Australian Government publishes climate-related transition planning guidance
Transition planning is an ongoing strategic process through which organisations identify, assess their exposure and respond to climate-related risks and opportunities (CROs) and deliver their climate ambition. Transition planning informs mitigation and adaptation measures that an organisation can take and provides a pathway to realise the emission reduction targets set by an organisation.
80% of ASX200 companies by market capitalisation have set net zero emissions targets1, and organisations face growing market expectations to demonstrate how they plan to meet these targets and respond to the transition and changing climate. The guidance forms part of the Australian Government's Sustainable Finance Roadmap and complements other priority initiatives including the mandatory climate-related financial disclosure regime and the Australian Sustainable Finance Taxonomy (see Navigating the New Landscape of Climate Reporting: Lessons from New Zealand and Climate litigation in Australia: Key developments in 2025 and what's ahead for 2026).
On 24 August 2026, the Australian Government published voluntary guidance on climate-related transition planning. The guidance, which does not create an obligation to prepare a transition plan or inform mandatory disclosures under AASB S2, is intended to support organisations in undertaking good practice, internationally-aligned transition planning regarding the impacts of the net zero transition and changing climate on their operations.
Providing voluntary guidance for transition planning was one of the priority initiatives identified in the Australian Government’s Sustainable Finance Roadmap. The guidance reflects the consensus from extensive consultation during 2025 with government, industry and non‑government stakeholders including those represented on a Transition Plan Working Group.
The guidance is framed as supporting the internal planning process rather than disclosure, directly responding to requests from the accountancy sector for greater clarity on this distinction.
The guidance builds on the TPT Transition Planning Cycle2 while incorporating Australian policy, physical-risk and regulatory context including references to governance, capital expenditure alignment, carbon-credit mitigation hierarchy and stakeholder engagement and dedicated First Nations content. These include references to the Australian Net Zero Plan3, sector emissions reduction plans4, the National Climate Risk Assessment5 and the National Climate Scenario Guidance6. Governance, capital expenditure alignment, carbon-credit mitigation hierarchy and stakeholder engagement, including dedicated First Nations content, were all substantially incorporated.
The guidance adopts a four-stage planning cycle:
Adaptation is embedded alongside mitigation throughout the four stages, responding to submissions from the academic sector emphasising Australia's high physical-risk exposure.
A notable feature of the guidance is the three-tier proportionality framework, which differentiates the approaches organisations can take towards transition planning:
Focus on fundamentals (Low climate risk exposure | Low complexity): a credible, principles-aligned climate narrative that articulates ambition and clearly signals intent for action.
Fully business integrated (Medium climate risk exposure | Medium complexity): transition planning fully embedded within business strategy, governance and risk management processes.
Technical and target aligned (High climate risk exposure | High complexity): rigorous and investment-grade strategic ambitions based on scientific evidence supported by detailed analysis and targets.
This graduated approach allows less experienced organisations to commence with simpler ambitions and improve over time and those in sectors with a lower exposure to climate risks to take a proportionate approach to their transition planning.
While the Australian guidance builds on the TPT architecture, key distinctions exist:
Organisations considering transition planning may use this guidance as a structured starting point, adapting its four-stage process to their circumstances. Although voluntary, the guidance articulates what Treasury considers good practice and may inform investor, lender and stakeholder expectations over time.
Reporting entities subject to AASB S2 should note that the guidance does not address those disclosure obligations; those entities should refer separately to AASB and ASIC materials8.
Further voluntary guidance and sector-specific materials are signalled for future development, and organisations are encouraged to engage with the Sustainable Finance Taxonomy as a complementary tool for identifying transition levers and setting financial targets.
Authors: Elena Lambros, Partner, Risk Advisory; Becky Clissmann, Expertise Counsel and Rob Heslenfeld, Executive, Risk Advisory.
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