AICD submission: Treasury's draft climate transition planning guidance

The AICD welcomes Treasury's principles-based, voluntary approach, emphasising the need for scalable, fit-for-purpose guidance aligned with leading international frameworks, particularly the UK Transition Planning Taskforce (TPT) framework

Our key recommendations included:

• Clarify purpose and audience: We support transition plan preparers being the primary audience for the guidance. However, we recommend clearer identification of who specifically - such as large businesses subject to AASB S2 – to ensure proportionality in implementation and support both early-stage and mature preparers in developing credible, fit-for-purpose transition plans.
• Reinforce voluntary nature: The document should make clear that this is guidance only, and does not set out expectations that, if not met, will attract the criticism of regulators. In other words, it should be genuine advice to support organisations, rather than ratchet up regulatory expectations.
• Design principles: While we support the first three design principles, we are concerned about the ‘Climate first but not only’ principle. While we acknowledge the interconnectedness of climate, nature, and social issues, we recommend the guidance remain primarily focused on climate change and emissions reduction. Climate is currently the only area subject to legislated disclosure requirements, and maintaining a clear scope will support consistency, comparability, and regulatory confidence. Where nature-related issues materially intersect with climate risk or commitments, they should be dealt with in an integrated manner.
• Practical examples: Include more case studies, examples, and metrics to help preparers-especially those developing their first transition plans - translate the principles into practice.

The AICD continues to advocate for clear, practical, and internationally aligned guidance to assist boards and organisations in credible climate transition planning