reinforcing the 2025 start date

      By September, Group 1 entities (large listed and financial sector companies) were entering final preparation mode.
      ASIC publicly reiterated that it expects “full, true and fair” climate disclosures aligned with AASB S2—and warned against selective reporting where risks appear in investor presentations but not in statutory reports.
      No new regulatory guide was issued, but ASIC’s long-standing RG 247 is effectively superseded by S2.

      “Modified liability” now in force

      A major September talking point was the temporary safe harbour protecting companies and directors from private litigation over forward-looking climate information—such as Scope 3 estimates, scenario analysis or transition plans—provided statements are made in good faith.
      The shield runs until 31 December 2027, though ASIC retains enforcement powers. The aim is to encourage frank, early disclosure while the market gains experience.

      Director declarations

      For the first three years, boards need only declare that they have “taken reasonable steps to ensure compliance” rather than that the Sustainability Report gives a “true and fair view.”
      This lighter attestation acknowledges that climate reporting is new territory while still demanding documented governance oversight.

      📘 Sources: Treasury Laws Amendment (Climate-related Financial Disclosures) Act 2024, ASIC climate reporting resources.

      4. Progress on assurance standards

      While no new assurance standard was finalised in September, the AUASB continued work on ASSA 5010, complementing ASSA 5000 (already approved earlier in 2025).
      Audit firms are now developing methodologies for limited assurance on climate disclosures for FY 2025 reports.

      Across the profession, pilot engagements and training programs ramped up—particularly within public-sector audit offices and major accounting networks. Even where assurance is not mandatory this year, many entities are seeking voluntary reviews to enhance credibility ahead of investor scrutiny.

      📘 Source: AUASB Sustainability Assurance Developments.

      5. Sector-specific observations

      No new sector exemptions or amendments were released, but regulators used September to reinforce expectations:

      • Financial institutions should be leaders in Scope 3 “financed emissions” reporting and scenario analysis for credit and investment portfolios. APRA’s Climate Vulnerability Assessment complements S2 objectives.
      • Energy and resources entities must integrate NGER emissions and TCFD-style scenario work directly into financial statements. ASIC has signalled it will look for consistency between climate disclosures and asset valuations.
      • Manufacturing and industrials should pay attention to proportionality guidance—qualitative disclosures may be acceptable initially, but planning for quantitative data is essential.
      • Real estate and agriculture are expected to highlight exposure to physical climate risks (e.g. floods, heat, drought) in line with S2’s risk-management pillar.

      Practical next steps for accountants and auditors

      1. Finalise readiness for FY 2025 reports.
      Ensure draft Sustainability Reports align with AASB S2’s structure—governance, strategy, risk management, and metrics/targets. Use the AASB Knowledge Hub as a checklist.

      2. Apply proportionality wisely.
      Smaller entities can scale disclosures but should still cover every major requirement qualitatively. Document the rationale for lighter treatment to show compliance intent.

      3. Strengthen board engagement.
      Directors must demonstrate those “reasonable steps.” Keep minutes, training records and climate discussions well documented for audit evidence.

      4. Prepare for assurance—even if limited.
      Gather calculation workbooks, emission factors, scenario models and control documentation early. These will support both internal review and external assurance under ASSA 5000.

      5. Monitor for further updates.
      Expect more FAQs and examples from Treasury, ASIC, and the professional bodies as Group 1 entities begin publishing.

      The bottom line

      By the end of September 2025, the climate-reporting framework in Australia had moved firmly from rule-making to implementation.
      The AASB provided practical tools, the AUASB advanced assurance infrastructure, and regulators made clear that high-quality disclosure—not mere compliance—will be the expectation.

      For preparers and auditors, this is the last stretch before go-live. Those who embrace the AASB’s September guidance on proportionality, emissions measurement and director accountability will be best positioned to produce credible, decision-useful climate information in 2025 and beyond.

      Further reading

    • Research Spotlight: Scope 4 Emissions and the Question of Legitimacy

      One recent paper that caught my attention is “Making things (that don’t exist) count: a study of Scope 4 emissions accounting claims” by Anna Young-Ferris, Arunima Malik, Victoria Calderbank, and Jubin Jacob-John, published in Accounting, Auditing & Accountability Journal (AAAJ).
      Read the abstract here.

      The paper examines so-called “Scope 4” emissions—avoided emissions resulting from energy efficiency initiatives or other actions that reduce emissions relative to a counterfactual. These claims are not part of the established Scopes 1, 2, and 3 framework, yet are increasingly referenced by firms and market actors.

      What I found especially interesting:

      • Scope 4 overlaps with some methodologies in the ACCU Scheme—such as avoided deforestation and energy efficiency projects.
      • The paper frames its analysis around legitimacy, noting how Scope 4 claims borrow the appearance of being part of the accepted emissions framework. Yet, it doesn’t explicitly invoke legitimacy theory. This shows how legitimacy is being performed through accounting even when not theorised directly.

      For my own work, this is a useful signal. I plan to explore how auditing contributes to the legitimisation of the ACCU scheme. This paper’s treatment of Scope 4 strengthens the case that audit plays a constitutive role in making contested things—such as offset credits—appear legitimate. It also reminds me to refine how I frame legitimacy in relation to assurance, market devices, and audit logics.

      The authors conclude with caution: Scope 4 claims risk distracting attention from the critical task of reducing absolute emissions. This resonates with wider debates about offsetting and greenwashing.

      In short: this is a sharp, thought-provoking study that opens space for further discussion of audit-made legitimacy in carbon markets.

    • Beyond the Majors: Why Mid-Tier Firms & Niche Consultancies Matter in Climate Assurance

      Large firms often dominate climate assurance conversations, but mid-tier accounting firms and specialist consultancies are quietly building important capacity—and may offer more accessible options for many businesses.

      What mid-tier / boutique players are doing

      • Grant Thornton Australia offers ESG, sustainability and climate reporting assurance and advisory services, positioning themselves as a bridge between large firms and smaller clients. (Grant Thornton Australia)
      • Perspektiv, a boutique sustainability consultancy, provides services from materiality assessments and reporting through to verification and assurance. (Perspektiv Australia)
      • FTI Consulting Australia emphasizes ESG strategy, reporting, and assurance as part of its advisory portfolio. (fticonsulting.com)
      • Texfora helps smaller clients with carbon & sustainability consulting, regulatory compliance, and reporting. (Texfora Australia)
      • Cress Consulting specialises in sustainability strategy, carbon accounting, and reporting support. (Cress Consulting)

      These firms typically present themselves as more flexible, tailored in approach, and more cost-conscious than Big 4 services.

      Where they tend to agree / converge with majors

      • Emphasis on readiness: assessing gaps, building systems, strengthening data governance.
      • Pragmatic advice: offering scalable solutions (e.g. phased adoption of disclosure modules).
      • Advisory + assurance bundling: many consultancies combine advice, reporting, and limited assurance offerings.
      • Focus on credibility and market perceptions: highlighting the importance of high-quality metrics, transparency, and stakeholder trust.

      Where their perspectives or constraints may differ

      AspectMid-tier / boutiqueContrast / limitation vs major firms
      CustomizationMore willing to tailor methodologies, timelines, and reporting scope for smaller clientsBig firms often impose more standardized frameworks or higher overhead
      Cost & scalabilityTypically lower cost and more scalable for SMEsMay lack depth or capacity for very large, global entities
      Specialist focusStronger in niche methods, sector-specific approaches, or emerging technologiesBig firms often cover many sectors, sometimes less depth in niche methods
      Capacity & coverageLimited geographic or resource reach (fewer teams, offices)Big firms have global reach, multiple teams in many locations
      Risk & credibility perceptionMay face more skepticism or require more demonstration of reliability to clientsBig firms have reputational “brand trust” that smooths client acceptance

      Why this matters for smaller / medium businesses

      • For many companies outside the coverage or budget of Big 4 services, mid-tier or specialist consultancies may be the only realistic path to credible climate assurance.
      • These firms can reduce barriers by offering modular, scaled-down assurance or reporting assistance in early years.
      • Over time, as climate disclosure enforcement tightens, these players will need to prove their technical rigor, methodological consistency, and assurance quality to compete.

      Final thoughts

      Mid-tier firms and specialist consultancies already contribute meaningful perspectives and capacity in the climate assurance space. They can serve as an important bridge in the transition to widespread disclosure and assurance. While all four Big 4 bring depth and prestige, their cost and scale may be prohibitive for many smaller organisations. In my upcoming research, I plan to examine how assurance quality, methodological variation, and provider capacity differ across this spectrum of providers—so stay tuned.

    • Big 4 Insights on Climate Reporting: What they agree, what they differ on, and what small-to-medium firms should be wary of

      The Big 4 accounting firms (KPMG, EY, Deloitte, PwC) are already deeply engaged in helping large companies navigate climate disclosure, sustainability assurance, and the transition to mandatory regimes like AASB S2. Their thought leadership and client guidance are early indicators of what the market will expect. Below is a quick comparison of their consensus views, areas of divergence, and some cautions — particularly for smaller or mid-tier firms.

      What they broadly agree on

      1. Mandatory disclosure is coming — readiness is urgent
        • All firms emphasise that entities should begin preparation now for mandatory climate disclosures starting from 1 January 2025 (for Group 1 entities). (EY)
        • They highlight that climate risk must be integrated into financial reporting, not treated separately. Deloitte states that management and boards need to connect sustainability risks with financial impact. (Deloitte)
      2. Practical tools, checklists, illustrative examples
        • EY offers an Illustrative Examples and Disclosure Checklist to help entities map their disclosures against AASB S2. (EY)
        • KPMG publishes guides and resources around accounting and reporting implications of climate disclosures. (KPMG)
      3. Governance, board oversight, and senior accountability
        • The Big 4 stress that climate disclosures require strong governance, with oversight by audit committees or board, and clarity in roles & responsibilities. (EY)
        • Many guides recommend early disclosure of transition plans, risk management processes, and scenario planning. (EY)
      4. Assurance / audit as part of the regime
        • They anticipate that climate disclosures will attract assurance requirements, phased in over time. AUSB’s new sustainability assurance standard (ASSA 5010 / ASSA 5000) has been referenced. (KPMG)
        • The Big 4 often position themselves as early movers capable of assurance on climate metrics.

      Where their advice or emphasis differs

      FirmUnique emphasis or anglePotential contrast or risk
      EYDeep on illustrative examples, detailed checklists, bridging global & local (IFRS/ISSB + AASB) (EY)Their examples may assume large, resource-rich companies — smaller firms may find them harder to apply fully.
      KPMGEmphasis on trends, external environment, benchmarking (KPMG “Sustainability Reporting Trends”) (KPMG Assets)Their trend reports may skew toward big clients, making small firm relevance less obvious.
      DeloitteFocus on readiness and linking climate risk to financial impact; workforce / capability dimensions (Deloitte)Their client readiness prescription may require expensive investments in data, systems — beyond what small firms can immediately afford.
      PwC (where visible)Less visible in what I found (fewer published checklists), but likely similar to others in pushing alignment with global IFRS/ISSB framework.Their services often bundle consulting + assurance — may be expensive for smaller clients.

      What small-to-medium firms should heed (and worry about)

      • Cost barrier / affordability risk
        The Big 4 bring premium experience and resources (global networks, data tools, assurance capacity). For many small or medium enterprises, their fees may be prohibitive.
      • Capability gap
        Big firms already have teams with climate, carbon, sustainability, and assurance expertise. Many smaller audit firms or accounting practices may not yet have trained staff or tools.
      • One-size-fits-all models
        Big 4 guidance often reflects large clients with robust data infrastructure; smaller firms will struggle to scale that model directly without adjustment.
      • Quality & variation
        While all four are experienced, there’s still uncertainty over consistency in climate assurance practices. When my research is published, I expect to comment (high-level) on variation in quality, methods, and what “sufficient assurance” actually means in practice.

      Closing thoughts

      In short: the Big 4 are doing crucial work, setting foundations, and pushing the market forward on climate reporting and assurance. For large companies, their offering is very likely the “go-to” option. But for many small to medium businesses, the cost and complexity may make them prohibitive. And as the regime scales, there is room — and need — for mid-tier firms, specialist assurance providers, and new entrants to close the gap.

      My research (once published) will also cast light on differences in quality, technique, and robustness across providers — especially beyond the Big 4.

    • CPA & CA ANZ: How the professional accounting bodies are gearing up for S2

      Australia’s new mandatory climate disclosure regime (via AASB S2) places huge new demands on preparers and auditors. Two of the key accounting and finance bodies—CPA Australia and Chartered Accountants Australia & New Zealand (CA ANZ)—are already mobilising guidance, training, and member support. But there are meaningful gaps, and a big discrepancy between what’s needed and current capability.

      Professional bodies’ guidance: common ground & differences

      What they agree on / common themes

      • Need for early preparation: Both bodies emphasise that entities should start readiness work now—data systems, climate risk assessment, governance, scenario analysis.
      • Materiality and judgement: Both underscore that climate disclosures will require more than ticking boxes—they demand judgment, especially around material climate risks and opportunities. CA ANZ has published a two-part guide to materiality in disclosures. (Chartered Accountants ANZ)
      • Bridging the knowledge gap: Both view the climate disclosure regime as a bridge between financial reporting and non-financial risk practice; members must develop new skills.
      • Practical guidance for finance teams: The guides feature roadmaps, templates, illustrative examples to help practitioners sequence work. CA ANZ’s “Practical Roadmap” guide is explicitly about preparing for S2 in Australian context. (Chartered Accountants ANZ)

      Differences & emphasis

      • Depth vs breadth:
        • CPA tends to produce broader primers (climate risk in financial reporting, general guidance) aimed at all accounting professionals. For example, CPA offers a “Climate change & financial reporting guide” which bridges climate risk and mainstream reporting. (CPA Australia)
        • CA ANZ’s recent guides are more modular and technical (e.g. materiality, scenario analysis, transition planning). Their “Information Guides” series targets specific disclosure challenges. (Chartered Accountants ANZ)
      • Training offerings:
        • CA ANZ has launched a Certificate in Climate-Related Disclosures (27 CPD hours) covering risk assessment, emissions accounting, scenario analysis, and disclosures. (CA ANZ Education Store)
        • I couldn’t find a similar dedicated certificate from CPA Australia specific to S2 (yet). CPA provides extensive climate/ESG resources and reports, but appears more focused on guides and readiness rather than full certification for climate disclosure. (CPA Australia)
      • Focus on audit / assurance readiness:
        • CA ANZ’s guidance often highlights the role of assurance, auditor judgment, and how audit practitioners should start understanding requirements now. (Chartered Accountants ANZ)
        • CPA’s guidance tends to lean more toward preparing financial teams for climate risks in standard financial statements and linking to assurance, rather than detailed assurance pathways. (CPA Australia)

      Skills & capacity gap: the looming challenge

      • Right now in Australia, only registered greenhouse & energy auditors (about 80) plus their direct associates are authorised under schemes like NGER to do assurance on emissions reporting.
      • But S2 will require many more accountants and auditors to step into climate disclosure work—and skills around emissions measurement, scenario modelling, transition planning, and forward-looking judgment will be in demand.
      • The mismatch is stark: many practitioners have financial audit experience, but few have deep climate technical skills, carbon accounting, or understanding of climate science & scenario analysis.
      • CA ANZ’s certificate is a positive step, but scaling that training to thousands of accountants will take time.
      • The bodies will need to collaborate with universities, consultancies, and firms to build capacity.

      What this means in practice (for private sector firms)

      • If your company is becoming subject to S2, you should look at which professional body your auditors or advisors belong to, and whether they have climate disclosure credentials.
      • You should begin training your finance, audit, risk, and sustainability teams now—and perhaps require certification or external training (e.g. CA ANZ’s certificate) as part of your recruitment or upskilling plan.
      • Don’t expect that most accounting firms already know how to do full S2 assurance; your first audits may be slower, more iterative, or underqualified if not planned carefully.
      • Be realistic: initial assurance might be limited in scope until practitioner capacity catches up.

      Official sources & further reading

      • CPA Australia “IFRS S1 & S2: a brief” (primer) (CPA Australia)
      • CPA Australia: Climate risk & audit guide, and climate / ESG resources page (CPA Australia)
      • CA ANZ: Information guides on climate disclosures (materiality, roadmap) (Chartered Accountants ANZ)
      • CA ANZ: Certificate in Climate-Related Disclosures course (CA ANZ Education Store)
      • KPMG summary of the new Australian sustainability reporting standards (S1/S2) (KPMG)