ASRS vs TCFD vs GRI: Which Framework Do You Actually Need?

We had a call last month with a sustainability manager at a mid-sized construction firm in Sydney. She rattled off five frameworks her board wanted covered: TCFD, GRI, CDP, ISSB, and ASRS. Her consultant had scoped the work at $145,000. When I asked her which of those were actually required by law, she paused. "I assumed all of them?"

None of them were. Except one.

If you're an Australian company trying to figure out the ASRS vs TCFD differences — or where GRI and CDP fit into the picture — you're not alone. The alphabet soup of climate reporting frameworks has been confusing for years. But 2025 changed things. Australia now has a single mandatory standard, and one of the most well-known voluntary frameworks literally doesn't exist anymore. Most mid-market companies are overcomplicating this, spending money on frameworks they don't need while scrambling to get the one they do need right.

Here's the honest breakdown.

TCFD is dead. ASRS ate it.

The Task Force on Climate-related Financial Disclosures disbanded in October 2023. That's not a rumour or a forecast — the FSB formally wound it down and handed monitoring responsibilities to the IFRS Foundation. If you're still referencing TCFD in your 2026 reporting strategy, you're referencing a ghost.

But here's the part that matters: TCFD didn't just disappear. Its DNA is inside ASRS. The ISSB built IFRS S2 to be the "culmination of the work of the TCFD" — their words, not ours. And AASB S2, Australia's mandatory climate standard, is the local adoption of IFRS S2. Same four pillars. Same structure. Governance, strategy, risk management, metrics and targets.

Every single one of the eleven TCFD recommended disclosures is fully incorporated into IFRS S2 (and by extension, AASB S2). If you comply with ASRS, you've met the TCFD recommendations. Full stop.

So if a consultant tells you that you need to "align with TCFD" as a separate workstream, ask them what specifically TCFD requires that ASRS doesn't. The answer is nothing. You might still mention TCFD alignment in your report as a reference point — that's fine for investor optics — but you don't need a separate project for it.

KPMG's 2024 survey found that 76% of ASX100 companies were already reporting aligned with TCFD recommendations. Those companies have a head start on ASRS. Everyone else needs to get moving, but on ASRS — not on a defunct framework.

Where GRI fits (and where it doesn't)

GRI is a different animal entirely. While ASRS asks: "how does climate affect your company's financial value?" GRI asks: "how does your company affect people and the environment?" That's not a subtle distinction. It's a fundamentally different question.

ASRS uses what's called financial materiality — sometimes called single materiality. A climate risk is material if it could reasonably influence investor decisions about your company. GRI uses impact materiality (and increasingly, double materiality alongside the European CSRD). Under GRI, a topic is material if your company has a significant impact on the economy, environment, or people — regardless of whether it affects your share price.

In practical terms: an Australian mining company might have significant water usage that doesn't pose a material financial risk (because water is cheap and plentiful at their site). Under ASRS, they might not disclose it. Under GRI, they absolutely would, because the environmental and community impact is real.

Here's the thing. GRI is voluntary in Australia. Nobody at ASIC or the Clean Energy Regulator will fine you for not filing a GRI report. But about 60% of ASX300 companies that produce standalone ESG reports reference GRI methodology, according to First Advisers research. GRI remains the most widely used impact-reporting framework globally, and some stakeholders — particularly European investors, NGOs, and certain procurement teams — expect it.

Our take: if you're a mid-market Australian company (say, 200 to 500 employees, $200M to $500M revenue), GRI is probably not your first priority in 2026. Get your ASRS house in order. That's the one with penalties attached — up to $15 million or 10% of annual turnover. Once your mandatory climate disclosures are solid, then consider GRI if your stakeholders are asking for broader impact reporting. But don't try to do both simultaneously from scratch. That's how you blow your budget and deliver neither well.

CDP: voluntary but not really optional for some companies

CDP (formerly the Carbon Disclosure Project) is a disclosure platform, not a standard per se. Over 22,100 companies disclosed through CDP in 2025, representing more than half of global market capitalisation. It's now fully aligned with ISSB's IFRS S2 as its baseline for climate disclosure, which means there's significant overlap with what you're already doing for ASRS.

Here's when CDP actually matters for your business. If a major customer or investor requests you disclose through CDP, you're going to do it. That's how CDP works — through supply chain and investor pressure. Companies like Telstra request their suppliers disclose climate data through CDP. If you're in their supply chain and you ignore the request, you're not breaking a law, but you might lose the contract.

We're still working out the cleanest way to map ASRS data directly to CDP questionnaire fields — there's real overlap, but the formats are different enough that it's not a simple copy-paste job. CDP's 2024 alignment with ISSB S2 helps, but the questionnaire includes additional questions around biodiversity, water, and deforestation that ASRS doesn't touch.

The practical question is simple: has anyone asked you to disclose through CDP? An investor, a customer, a supply chain partner? If yes, it's worth the effort. If no, park it. Focus on ASRS.

A decision framework that actually works

Rather than a matrix of every possible scenario, here's how we think about it. Three questions. That's it.

Are you caught by ASRS? If you meet two of three thresholds for Group 1, 2, or 3, or you're an NGER reporter, ASRS is mandatory. Not optional, not "best practice," not a nice-to-have. This is the one. Spend your money here first.

Has a customer, investor, or supply chain partner requested CDP disclosure? If yes, budget for it. The good news is that maybe 60-70% of the data work overlaps with ASRS. The bad news is the remaining 30% can still take weeks, especially if you're going for a decent score rather than just submitting something.

Do your stakeholders expect broader impact reporting (GRI)? This is most relevant if you have European investors, if your industry has a GRI Sector Standard (mining, oil and gas, agriculture, coal all do), or if you're competing for contracts where ESG credentials are scored. If none of those apply, GRI can wait.

That's the decision tree. For probably 80% of Australian mid-market companies, the answer is: ASRS mandatory, CDP maybe, GRI later.

The materiality trap

One thing that trips companies up is assuming all frameworks want the same information presented differently. They don't. The materiality lens is different, and that changes what you report.

Under ASRS (financial materiality), you're telling investors: "Here's how climate affects our bottom line." Under GRI (impact materiality), you're telling stakeholders: "Here's how our operations affect the world." A topic can be material under one framework and immaterial under the other. Water usage at a mine in a water-rich area might matter to GRI but not ASRS. A carbon price risk on your gas-fired assets matters enormously to ASRS but wouldn't appear in a GRI report unless there's also an environmental impact.

Companies that try to do a single materiality assessment for all frameworks end up with a muddled mess. If you're going to report under both ASRS and GRI eventually, do two separate assessments. It costs more upfront, but you'll produce cleaner disclosures that actually satisfy each framework's users — rather than one report that half-satisfies everyone.

We've seen companies spend $30,000 on a "double materiality assessment" that delivered a consultant's PowerPoint deck with no usable data for either ASRS or GRI reporting. Don't be that company.

What this actually costs

Nobody likes talking about reporting costs in concrete numbers, so here goes. For a mid-market company (250-500 employees, Group 2 under ASRS), based on what we've seen across prospect conversations:

ASRS only: $80,000 to $200,000 in year one, depending on whether you use consultants, software, or both. That includes the materiality assessment, data collection, scenario analysis, drafting disclosures, and limited assurance. Year two drops significantly once your systems and processes are established.

ASRS + CDP: Add $15,000 to $40,000 for CDP-specific preparation, depending on complexity and whether you're aiming for a high score or just responding to a request.

ASRS + CDP + GRI: Add another $30,000 to $80,000 for a proper GRI report with its own materiality assessment and stakeholder engagement process. This is where costs start stacking up fast.

All five frameworks simultaneously: We've seen quotes north of $300,000 for the first year. And honestly, the output quality suffers because the team is spread too thin.

The $145,000 our Sydney contact was quoted for five frameworks? That was actually on the low end, which tells me corners would've been cut somewhere. Probably on data quality — which is the one place you can't afford to cut corners given the ACCC's greenwashing enforcement posture. They imposed $8.25 million in penalties on Clorox in February 2025 for misleading environmental claims. Your numbers need to be defensible.

The order of operations matters

If you take one thing from this post, let it be this: sequence your framework adoption. Don't try to boil the ocean.

Year one: get ASRS right. Nail your Scope 1 and 2 emissions data. Build your governance structures. Run your scenario analysis. Get through your first limited assurance engagement without the auditors sending everything back.

Year two: layer on CDP if stakeholders are requesting it, and start your Scope 3 data collection (which ASRS mandates from your second reporting period anyway).

Year three onwards: consider GRI if your stakeholder landscape demands it, particularly if you're expanding into European markets or your sector has a GRI Sector Standard.

That sequencing isn't just about budget management — though it helps. It's about data infrastructure. The emissions data you collect for ASRS forms the backbone of what CDP and GRI will need anyway. Build the foundation once, properly, and the additional frameworks become extensions rather than separate projects.

That's exactly what we're building Carbonly to do — collect and validate the underlying emissions data once, then output it in whatever framework format your stakeholders need. We're not there on every framework yet (we're honest about that), but the data layer is the hard part, and that's where we've focused.