Australia’s $3.5 trillion superannuation sector is one of the largest pools of institutional capital globally. With the largest super funds classified as Group 1 ASRS entities, and APRA CPG 229 setting prudential expectations for climate risk management, the dual compliance burden is significant.
ASRS + CPG 229: Two Frameworks, One Programme
ASRS 1 and ASRS 2 require climate-related financial disclosures in the annual report. CPG 229 sets governance, risk management, and strategy expectations for APRA-regulated entities. While they overlap, they are not identical:
| Aspect | ASRS | CPG 229 |
|---|---|---|
| Nature | Mandatory disclosure | Prudential guidance (best practice) |
| Focus | Financial report disclosures | Risk management practices |
| Scope 3 | Required (with safe harbour) | Financed emissions expected |
| Scenario analysis | Required | Expected (climate stress testing) |
| Assurance | Limited (Scope 1 & 2) | Not specified |
Key Challenges for Super Funds
- Financed emissions (Scope 3 Category 15): Calculating the carbon footprint of investment portfolios across asset classes — equities, fixed income, property, infrastructure, private equity — requires data from investee companies, many of whom are not yet reporting
- Climate stress testing: APRA expects climate stress testing for RSE licensees. Scenarios must be tailored to portfolio composition and investment time horizons
- Member communication: Sustainability claims in member-facing materials must align with ASRS disclosures (ASIC greenwashing risk)
- Trustee duties: The Hutley opinions established that climate risk is a foreseeable financial risk that trustees must consider. ASRS makes this explicit
Practical Steps
- Map your ASRS and CPG 229 obligations in a single compliance matrix
- Establish financed emissions data collection from investee companies
- Design climate stress test scenarios aligned with both ASRS and APRA expectations
- Align member communications with ASRS disclosures (greenwashing risk)
- Train trustees and investment committees on climate governance obligations
RSustain Advisory
RSustain helps super funds and APRA-regulated entities design integrated ASRS + CPG 229 compliance frameworks. Book a free scoping call to discuss your dual compliance requirements.
RSustain UK provides advisory services only. We do not provide statutory assurance or verification.