Clarity for Certainty: Advancing Corporate Policy Engagement Transparency in Australia

Roman Davas-Fahey, Global Voices, COP29 2024 Fellow

Executive Summary

In Australia, many leading companies publicly endorse climate action; yet their policy engagements are frequently misaligned with the Paris Agreement - undermining their pro-climate commitments (InfluenceMap, 2021, 2024a). Despite the Australian Government’s recognition of the critical role investors play in funding the country's transition to net zero, investors have limited insight into the corporate policy engagement (CPE) activities of Australian companies. This is largely due to the absence of strong lobbying transparency laws and inadequate voluntary disclosures by companies (InfluenceMap, n.d.; Ng, 2020; The Senate, Finance and Public Administration References Committee, 2024).

A lack of transparency on corporate engagement in public policy presents significant risks to investors and undermines Australia’s pathway to net zero. This paper explores the risks associated with undisclosed CPE activities and their impact on investors, with a specific focus on climate lobbying. It highlights how poor transparency of CPE activities creates policy uncertainty, delays regulatory action, and weakens investment signals. 

Drawing on international frameworks – most notably the European Sustainability Reporting Standard (ESRS) requirements for political engagement disclosures – this paper recommends amending the Corporations Act 2001 (Cth) to mandate Australia's current voluntary Sustainability Reporting Standards (ASRS SSB1) and expanding them to include corporate policy engagement. Such a policy would position Australia as a leader in corporate accountability and governance, ensuring companies provide detailed and consistent information on their lobbying activities, political contributions, and the alignment between their public commitments and policy engagements. Two main risks emerge: industry pushback against the additional reporting costs, and limited political appetite for mandating disclosures of corporate policy-engagement activities.

Problem Identification: Corporate Policy Engagement is Material to Investors

Corporate policy engagement (CPE) encompasses a wide range of corporate activities aimed at influencing government policy and public discourse, including lobbying, public campaigns, research sponsorship and political financing (Bombardini & Trebbi, 2025; Mialon et al., 2016; OECD, 2022; UNEP et al., 2013). 

Corporate engagement in public policy is increasingly recognised as an investment risk, where CPE activities create firm and industry-level risks and amplify systems-level risks (OECD, 2022; PRI, 2022). CPE activities contribute to policy uncertainty by obstructing critical climate policies, delaying regulatory action, and the investment signals needed for the energy transition (Australasian Centre for Corporate Responsibility (ACCR), 2023; InfluenceMap, 2024a). This increases financial risk for investors, who seek stable and predictable policy environments to guide capital allocation (Investor Group on Climate Change (IGCC), 2025). For example, a survey by IGCC of investors representing $37 trillion of Australia’s institutional capital market found 40% of investors cited policy and regulatory uncertainty as a major barrier to investment (IGCC, 2024a). 

There is increasing investor demand for greater CPE transparency on material issues, particularly climate change (Climate Action 100+, 2024a; Newton, 2024). A key example is Climate Action 100+, the largest-ever global investor engagement initiative on climate change, which now comprises 700 investors responsible for over $68 trillion in assets under management (Climate Action 100+, 2024a). The initiative specifically prioritises policy engagement disclosure and alignment in its benchmark assessment. Investors are also becoming increasingly vocal about corporate lobbying practices and strengthened oversight of CPE at annual general meetings (Climate Action 100+, 2024b; Interfaith Center on Corporate Responsibility, 2025). Data from S&P Global highlights that resolutions related to climate change and corporate lobbying outpaced other shareholder concerns in 2024 (Rives, 2024). While this proposal focuses on CPE related to climate change, the rationale for enhanced disclosure requirements is equally relevant to other areas of public policy influence, such as on nature and health (WMBC, 2023).

The Australian Government recognises the critical role that investors play in funding Australia’s transition to net zero and the need for rigorous, internationally aligned and credible disclosures (Australian Government, Department of Treasury, 2024a). Achieving Paris Agreement-aligned targets in Australia will require $420 billion to decarbonise the National Electricity Market (Clean Energy Investor Group & Baringa, 2022; IGCC, 2024b). Yet, investor insight into the CPE activities of Australian companies remains limited, largely due to the absence of strong lobbying transparency laws and inadequate voluntary disclosures by companies (InfluenceMap, n.d.; Ng, 2020; The Senate, Finance and Public Administration References Committee., 2024).

Context

How Policy Engagement is Material to Investors

(a) CPE as systemic risk - Climate Lobbying in Australia

Many large institutional investors, such as pension funds and asset managers, regard negative corporate policy engagement as a major risk to systems risk management, as it can contribute to delays in policies considered necessary by the government for mitigating the impacts of climate change (InfluenceMap, 2024b; Newton, 2024). The case of climate lobbying in Australia demonstrates how CPE activities shape the policy environment and create systemic risk for investors. 

Many leading companies in Australia engage in ‘climate lobbying’ activities to block progressive climate policy, often through industry associations (ACCR, 2023; InfluenceMap, 2025). InfluenceMap’s research shows that corporate policy engagement is having significant consequences for Australian climate policy. For example, of the 14 policies analysed in their research, six were repealed, weakened or blocked from ambitious reform following overwhelmingly negative policy engagement from the corporate sector (Influence Map, 2023), delaying Australia’s transition to net zero (Climate Integrity, 2024). 

(b) CPE as company-level investment risk - Legal and Regulatory Risks

CPE activities that are not transparent or are misaligned with a company’s public commitments can expose the company to regulatory scrutiny and legal actions. In Climate Integrity's (2024) report, legal opinion from the Environmental Defender’s Office highlights the potential legal risks for companies that make net zero commitments and then undertake lobbying that is misaligned with those commitments. These include risks of action against misleading or deceptive conduct, risks associated with increased shareholder advocacy, and tort-based claims against companies involved in serious climate misinformation.

ACCR found that of 50 leading ASX-listed companies, including BHP and Rio Tinto, there was a significant gap between companies’ asserted stances on climate policy and their advocacy efforts (ACCR, 2023). Energy and resource companies have some of the highest levels of engagement with climate policy in Australia, and 14 of the 15 most engaged companies have active net zero commitments (InfluenceMap, 2024a). Yet, their policy engagements are frequently misaligned with the Paris Agreement - undermining their pro-climate commitments (InfluenceMap, 2021). This is increasingly relevant to sustainability as Australian regulators, consumers and investors increase their scrutiny of greenwashing (ACCR, 2023; Davis, 2024).

Current Policy Landscape

Regulation of Lobbying Activities

Lobbying regulation in Australia is primarily governed by the Register of Lobbyists and the Lobbying Code of Conduct. Both instruments leave significant transparency and integrity gaps (Australian National Audit Office, 2020; Tonkin & Florence, 2024). Key gaps include a narrow definition of lobbyist in Australia’s Register of Lobbyists, particularly the omission of “in-house” lobbyists, thereby only accounting for 20% of all professional lobbyists (Our Democracy, 2024). The Australian Federal Register also does not provide details on specific lobbying activities, such as when, where, and with whom lobbyists met, the specific objectives of the meeting or how lobbying activities are conducted (Lacy-Nichols et al., 2023).

While these gaps in Australia’s integrity system have received significant attention (Pocock, 2024), multiple efforts to improve transparency have been repeatedly turned down (Crowe, 2024; Ng, 2020; Rennie, 2017), suggesting a degree of political hesitation towards regulatory reforms. This was demonstrated following the Senate Inquiry into access to the Australian Parliament House by lobbyists, which, despite highlighting inadequacies of current regulation, failed to present decisive recommendations in line with its findings (Tham, 2024; The Senate, Finance and Public Administration References Committee, 2024). Meaningful lobbying reforms remain critical to long-term political transparency and accountability in Australia (Transparency International Australia, 2025); however, complementary measures that provide timely, investor-relevant information can sustain progress while broader legislative reforms build political momentum.

Voluntary Corporate Disclosures

The Australian Accounting Standards Board (AASB) released the Australian Sustainability Reporting Standards (ASRS) in September 2024. The suit consists of the voluntary AASB S1 General Requirements for Disclosure of Sustainability-related Financial Information and the mandatory AASB S2 Climate-related Disclosures. Both standards track the inaugural International Sustainability Standards Board’s (ISSB) standards, IFRS (International Financial Reporting Standards) S1 and IFRS S2, with only minor Australian tailoring (KPMG, 2025). Because IFRS S2 embeds the structure of the Task Force on Climate-related Financial Disclosures (TCFD) and the ISSB has formally assumed responsibility for TCFD guidance, the ASRS provides a platform for widening corporate transparency. What it currently lacks is any requirement that companies report on political influence or lobbying activities.

In the absence of comprehensive corporate disclosure requirements on CPE activities, voluntary guidance frameworks have emerged with CPE disclosure criteria. However, analysis highlights how these voluntary-based systems are not providing quality information on lobbying to the investment community, with companies failing to provide robust and transparent information on their CPE activities (Climate Action 100+, 2024a; InfluenceMap, n.d.-a). InfluenceMap's analysis of over 450 companies revealed that in 2021, fewer than 5% fully disclosed their policy engagement activities, while more than 80% offered disclosures that were inadequate, incomplete, or difficult to access.

Opportunities for Corporate Policy Engagement Disclosures in Australia

Mandatory sustainability reporting provides a suitable alternative, as international case studies demonstrate, as it can facilitate reporting on a variety of criteria. The new European Sustainability Reporting Standards (ESRS), prepared by the European Financial Reporting Advisory Group (EFRAG) and published in the Official Journal on 22 December 2023, provide a useful case study on how mandatory sustainability reporting could be used to fill this gap (Christensen et al., 2021; European Commission, 2025; Hummel & Jobst, 2024). These standards apply to companies under the scope of the Corporate Sustainability Reporting Directive (CSRD) and inform mandatory sustainability disclosure requirements at the EU level. It includes a disclosure requirement under the Business Conduct standard (ESRS G1) referring to “Political influence and lobbying activities”, requiring disclosures on policy engagement activities, main topics and positions being advocated on (European Financial Reporting Advisory Group, 2023).

Research from Transparency International UK finds that, of a sample of 90 UK-listed companies, 35% identify anti-corruption and bribery, and 23% identify political engagement as material sustainability matters (Lacey et al., 2024). Companies that identify ‘political engagement’ as material will need to report in line with ESRS G1 Business conduct. This could include reporting information on the company’s lobbying activities (types and purposes); and its political contributions (financial or in-kind). The ESRS builds on international frameworks like the IFRS and Global Reporting Initiative (GRI), while incorporating additional inclusions. 

While many firms are now disclosing under ESRS Business Conduct (G1), early reviews of the ESRS implementation still find little details on the progress of political engagement reporting (McKay, 2025; Picard et al., 2025). Formal monitoring and enforcement processes are still developing across EU member states (Timmermann & Zalinyan, 2024). Even so, the ESRS remains the most globally significant regulatory framework covering CPE disclosures (Alemanno et al., 2025), offering Australia a valuable early case study to build on.

Options

There are several policy levers available to the Australian Government which could increase the transparency of CPE activities. These are:

1. Expand the Definition of Lobbyists Under Australia’s Register of Lobbyists and Increase Lobbyist Reporting Obligations

   
   

This option would broaden the definition of “lobbying” and “lobbying activities” within the Register of Lobbyists and require all professional lobbyists and actors who seek to influence the government to disclose who they have met with on a public register, along with how, where, and for what specific objectives. Lobbying reforms are essential for lasting political transparency and accountability in Australia, but as momentum and pressure for those reforms builds, complementary measures that deliver company-specific, investor-grade data are also needed.

2. Mandate Australia’s Voluntary Sustainability Reporting Requirements in ASRS SSB1 through the Corporations Act 2001 (Cth) (Corporations Act) and expand to include Policy Engagement Disclosures

   
   

This option would incorporate corporate political engagement and lobbying activities within ASRS SSB 1’s voluntary framework, focusing on instances where these may represent material business risks. Mandating the standard would deliver clearer, investor-grade transparency but would also raise compliance and supervisory costs for companies and regulators. The Australian Accounting Standards Board (AASB) would draft the expanded requirements, while the Auditing and Assurance Standards Board (AUASB) would ensure compliance and provide assurance. Implementing this requirement through existing ASRS cycles offers a ready path to greater transparency and can be validated against future, more granular federal lobbying records once reforms are enacted.

3. Expand Australia’s Voluntary Sustainability Reporting Requirements in ASRS SSB 1 to Include Political Engagement Disclosures

   
   

This option would incorporate CPE activities within ASRS SSB 1’s voluntary framework, focusing on instances where these may represent material business risks. While this option may offer an incremental step towards greater disclosures, the poor performance of voluntary corporate disclosures of CPE suggests this option is unlikely to be impactful.

Policy recommendation

Option 2, ‘Mandate Australia’s Voluntary Sustainability Reporting Requirements in ASRS SSB1 through the Corporations Act 2001 (Cth) (Corporations Act) and expand to include Policy Engagement Disclosures’ is recommended as the most effective policy option for improving corporate transparency and addressing material risks related to policy engagement. This policy option builds on the global alignment provided by the ISSB’s IFRS S1 (IFRS, n.d.) while expanding its scope to require disclosures on corporate policy engagement activities. These disclosures are essential for enabling investors to assess material risks, engage meaningfully with companies and make decisions about capital allocation. Such a mandate would position Australia as a leader in transparent corporate governance.

As implemented in the ESRS G1 Business Conduct under Disclosure Requirements G1-5 – Political influence and lobbying activities, it is recommended the addition of new political engagement disclosure requirements be integrated into the ASRS AASB S1 under the existing governance section. These disclosures would include:

• Lobbying Activities: a breakdown of lobbying efforts related to issues material to entity operations, both direct and indirect via industry associations and think tanks.

• Political Contributions: full transparency of financial contributions to political parties, campaigns, and related activities.

• Policy Alignment: an assessment of the alignment between public commitments and lobbying practices.

These disclosures align with global best practices, including the ESRS (G1 Business Conduct) and the Global Standard on Responsible Corporate Climate Lobbying (Responsible Climate Lobbying: The Global Standard, 2022). Implementation of these disclosures would result in greater transparency and accountability for corporate political engagement in public policy, particularly climate policy, and improve information flows and materiality to investors, enabling investors to be better informed on the full picture of CPE activities.

Phasing

This policy would be implemented through a phased approach, as adopted for the implementation of mandatory climate-related financial disclosures, over four years to ease the transition for companies in meeting the reporting requirements and to delay complete disclosures of certain information, even if material (Australian Government, Department of Treasury, 2024a). The transition would begin with large publicly listed companies and high-impact sectors before scaling to smaller entities. Phase provisions would be partly dependent on the size or nature of the reporting company – see Appendix A. The AASB would lead the revision and operationalisation of the ASRS SSB1, while the Treasury would oversee the necessary legislative amendments. The AUASB would ensure compliance and provide assurance that reported disclosures meet required standards.

Total Implementation Costs 

A preliminary estimate would require up to approximately $12 million over the first three years.

Predicted Costs 

Funding for this initiative would be drawn from existing allocations to the AASB and AUASB and would also require additional resourcing. The AASB, which received $9.563 million in 2024-2025 for sustainability reporting and $15.261 million in total for the following three years (Australian Government, Department of Treasury, 2024, p. 358), would require an additional $5-7 million over three years to expand and incorporate these new requirements. The AUASB, which received $4.121 million in 2024–25 and $11.2 million in total for the following three years (Australian Government, Department of Treasury, 2024, p.336), would require an additional $2-3 million for auditing and assurance efforts. The Treasury, which received $2.2 million between 2023-2025, would require an additional $2 million. 

Limitations

Determining what constitutes material policy engagement will vary across sectors, company structures, and governance contexts, making it challenging to establish a widely accepted definition. In the absence of a consistent definition in the Australian context, the proposal draws on international best practice, recommending the use of existing thresholds and definitions from jurisdictions with robust transparency regimes—such as Ireland’s lobbying register and U.S. federal political donation disclosure laws (Federal Election Commission, n.d.; Standards in Public Office Commission., 2023)—as interim guidance for identifying relevant activities.

Ensuring compliance with CPE disclosure requirements will also require robust regulatory oversight to verify disclosure data. Until comprehensive regulatory reforms are introduced to validate disclosures, third-party databases such as InfluenceMap’s LobbyMap (InfluenceMap, n.d.-b) provide an alternative means for civil society organisations (CSOs) and investors to verify corporate lobbying disclosures. 

Risks and Barriers

Given the recent publishing of the ASRSs in September 2024 and the industry pushback experienced during the consultation process, opposition from industry is once again expected to be a barrier to policy implementation. In the lead-up to implementing mandatory climate-related financial disclosures, there was significant industry resistance, demanding companies be given more time. Industry pushback could be substantial, given the proposal would impose additional costs on firms resulting from new and greater reporting requirements. For example, while disclosing climate risk under TCFD, which is less prescriptive than the AASB S2, it is costing firms between $250,000 to $400,000 per year per firm (Australian Government, Department of Treasury, 2023). Political buy-in is also a risk, given the proposal for disclosures of political engagement activities. Adopting a gradual, phased approach could address industry concerns and capacity for compliance. This approach allows companies to adapt to new requirements progressively.

References

Alemanno, A., Stewart, H., & ZInnbauer, D. (2025). The Good Lobby Tracker Report 2025. The Good Lobby. https://www.thegoodlobby.eu/wp-content/uploads/2025/01/The-Good-Lobby-Tracker-Report-2025-3.pdf

Althaus, C., Bridgman, P., & Davis, G. (2018). The Australian policy handbook: A practical guide to the policy-making process. Allen & Unwin. https://research.ebsco.com/linkprocessor/plink?id=8d84f238-459c-3fc2-a73f-86da40023199

Australasian Centre for Corporate Responsibility. (2023, June 8). Submission—Greenwashing Inquiry. https://www.accr.org.au/downloads/accrsubmission_greenwashinginquiry_062023.pdf

Australasian Centre for Corporate Responsibility (ACCR). (2023). Benchmarking for change: Corporate political expenditure and climate lobbying in Australia. Australasian Centre for Corporate Responsibility (ACCR). https://www.accr.org.au/downloads/1023_accr_benchmarkingforchange.pdf

Australian Government, Department of Treasury. (2023, September). Climate-related financial disclosures—Policy Impact Analysis. Canberra: Department of Treasury. https://treasury.gov.au/sites/default/files/2024-01/c2024-466491-pia.pdf

Australian Government, Department of Treasury. (2024a). Mandatory climate-related financial disclosures—Policy position statement. https://treasury.gov.au/sites/default/files/2024-01/c2024-466491-policy-state.pdf

Australian Government, Department of Treasury. (2024b). Portfolio Budget Statements 2024–25 Budget Related Paper No 1.15 Treasury Portfolio (Portfolio Budget Statements 2024–25 Budget Related Paper No 1.15 1.15). Department of Treasury. https://treasury.gov.au/sites/default/files/2024-05/pbs_treasury_2024-25.docx

Australian National Audit Office. (2020). Management of the Australian Government’s Lobbying Code of Conduct—Follow-up Audit (Performance Audit Auditor-General Report No.48 2019–20; p. https://www.anao.gov.au/sites/default/files/Auditor-General_Report_2019-2020_48.pdf). Attorney-General’s Department.

Bombardini, M., & Trebbi, F. (2025). The Political Power of Firms (Working Paper 33696). National Bureau of Economic Research. https://doi.org/10.3386/w33696

Christensen, H. B., Hail, L., & Leuz, C. (2021). Mandatory CSR and sustainability reporting: Economic analysis and literature review. Review of Accounting Studies, 26(3), 1176–1248. https://doi.org/10.1007/s11142-021-09609-5

Clean Energy Investor Group & Baringa. (2022). Decarbonising Australia: Accelerating our energy transition with a credible 1.5°C scenario. https://ceig.org.au/wp-content/uploads/2022/07/CEIG-x-Baringa-Report_2023-Final.pdf

Climate Action 100+. (2024a). Climate Action 100+ Net Zero Company Benchmark 2.1: 2024 results. https://www.climateaction100.org/wp-content/uploads/2024/10/2024_10_14-October-Final-Summary-Report-Slides.pdf

Climate Action 100+. (2024b, April 25). As the 2024 proxy season gets underway, Climate Action 100+ investors call on companies to improve climate lobbying, accounting, and governance. Climate Action 100+. https://www.climateaction100.org/news/as-the-2024-proxy-season-gets-underway-climate-action-100-investors-call-on-companies-to-improve-climate-lobbying-accounting-and-governance/

Climate Integrity. (2024). Risky Influence: The legal implications of misaligned climate-related lobbying by Australian companies. https://climate-integrity.squarespace.com/s/Climate_Integrity_Risky-Influence_Report_2024.pdf

Crowe, D. (2024, May 7). ‘Fatally flawed’: Crossbench anger after Senate report stops short of lobbying reform. The Centre for Public Integrity. https://publicintegrity.org.au/fatally-flawed-crossbench-anger-after-senate-report-stops-short-of-lobbying-reform/

Davis, J. (2024, October 15). For a few extra dollars, Qantas offers to “offset” your flight. But does it really do anything for the climate? ABC News. https://www.abc.net.au/news/2024-10-16/qantas-accused-of-greenwashing-with-sustainable-flights-claim/104468812

European Commission. (2025). Corporate sustainability reporting. European Commission. https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en

European Financial Reporting Advisory Group. (2023). ESRS G1 Business conduct (Commission Delegated Regulation (EU) 2023/5303, Annex I). https://www.efrag.org/sites/default/files/sites/webpublishing/SiteAssets/ESRS%20G1%20Delegated-act-2023-5303-annex-1_en.pdf

Federal Election Commission. (n.d.). Contribution limits. FEC.Gov. Retrieved May 19, 2025, from https://www.fec.gov/help-candidates-and-committees/candidate-taking-receipts/contribution-limits/

Hummel, K., & Jobst, D. (2024). An Overview of Corporate Sustainability Reporting Legislation in the European Union. Accounting in Europe, 21(3), 320–355. https://doi.org/10.1080/17449480.2024.2312145

IFRS. (n.d.). IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information. IFRS. Retrieved March 15, 2025, from https://www.ifrs.org/issued-standards/ifrs-sustainability-standards-navigator/ifrs-s1-general-requirements/

InfluenceMap. (n.d.-a). Corporate Policy Engagement Disclosure Scorecards. InfluenceMap. Retrieved January 20, 2025, from https://ca100.influencemap.org/lobbying-disclosures

InfluenceMap. (n.d.-b). LobbyMap. LobbyMap. Retrieved May 19, 2025, from https://lobbymap.org/index.html

InfluenceMap. (2021). Does Corporate Australia Support Paris-Aligned Climate Policy? https://australia.influencemap.org/site//data/000/019/InfluenceMap_DoesCorpAustraliaSupportParisAlignedClimatePolicy_Sept2021_compressed.pdf

InfluenceMap. (2024a). Corporate Climate Policy Engagement in Australia: Key corporate policy engagement trends following Labor’s election in May 2022. https://influencemap.org/file/1ef9457729ef4a088352f9dd6443af53

InfluenceMap. (2024b, July). Corporate Climate Policy Engagement and the SSBJ Climate Exposure Draft. InfluenceMap. https://influencemap.org/report/Climate-Policy-Engagement-in-SSBJ-Disclosures-28744

InfluenceMap. (2025). Lobbying on Australia’s Energy Pathways: How the Corporate Sector is Engaging with the Future Made in Australia Strategy. https://influencemap.org/file/21b772880f4646aeae41200a2e98c497

Interfaith Center on Corporate Responsibility. (2025, April 1). Investors File 60 Proposals Calling for Transparency Around Corporate Political Activity. Interfaith Center on Corporate Responsibility. https://www.iccr.org/investors-file-60-proposals-calling-for-transparency-around-corporate-political-activity/

Investor Group on Climate Change. (2024a, March). Climate Policy Improves Investment Confidence – Australia’s institutional capital market—Policy Brief. Investor Group on Climate Change. https://igcc.org.au/wp-content/uploads/2024/03/FINAL-IGCC-Net-zero-survey-2024-policy-media-brief.pdf

Investor Group on Climate Change. (2024b, May). The State of Net Zero Investment 2024: Analysis of $5 trillion managed for Australians. Investor Group on Climate Change. https://igcc.org.au/wp-content/uploads/2024/05/IGCC-State-of-Net-Zero-Report-Australia-2024.pdf

Investor Group on Climate Change. (2025, March 5). Australia’s future prosperity relies on climate policy certainty. Investor Group on Climate Change. https://igcc.org.au/australias-future-prosperity-relies-on-climate-policy-certainty/

KPMG. (2025, April 14). Australian sustainability reporting legislation and standards finalised—KPMG Australia. KPMG. https://kpmg.com/au/en/home/insights/2024/09/24ru-12-australian-sustainability-reporting-standards-legislation-finalised.html

Lacey, C. de, Lane, M., & Prior, T. (2024). Preparing for the Corporate Sustainability Reporting Directive. Transparency International UK. https://www.transparency.org.uk/sites/default/files/2024-12/Report-Preparing%20for%20the%20Corporate%20Sustainability%20Reporting%20Directive-Business-Integrity-Transparency-International-UK.pdf

Lacy-Nichols, J., Christie, S., & Cullerton, K. (2023). Lobbying by omission: What is known and unknown about harmful industry lobbyists in Australia. Health Promotion International, 38(5). https://doi.org/10.1093/heapro/daad134

McKay, A. (2025, April 8). Unpacking The First CSRD Reports: What Can We Learn? Anthesis Group. https://www.anthesisgroup.com/insights/unpacking-the-first-csrd-reports-what-can-we-learn/

Mialon, M., Swinburn, B., Allender, S., & Sacks, G. (2016). Systematic examination of publicly-available information reveals the diverse and extensive corporate political activity of the food industry in Australia. BMC Public Health, 16(1), 283. https://doi.org/10.1186/s12889-016-2955-7

Newton, C. (2024). Investor Expectations for Corporate Just Transition Planning. Investor Group on Climate Change. https://igcc.org.au/wp-content/uploads/2024/10/Investor-Expectations-for-the-Just-Transition.pdf

Ng, Y.-F. (2020). Regulating the influencers: The evolution of lobbying regulation in Australia. Adelaide Law Review, 41(2). https://apo.org.au/sites/default/files/resource-files/2020-12/apo-nid313906.pdf

OECD. (2022). Regulating Corporate Political Engagement: Trends, challenges and the role for investors (OECD Public Governance Policy Papers) [No.13]. OECD Publishing. https://doi.org/10.1787/8c5615fe-en.

Our Democracy. (2024). Our Democracy Alliance Submission Into Inquiry into access to Australian Parliament House by lobbyists. https://transparency.org.au/wp-content/uploads/2024/03/OurDemocracy-alliance-submission-Inquiry-into-access-to-Australian-Parliament-House-by-lobbyists.pdf

Picard, N., O’Connell, K., Saint-Martin, C., & Baber, L. (2025, March 28). Insights from the first 100 CSRD reports. PwC. https://www.pwc.com/gx/en/issues/esg/sustainability-compliance-to-reinvention/corporate-sustainability-reporting-directive/initial-csrd-insights.html

Pocock, S. D. (2024). Dissenting report from Senator David Pocock (Australia). Parliament of Australia. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Finance_and_Public_Administration/LobbyistsAccessAPH47/Report/Dissenting_report_from_Senator_David_Pocock

PRI. (2022). The Investor Case for Responsible Political Engagement. https://www.unpri.org/download?ac=15716

Rennie, G. (2017, October 23). Senate crossbenchers take the first steps on lobbying reform – now to ensure it succeeds. The Conversation. http://theconversation.com/senate-crossbenchers-take-the-first-steps-on-lobbying-reform-now-to-ensure-it-succeeds-85994

Responsible Climate Lobbying: The Global Standard. (2022). Appendix: Global Standard on Responsible Corporate Climate Lobbying. https://climate-lobbying.com/wp-content/uploads/2022/03/2022_global-standard-responsible-climate-lobbying_APPENDIX.pdf

Rives, K. (2024, March 15). Shareholders pushing US companies on climate, political lobbying in 2024. S&P Global Market Intelligence. https://www.spglobal.com/market-intelligence/en/news-insights/articles/2024/3/shareholders-pushing-us-companies-on-climate-political-lobbying-in-2024-80857370

Standards in Public Office Commission. (2023). Quick Guide to the Act. Register of Lobbying. https://www.lobbying.ie/help-resources/information-for-lobbyists/quick-guide-to-the-act/

Tham, J.-C. (2024, May 8). Senate report on lobbying passes the buck on improving transparency or legislation. The Conversation. http://theconversation.com/senate-report-on-lobbying-passes-the-buck-on-improving-transparency-or-legislation-229510

The Senate, Finance and Public Administration References Committee. (2024). Access to Australian Parliament House by lobbyists. Parliament of Australia. https://parlinfo.aph.gov.au/parlInfo/download/committees/reportsen/RB000307/toc_pdf/AccesstoAustralianParliamentHousebylobbyists.pdf

Timmermann, L., & Zalinyan, I. (2024, August 13). Early Insights: EFRAG’s Study on ESRS Implementation Practices. RSM Netherlands. https://www.rsm.global/netherlands/en/insights/early-insights-efrags-study-esrs-implementation-practices

Tonkin, A., & Florence, E. (2024). Lobbying in Victoria (No. 1). Parliament of Victoria. Parliamentary Library & Information Service. https://www.parliament.vic.gov.au/498956/globalassets/sections-shared/about/publications/research-papers/lobbyinginvictoria_rn_2024_.pdf

Transparency International Australia. (2025). Strengthening Our Democracy for All Australians: An Integrity Pack for Members of Australia’s 48th Parliament. https://transparency.org.au/wp-content/uploads/2025/02/Transparency_IntegrityPack2025.pdf

United Nations Environment Programme, United Nations Global Compact, World Resources Institute, & World Wildlife Fund. (2013). The Guide for Responsible Corporate Engagement in Climate Policy. http://www.unglobalcompact.org/docs/issues_doc/Environment/climate/Guide_Responsible_Corporate_Engagement_Climate_Policy.pdf

We Mean Business Coalition. (2023, June). Climate Ambition Advocacy: A framework for responsible policy engagement.

Appendix

Requirements for when entities must commence mandatory disclosures. Based on a phasing approach implemented for the Australian Government's mandatory climate-related financial disclosures (Australian Government, Department of Treasury, 2024a).

First Annual Reporting Periods Starting on or After	Large entities and their controlled entities meeting at least two of three criteria:	National Greenhouse and Energy Reporting (NGER) Reporters	Asset Owners
			Consolidated Revenue EOFY	Consolidated Gross Assets EOFY	EOFY employees
1 year from policy implementation	$500 million or more	$1 billion or more	500 or more	Above NGER publication threshold	N/A
2 years from policy implementation	$200 million or more	$500 million or more	250 or more	All other NGER reporters	$5 billion assets under management or more
3 years from policy implementation	$50 million or more	$25 million or more	100 or more	N/A	N/A

The views and opinions expressed by Global Voices Fellows do not necessarily reflect those of the organisation or its staff.