Most of the Australian Accounting Standards Board (AASB) S2 (Climate-related Disclosures) reports from first disclosures treat transition risk as something that is coming, not something that is happening. The September 2025 Electricity and Energy Sector Plan and the April 2026 Safeguard Mechanism data say otherwise. The transition is already priced into the physical system. The recent climate-related disclosures haven't caught up.
Renewables now supply over 40% of generation in the National Electricity Market (NEM) and the South West Interconnected System (SWIS). According to the Energy Sector Plan, Rooftop solar — on more than a third of Australian homes — provides 11% of electricity, more capacity than every remaining coal plant combined. And electricity emissions have fallen 22% since 2005 and peaked in 2009.
Treasury's Baseline modelling projects electricity sector emissions dropping from 140 Mt CO2-e in 2025 to 9 Mt by 2050, with only 2 GW of NEM coal capacity left by 2035. Most of Australia's coal fleet is already over 40 years old and due to close this decade if more extensions are granted.
If you run a coal asset, a gas peaker, or a vertically integrated retailer, this is not a 2040s scenario. It's an asset-by-asset question about who pays for stranded value and when.
Yet in the AASB S2 disclosures coming from Group 1 companies are presented as a future problem.
The Clean Energy Regulator released the 2024–25 Safeguard data in April. 208 facilities, 132.8 Mt CO2-e covered. Total covered emissions fell 2.3% year-on-year. On a like-for-like basis Michael West reports the real on-site reduction is closer to half that because offset use jumped 45%. 10.8 million ACCUs and 2.6 million SMCs were surrendered, up from 7.6 million and 1.4 million. Over 80% came from methods with documented integrity problems, including avoided-deforestation credits wound down after the Chubb Review.
If your transition plan leans on Safeguard compliance as evidence of decarbonisation, your auditor, and increasingly your investors, will ask whether that compliance is abatement or accounting. Those are two very different numbers to disclose.
Three numbers from the Net Zero Plan that rarely make it into a climate risk register:
The Australian Energy Market Operator (AEMO) states that data centre load in the NEM will grow from 4 TWh today to ~12 TWh by 2030 and ~34 TWh by 2050. This means that retailers are signing long-dated Power Purchase Agreements against this demand now.
Domestic electricity demand is set to double by 2050. That means 5,000 km of new east-coast transmission is needed inside this decade.
A disorderly transition pushes wholesale electricity prices up 17% in the 2030s and 54% in the 2040s, per Treasury. A renewable-exports upside scenario pushes them down 20% by 2050.
That's a 70-point spread in wholesale prices depending on execution. It belongs in scenario analysis under AASB S2 for anyone in the supply chain, not just in a footnote.
Three things we find missing in most first-year filings:
Asset-level coal and gas exit timing, not a sector-wide 2050 aspiration. The Sector Net Zero Plan has coal essentially gone from the NEM by 2035. Your disclosures should reconcile to that, asset by asset.
Offset reliance, broken out from real abatement. If Safeguard compliance is in your plan, separate tonnes reduced from tonnes surrendered. Investors will do this calculation anyway — or the scrutiny of journalists will.
A wholesale price sensitivity tied to the Treasury scenarios. Disorderly +17% to +54%. Renewable-exports upside -20%. You should pick your assumption and show your working.
The risk isn't that the transition is uncertain. It's that the numbers describing it are now specific, public, and inconsistent with what most energy companies disclose.
Group 1 reporters have just one more cycle before their second filings. That's not long to close the gap between the system's reality and the risk register.
Afonso Firmo is the co-Founder and co-CEO of NetNada, which helps Australian businesses produce audit-ready AASB S2 disclosures.