Watchdog Insights
Decision Useful Diagnosis · Protocol v15.23 · 2 September 2026

FY25 to FY26: What the Mandate Moved

Seventeen Australian entities have now been reviewed across two consecutive periods, the second of them the first mandatory year under AASB S2. Nobody went backwards. Nobody got close to the top of the scale.

Entities paired
17
FY2025 against FY2026
Score movement
+12
121 to 133 points across 17 entities
Up / flat / down
8/9/0
No entity lost points between periods
Criteria closed
23
124 not met, then 101, of 323 assessed
Green ratings
2
of 85 in this set, and of 235 programme-wide
§01  Method

How the review works

Every figure on this page comes from the same instrument: a Decision Useful Diagnosis, which tests whether a reader can actually rely on a company's climate disclosure for the decision they are making. It is not an audit, and it is not a verdict on the company's climate performance. It is a verdict on whether the disclosure lets a reader work out what is happening.

AudienceCriteriaReferenceWhat the audience needs
Carbon and supply-chain accounting4A1–A4Lifting the company's emissions figures into their own inventory. They need complete category coverage, a single reconcilable footprint and a disclosed method. Whether a figure is estimated or supplier-specific is a maturity question, not a fault; the fault is exclusion.
Institutional investors6I1–I6Pricing physical and transition risk, including whether targets are credible and are being met by real reduction, how complete financed and portfolio exposure is, and what exposure is inherited from investees whose own emissions may be growing. They can usually reconstruct detail, so they are judged on whether the true position can be reached at all.
Consumer and retail investors4R1–R4Understanding the company's position and target progress without expert reconstruction. They need headline claims to match the evidence, the material sources to be targeted, and caveats to be easy to find.
Consumers and public3P1–P3Knowing whether the public claims are true: that the company is genuinely acting, and not fuelling climate change while presenting otherwise. Headline claims matter most here, and this reader is least able to read past a buried caveat.
Regulators2G1–G2Whether the disclosure is compliant, and consistent across sources and audiences: does the company say one thing to one audience and something else to another.

The audience definitions are the protocol’s own. The criterion identifiers are used throughout the criterion-level sections below.

3
Answers the question

The disclosure answers that reader's core question.

2
Answers it with effort

It answers, but with work or with gaps that reader can work around.

1
Does not answer it

That reader cannot get to the position from the disclosure.

The five ratings are summed into an overall score out of 15. That total is a ranking number, deliberately un-banded. It is used to order reports, not to pass or fail one, and a single point of difference between two entities is not a meaningful distinction.

A rating is about the disclosure, not the company’s emissions. An entity with a large footprint that reports it clearly can rate well; an entity with a small footprint that obscures it cannot.

Why the criterion count is reported beside the score

Before any digit is assigned, every load-bearing criterion behind each audience is listed and marked. There are three verdicts and no fourth: met, partial, or not met. A partial only stands as a partial where the reviewer can name the specific action the reader takes and the specific published data they use; where no such action and data can be named, the criterion counts as not met.

The score then saturates. An audience row reaches 1 on two failed criteria, or on one failure of a kind that reads a row down on its own, and it cannot go lower. So a disclosure that closes three real gaps can show no movement at all, and two entities with very different numbers of defects can share a score. The count and the score answer different questions: the score is how many audiences can use the disclosure, the count is how many things are wrong.

This is the reason sections 05 to 07 exist. On the score alone, nine of the seventeen entities look unchanged; on the count, only three are.

Where evidence is missing the review says “cannot verify”, not “no issue”. It does not allege illegality, dishonesty or greenwashing, and it is not legal advice, an audit or an assurance engagement. A certification, including the Australian Government’s Climate Active program, is treated as a claim to be tested rather than a strength in itself, and detailed disclosure and candour about a company’s own gaps are the baseline expected of a credible discloser, not a credit.
The standing limits on every review
§02  The greens

Two green ratings, both in carbon accounting

Across 47 live company reviews there are 235 audience ratings. Until this round, none of them was a 3. Two are now, and they sit in the same column.

Diagnosis No. 001
23

Telstra

Carbon and supply-chain accounting1 → 3

All 15 Scope 3 categories carry a figure, two of them a reasoned zero. The footprint is published on both boundaries and the two reconcile exactly: excluding Digicel Pacific, Scope 1 is 26,922 tCO₂e, Scope 2 is 658,410 and Scope 3 is 1,324,526; Digicel Pacific is quantified separately; and the two sets add to the group figures to the tonne. Per-category method is set out with factor sources named.

Still open

Two published figures contradict data printed beside them: the “4 per cent” year-on-year reduction in the sustainability report, and the emissions-intensity change in the data pack.

Diagnosis No. 024
13

Qantas

Carbon and supply-chain accounting1 → 3

Scope 3 is broken out by category for the first time, at 7,572.6 ktCO₂e across four named categories plus a bounded residual, with categories 10 to 14 assessed out and reasons given. Scope 2 carries both a location-based and a market-based figure. Scope 1 and Scope 2 hold a reasonable-assurance audit opinion, a year ahead of the phase-in, and Scope 3 a limited-assurance review.

Still open

Where emissions from partner-operated flights sold under a Qantas code sit is not stated. Gross emissions reached a record above the baseline while a 12% net reduction leads the disclosure.

Both greens are in carbon accounting. Not one of the 235 ratings is a 3 for consumers and the public, for retail investors, for institutional investors, or for regulators.
The ceiling, stated plainly
§03  Movement

Where the score went

Total score across the set moved from 121 to 133 points out of a possible 255. 8 entities gained, 9 held, 0 lost.

001
Telstra
911
+2
009
Fortescue
79
+2
024
Qantas
79
+2
004
CBA
68
+2
005
Origin Energy
89
+1
014
AGL
78
+1
027
ASX
78
+1
019
NEXTDC
67
+1
010
Woolworths
99
0
003
Bendigo Bank
88
0
011
Coles
88
0
029
Wesfarmers
88
0
021
BHP
77
0
008
Goodman
66
0
012
Medibank
66
0
028
Stockland
66
0
015
nib
66
0

Each row shows the prior period position (hollow dot) and the current position (solid dot) on a 15-point scale.

§04  The matrix

Every audience, every entity

Every review rates the same disclosure separately for five audiences, because the same document serves them differently. A 3 means the disclosure answers that reader's core question; a 2 means it answers it with effort or with gaps that reader can work around; a 1 means it does not.

EntityCarbon accountingInstitutional investorsRetail investorsConsumers & publicRegulatorsScoreΔ
001 Telstra2322122222911+2
009 Fortescue221112122279+2
024 Qantas132211112279+2
005 Origin Energy122222112289+1
010 Woolworths2222221122990
004 CBA111212112268+2
014 AGL112212112278+1
027 ASX111122122278+1
003 Bendigo Bank2222111122880
011 Coles2222111122880
029 Wesfarmers2222111122880
019 NEXTDC111211112267+1
021 BHP2211111122770
008 Goodman1111111122660
012 Medibank1111111122660
028 Stockland1111111122660
015 nib1111111122660
Column totals2428 /512527 /512024 /511820 /513434 /51121133+12

Each pair reads prior period, then first mandatory year. The regulators column is the only one in which no cell moved in either direction across all seventeen entities.

Carbon accounting
2428 /51
Prior
New
+4
Institutional investors
2527 /51
Prior
New
+2
Retail investors
2024 /51
Prior
New
+4
Consumers & public
1820 /51
Prior
New
+2
Regulators
3434 /51
Prior
New
0
§05  Underneath the digit

Criteria not met, prior against current

Across the set, criteria not met fell from 124 to 101 of 323 assessed. The bar left of the centre line is the reduction in criteria not met; the bar to the right is an increase.

CBA
94
Telstra
30
ASX
74
Coles
74
Origin Energy
42
Fortescue
75
NEXTDC
108
Wesfarmers
75
Stockland
1311
Qantas
54
Goodman
109
Bendigo Bank
77
Woolworths
33
Medibank
1111
AGL
67
BHP
56
nib
1011
Coles closed three not-met criteria and its score did not move a digit; the rows where it improved were already at 1, where nothing further can be registered. Wesfarmers made the exact fix its prior review asked for first, and the row it was meant to lift held anyway, because only half the fix landed.
Why the count is reported beside the score
§06  Criterion level

What moved beneath the ratings

Each of the 19 criteria is assessed for every entity in both periods, 323 criterion pairs in total.

Criterion pairs
19
Assessed twice each
Improved
16
Net upward movement
Regressed
0
Net downward movement
Defeats closed
23
Entities no longer failing
Passes gained
41
Entities newly passing
A1
No material category excluded
up 5 · held 12 · down 0
defeated 108 · passing 1 5
A2
A single reconcilable footprint
up 7 · held 8 · down 2
defeated 20 · passing 6 10
A3
Method, boundary and version transparency
up 5 · held 11 · down 1
defeated 88 · passing 0 4
A4
Granularity and assurance sufficient to lift
up 5 · held 9 · down 3
defeated 22 · passing 9 11
I1
Physical risk relevant and transparent
up 7 · held 9 · down 1
defeated 11 · passing 4 10
I2
Transition risk: derivable target headroom
up 1 · held 15 · down 1
defeated 67 · passing 1 2
I3
Targets met by real reduction, progress stated honestlyClaim criterion
up 5 · held 12 · down 0
defeated 1510 · passing 0 0
I4
Portfolio and financed-emissions completeness
up 2 · held 15 · down 0
defeated 32 · passing 12 13
I5
Flow-through and look-through exposure
up 2 · held 14 · down 1
defeated 55 · passing 2 3
I6
Reconstructable by a sophisticated reader
up 1 · held 15 · down 1
defeated 12 · passing 5 6
R1
Headline matches evidence without cross-document work
up 6 · held 10 · down 1
defeated 117 · passing 0 2
R2
Targets cover the material sources; achievement honestClaim criterion
up 0 · held 17 · down 0
defeated 1313 · passing 0 0
R3
Material risks legible
up 4 · held 13 · down 0
defeated 00 · passing 8 12
R4
Caveats findable and fairly presented
up 3 · held 13 · down 1
defeated 54 · passing 1 2
P1
Claims literally true within their implied boundary
up 4 · held 12 · down 1
defeated 106 · passing 2 4
P2
No misleading composite impressionClaim criterion
up 3 · held 14 · down 0
defeated 1613 · passing 0 0
P3
Genuine climate action evidenced
up 3 · held 14 · down 0
defeated 00 · passing 9 12
G1
Standards compliance and readiness
up 5 · held 11 · down 1
defeated 01 · passing 4 9
G2
Cross-source and audience consistencyClaim criterion
up 4 · held 13 · down 0
defeated 1612 · passing 0 0
Defeats fell by 23. Passes rose by 41. Most of the year’s gain was a partial becoming a pass, which is a disclosure being tightened, not a gap being closed.
The two numbers that do not match

Pass rate by criterion, within this comparison set

Current-period passes as a share of the 17 entities paired here. These rates describe this comparison set only, not the wider review programme.

I4
Portfolio and financed-emissions completeness
13/17 · 76%
R3
Material risks legible
12/17 · 71%
P3
Genuine climate action evidenced
12/17 · 71%
A4
Granularity and assurance sufficient to lift
11/17 · 65%
A2
A single reconcilable footprint
10/17 · 59%
I1
Physical risk relevant and transparent
10/17 · 59%
G1
Standards compliance and readiness
9/17 · 53%
I6
Reconstructable by a sophisticated reader
6/17 · 35%
A1
No material category excluded
5/17 · 29%
A3
Method, boundary and version transparency
4/17 · 24%
P1
Claims literally true within their implied boundary
4/17 · 24%
I5
Flow-through and look-through exposure
3/17 · 18%
I2
Transition risk: derivable target headroom
2/17 · 12%
R1
Headline matches evidence without cross-document work
2/17 · 12%
R4
Caveats findable and fairly presented
2/17 · 12%
I3
Targets met by real reduction, progress stated honestly
0/17 · 0%
R2
Targets cover the material sources; achievement honest
0/17 · 0%
P2
No misleading composite impression
0/17 · 0%
G2
Cross-source and audience consistency
0/17 · 0%
§07  The claim

The four criteria that carry the claim

No entity passes all four of the criteria that test whether the headline claim survives contact with the evidence. D marks a criterion defeated; P marks a partial pass.

EntityI3 · Real reduction, honest progressR2 · Targets cover material sourcesP2 · No misleading composite impressionG2 · Cross-source consistencyDefeated
001 TelstraPartialPartialPartialPartial0/4
005 Origin EnergyPartialPartialDPartial1/4
004 CBAPartialDDPartial2/4
009 FortescueDDPartialPartial2/4
011 ColesPartialDPartialD2/4
027 ASXDDPartialPartial2/4
003 Bendigo BankPartialDDD3/4
010 WoolworthsDPartialDD3/4
019 NEXTDCPartialDDD3/4
024 QantasDPartialDD3/4
029 WesfarmersPartialDDD3/4
008 GoodmanDDDD4/4
012 MedibankDDDD4/4
014 AGLDDDD4/4
015 nibDDDD4/4
021 BHPDDDD4/4
028 StocklandDDDD4/4
Defeated, by criterion10/1713/1713/1712/1748/68
Two criteria have never been passed by any entity in any period: that reported progress is real reduction rather than accounting movement, and that the overall impression the disclosure leaves is supported.
Zero passes in 46 reviews
§08  Improvements seen

8 entities gained points

What moved in the first mandatory year, and the single change that would move each of them next.

Diagnosis No. 001 · FY2025FY2026
+2

Telstra

2322122222
Score 911 · criteria not met 30 (-3)

Every category of the inventory now carries a figure and the group and ex-Digicel boundaries reconcile to the tonne. No load-bearing criterion is left not met, the first such matrix in the programme.

First recommendation

Correct the two published figures that contradict data printed beside them, the “4 per cent” year-on-year reduction and the emissions-intensity change in the data pack, and reissue both. Then attribute the 27 percentage point figure to one scope consistently.

Diagnosis No. 009 · FY2025FY2026
+2

Fortescue

2211121222
Score 79 · criteria not met 75 (-2)

Both the retail and public rows move to 2. The Scope 3 first-year relief was waived, all fifteen categories are quantified or reasoned out, and the inventory carries reasonable assurance. The institutional row holds at 1 on target architecture, not on data.

First recommendation

Publish a quantified, year-by-year abatement pathway in MtCO₂e from the current 2.72 MtCO₂e to zero by 2030, and an interim absolute Scope 3 cap for 2030 with the netting the 2040 target permits stated as a quantity.

Diagnosis No. 024 · FY2025FY2026
+2

Qantas

1322111122
Score 79 · criteria not met 54 (-1)

The accounting row moves from 1 to 3 on a category breakdown and reasonable assurance a year early. The retail and public rows stay at 1: gross emissions reached a record above the baseline while a 12% net reduction leads, and the abatement line is booked on credits acquired, and in part on estimate before acquisition.

First recommendation

Publish the abatement line's composition, showing separately the tonnes from SAF, the credits retired by scheme, the credits acquired but not retired, and the tonnes accrued against credits not yet acquired, so a reader can see what the 12% is made of.

Diagnosis No. 004 · FY2025FY2026
+2

CBA

1112121122
Score 68 · criteria not met 94 (-5)

Criteria not met fall from nine to four as the first mandatory statements land, and both the institutional and retail rows lift. The accounting row stays at 1: the headline coverage figure does not separate commitments from intentions.

First recommendation

Separate the ten goals from the five targets wherever coverage is claimed, and state the share of lending that carries an actual commitment beside the 70% figure.

Diagnosis No. 005 · FY2025FY2026
+1

Origin Energy

1222221122
Score 89 · criteria not met 42 (-2)

Only two criteria are now not met. What is unresolved is no longer the numbers but what the numbers are taken to show.

First recommendation

State what the FY26 reduction consists of: publish an abatement bridge separating output and weather from grid movement and from Origin's own action, and quantify the emissions spanned by the Eraring extension so that “not expected to affect those targets” is not read as meaning the extension has no climate consequence.

Diagnosis No. 014 · FY2025FY2026
+1

AGL

1122121122
Score 78 · criteria not met 67 (+1)

The retail row moves to 2 on clearer risk presentation. The criterion count moved the other way, from six not met to seven: the headline reduction is still driven by dispatch rather than by abatement, for a second year.

First recommendation

Carry the driver of the year's movement with the headline wherever the headline appears, splitting the annual change between generation volume, fuel mix, plant efficiency and structural abatement against a stated counterfactual, and publish both Scope 2 bases with the annual report rather than three months after it.

Diagnosis No. 027 · FY2025FY2026
+1

ASX

1111221222
Score 78 · criteria not met 74 (-3)

Criteria not met fall from seven to four. Moving the climate content into a single audited statement closed six cross-source divergences at once, and the public row rises as both mechanisms behind the claim are now named beside it.

First recommendation

Publish a gross emissions target with interim milestones, so that the net-zero commitment constrains something other than the volume of credits retired.

Diagnosis No. 019 · FY2025FY2026
+1

NEXTDC

1112111122
Score 67 · criteria not met 108 (-2)

A first net-zero target was approved during the year and the figures are now assured, which lifts the institutional row. The target is a net one with no base period and no interim milestone, and it covers about a third of the electricity the facilities consume.

First recommendation

Publish the electricity delivered to customer IT equipment, in MWh and in tonnes, beside the reported Scope 2 figure, and state that the reported figure is on a narrower boundary than the prior period's together with the effect of the change.

§09  Improvements needed

9 entities held their score

Most of these documents did change. The ratings did not, because the criteria that were holding each row back stayed where they were.

Diagnosis No. 011 · FY2025FY2026
0

Coles

2222111122
Score 88 · criteria not met 74 (-3)

The clearest case of a saturated score: three criteria closed and not one digit moved, because the two rows that improved were already at 1 and the rest were held by other gaps.

First recommendation

Set a reduction target across the value-chain emissions no target currently reaches, starting with the roughly 5.5 Mt made up of end-of-life treatment, use of sold products and the agriculture emissions outside the FLAG target boundary; and publish the in-boundary agriculture figure in tonnes each year.

Diagnosis No. 029 · FY2025FY2026
0

Wesfarmers

2222111122
Score 88 · criteria not met 75 (-2)

The clearest case of a flagged fix being made and the row holding anyway. Last period's first recommendation was to publish a group location-based total beside the headline; that total is now in the annual report. The prior year's location-based figure is still absent at group level, so the corrective movement of 5.4% against a headline of 21.9% exists only if the reader adds seven divisional rows across four pages.

First recommendation

Restate the FY2023 to FY2025 Scope 3 comparatives on the FY2026 methods, or state each change's effect in tonnes and mark the break, so that the only published trend for 97.58% of the footprint measures something; and print the group location-based Scope 1 and 2 movement beside the 21.9% figure wherever it appears, with the certificate, divestment and physical components separated.

Diagnosis No. 028 · FY2025FY2026
0

Stockland

1111111122
Score 66 · criteria not met 1311 (-2)

Two criteria closed and the pass count rose from three to five, with no digit moving. Scope 1 and both Scope 2 bases now carry a full audit opinion with certificates published serial by serial. Scope 3 is still not published at all, about 87% of the footprint, and the intensity figures in the annual report still contradict the assured data pack by a factor of a thousand.

First recommendation

Publish the FY21 Scope 3 baseline value and a current position for the 2030 intensity target, so that the “on track” statement can be tested, and print beside the net zero claim what share of the total footprint Scopes 1 and 2 are and that the position is delivered entirely by market instruments.

Diagnosis No. 008 · FY2025FY2026
0

Goodman

1111111122
Score 66 · criteria not met 109 (-1)

One criterion closed and nine remain not met, the largest residue in the set. A 6.4 GW data-centre power bank sits outside every published figure and every target, and a 400 MW solar target was reported achieved at 363 MW.

First recommendation

Publish the embodied-carbon figure it already measures and a bounding estimate of tenant and data-centre customer energy, so the emissions Goodman reports can be read against the emissions its business model generates.

Diagnosis No. 010 · FY2025FY2026
0

Woolworths

2222221122
Score 99 · criteria not met 33

The document improved in the first mandatory year and the measures did not move: two criteria changed in opposite directions and cancelled. The Scope 3 first-year relief was declined. Location-based Scope 1+2 rose 0.6% behind a 45% headline that is 67% certificates.

First recommendation

Correct the 1,429 MWh figure and the “100% renewable energy” statement in the climate statement; state the 45% on the location-based basis beside the market-based one throughout; and publish the F23 FLAG and non-FLAG baseline split so the four Scope 3 targets can be measured at all.

Diagnosis No. 003 · FY2025FY2026
0

Bendigo Bank

2222111122
Score 88 · criteria not met 77

Identical ratings and an identical count in both periods. Both first-year reliefs were waived, which is unusual, and the renewable electricity share fell from 74% to 58% while being reported as maintained.

First recommendation

Correct the four numeric collisions and the stale carbon-neutral certification cross-reference, then print the total renewable electricity share beside the “100% renewable” commitment wherever it appears. The substantive gap is that 78.9% of the financed footprint carries no emissions-reduction target.

Diagnosis No. 012 · FY2025FY2026
0

Medibank

1111111122
Score 66 · criteria not met 1111

Eleven of nineteen criteria not met in both periods, reached by a different route each time. No Scope 3 figure of any kind is published for the current year, the net-zero date moved from 2040 to 2050 and a 50%-by-2030 Scope 3 target was withdrawn, neither stated plainly.

First recommendation

Publish Scope 3, at least as a bounded total by category, and bring the $3,352.6m investment portfolio inside a dated pathway with a stated method; publish the 2025 baseline value for each scope; and state the net-zero date change and the withdrawn target, with the reason for each.

Diagnosis No. 021 · FY2025FY2026
0

BHP

2211111122
Score 77 · criteria not met 56 (+1)

Clean on compliance in both periods and one criterion further behind in the second. Emissions rose, reported progress against the operational target went backwards, and decarbonisation capital expenditure is about 1% of capital expenditure.

First recommendation

Put an absolute emissions envelope, with a carbon budget, over iron ore processed into crude steel, and reconcile it against the disclosed Western Australia Iron Ore volume and approved port capacity, so that 76.6% of the footprint carries a testable pathway rather than a dollar-denominated support goal.

Diagnosis No. 015 · FY2025FY2026
0

nib

1111111122
Score 66 · criteria not met 1011 (+1)

The inventory got cleaner and the commitment got smaller. Nine Scope 3 categories now sum exactly and both Scope 2 bases are published for the first time. The net-zero-by-2040 commitment and the Scope 3 target were withdrawn and replaced by a target over Scope 1 and market-based Scope 2, which is 59.7 t of a 16,551.5 t footprint.

First recommendation

Put the Scope 3 figure, or an explicit pointer to it, inside the climate statement: nib already produces the number and publishes it twice, and the first-year relief permits the omission but nothing requires it to be silent. Then quantify the $1,102.7m investment portfolio's emissions and bring them inside a target.

§10  Method

How this comparison was produced

  • 1

    Population. The seventeen entities that now have reviews for two consecutive periods. Thirteen further live reviews cover a single period only and are not in this comparison; a synthetic exemplar used to test the protocol is excluded from every count on this page.

  • 2

    What is extracted and what is adjudicated. Every digit, total and criterion count on this page is extracted mechanically from the issued reports and recomputed here from the underlying rows, so adding a review cannot leave a stale total behind. The verdicts those digits express are assigned by hand against the rulebook. The first is reproducible; the second is open to challenge, and the reports carry the reasoning for each.

  • 3

    No re-marking. Prior-period reports were not re-scored when the newer protocol version was adopted. Calibration runs one report at a time against its own sources. Every movement on this page is therefore a change in the entity's disclosure, not an artefact of a moved goalpost.

  • 4

    Period scoping. Each review reads only documents covering the period under review and earlier, so a finding that first appears in the later report belongs to the later period and is not applied backwards.

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