AICD submission on business reporting requirements

On 9 October 2026, the AICD provided a submission to the Productivity Commission in response to its inquiry into non-financial business reporting requirements (Inquiry).

This Inquiry provided an opportunity to highlight concerns that our members have long raised regarding the cumulative weight, complexity and duplication of federal non-financial reporting requirements, particularly where there appears to be limited benefits associated with the obligation, such as improved transparency or accountability. In our submission, we firstly recommended the adoption of a whole-of-government framework that guides the development, revision and review of non-financial reporting requirements. We then recommended specific changes or areas for further analysis in a range of key non-financial reporting areas, including sustainability reporting.

The principles we put forward to guide the development and review of reporting requirements were: 

• A tell us once approach
• The benefits of reporting must outweigh the costs
• Reporting obligations should be proportionate and risk-based
• Comparable and internationally aligned obligations should be adopted wherever possible
• Reporting thresholds should be automatically adjusted
• Reporting regimes should make best practice use of technology
• Post-implementation reviews of reporting obligations should be undertaken

In addition to the adoption of these principles, we recommended that regulators and government agencies adopt a formalised process for regularly assessing the cumulative costs of reporting obligations imposed on businesses.

Our recommendations regarding specific reporting requirements were:

• Streamlining reporting under WGEA: The AICD supports the policy objectives of the Workplace Gender Equality Act reporting requirements and endorses initiatives to reduce the associated regulatory burden, including enabling the Workplace Gender Equality Agency to use data employers have already provided to government and developing digital reporting solutions.
• Revising climate reporting thresholds: We continue to recommend limiting the scope of mandatory climate reporting to groups 1 and 2 only, with NFPs explicitly excluded given the significant compliance costs involved.
• Maintaining limited assurance for climate reports to 2035: Given the complexity of climate reporting, ongoing capability constraints and challenges for assurance providers, our view is that a mandatory transition to reasonable assurance should be delayed to 2035 to provide an opportunity for the assurance market and supporting systems to mature and costs for entities to stabilise. 
• Addressing duplicative emissions reporting: Entities that are subject to AASB S2 climate reporting, the National Greenhouse and Energy Reporting Scheme and/or the Safeguard Mechanism have to repeat their Scope 1 and 2 emissions data disclosure. This could be addressed by greater harmonisation to reduce costs and the burden on reporting entities. 
• Harmonising reporting and notification requirements for data and cyber incidents: Harmonisation efforts should be undertaken such that an entity’s reporting to different regulators and agencies under different frameworks is consolidated to the greatest extent possible. The current reporting landscape results in significant compliance costs and creates challenges when responding to a cyber attack or data breach.
• Reducing the burden of financial services reporting: Currently, financial services entities need to maintain multiple compliance processes to produce substantially similar information. Information sharing and greater consistency in data definitions, reporting formats, reporting periods and coordinated regulatory information requests would simplify compliance.   
• Implementing longer-term reforms to align quality and safety regulation of the care economy: Establish a single set of practice and quality standards, a single system for provider audits and a ‘tell us once’ approach to address duplicative standards and multiple regulators across different sectors and jurisdictions.

Re-considering introduction of a ‘failure to prevent’ criminal offence and increasing modern slavery reporting thresholds: While not within the scope of this Inquiry, we strongly oppose the introduction of a ‘failure to prevent modern slavery’ criminal offence, and consider the current $100M revenue threshold for reporting should be set at a higher level. Our separate submission on modern slavery reporting lays out these views in detail.