Watchdog Insights
Decision Useful Diagnosis · Protocol v15.23 · 9 September 2026

FY25 to FY26: What the Mandate Moved

Thirty-Three Australian entities have now been reviewed across two consecutive periods, the second the first mandatory year under AASB S2. 13 of 33 improved their rating. One went backwards. Two reasonably decision-useful disclosures; nobody got close to the top of the scale.

Entities paired
33
FY2025 against FY2026
Score movement
+17
225 to 242 points across 33 entities
Up / flat / down
13/19/1
13 gained points, 19 held, 1 lost
Criteria closed
38
259 not met, then 221, of 627 assessed
Green ratings
2
of 165 in this set, and of 410 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, 20 of the 33 entities look unchanged or worse; on the count, only 3 are unchanged.

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 82 live company reviews there are 410 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 410 ratings is a 3 for consumers and the public, for retail investors, for institutional investors, or for regulators.
The ceiling, stated plainly
§03  Movement

thirteen went forward, One backwards, nobody got close to the top of the scale.

Each entity's overall score is the sum of its five audience ratings, out of a possible 15. It is a ranking number, not a verdict. The prior-period digits below are unchanged from when those reviews were issued: no report was re-marked, so every movement shown is a change in the disclosure rather than a change in the ruler.

001
Telstra
911
+2
041
South32
810
+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
039
Brambles
78
+1
019
NEXTDC
67
+1
030
Transurban
67
+1
049
Beach Energy
67
+1
013
Macquarie
67
+1
010
Woolworths
99
0
003
Bendigo Bank
88
0
011
Coles
88
0
029
Wesfarmers
88
0
037
BlueScope
88
0
025
Xero
88
0
021
BHP
77
0
008
Goodman
66
0
012
Medibank
66
0
028
Stockland
66
0
031
Suncorp
66
0
015
nib
66
0
036
IMB Bank
66
0
042
Cochlear
66
0
040
Mirvac
66
0
044
Vicinity Centres
66
0
045
Codan
66
0
043
IGO
66
0
038
Dexus
66
0
046
Super Retail
76
-1

Overall score out of 15, prior period to first mandatory year. Scale runs from 5, the observed floor across the whole programme, to 15, the ceiling. Extracted from the ratings row of each report; the arithmetic is recomputed from the five audience digits on load.

§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
041 South322222121222810+2
009 Fortescue221112122279+2
024 Qantas132211112279+2
005 Origin Energy122222112289+1
010 Woolworths2222221122990
004 CBA111212112268+2
014 AGL112212112278+1
027 ASX111122122278+1
039 Brambles222211111278+1
003 Bendigo Bank2222111122880
011 Coles2222111122880
029 Wesfarmers2222111122880
037 BlueScope2222111122880
025 Xero2211221122880
019 NEXTDC111211112267+1
030 Transurban121111112267+1
049 Beach Energy111211112267+1
013 Macquarie111112112267+1
021 BHP2211111122770
008 Goodman1111111122660
012 Medibank1111111122660
028 Stockland1111111122660
031 Suncorp1111111122660
015 nib1111111122660
036 IMB Bank1111111122660
042 Cochlear1111111122660
040 Mirvac1111111122660
044 Vicinity Centres1111111122660
045 Codan1111111122660
043 IGO1111111122660
038 Dexus1111111122660
046 Super Retail111111212276-1
Column totals4449 /994447 /993743 /993537 /996566 /99225242+17

Each pair reads prior period, then first mandatory year. The regulators column moved once, and every entity now sits at 2 in the mandatory year: Brambles held the only 1 ever recorded in that column and it lifted this year.

Carbon accounting
4449 /99
Prior
New
+5
Institutional investors
4447 /99
Prior
New
+3
Retail investors
3743 /99
Prior
New
+6
Consumers & public
3537 /99
Prior
New
+2
Regulators
6566 /99
Prior
New
+1

Column totals across the thirty-three entities, out of a maximum of 99 per audience. Recomputed from the matrix above.

§05  Underneath the digit

Criteria not met, prior against current

Behind each of the five ratings sits an enumerated set of load-bearing criteria, nineteen per review, each marked met, partly met or not met before any digit is assigned. The count is the finer instrument: a rating already at 1 cannot fall further and a rating held at 2 can absorb several closed gaps without moving, so a flat score can conceal real change in both directions.

CBA
94
South32
51
Telstra
30
ASX
74
Coles
74
Transurban
118
Beach Energy
1310
Origin Energy
42
Fortescue
75
NEXTDC
108
Wesfarmers
75
Stockland
1311
IMB Bank
1412
Brambles
64
Cochlear
1210
Qantas
54
Goodman
109
Suncorp
1110
BlueScope
54
Mirvac
1211
Vicinity Centres
98
Codan
109
IGO
76
Bendigo Bank
77
Woolworths
33
Medibank
1111
AGL
67
BHP
56
nib
1011
Xero
23
Dexus
1011
Super Retail
56
Macquarie
37

Change in the number of load-bearing criteria not met, of 19 per review. One measure applied to all thirty-three: the count published in each report’s own enumeration. Seven entities moved the wrong way on this measure; four of them held their score anyway, two rose, and one fell.

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

Thirty-three entities times nineteen criteria gives 627 before-and-after pairs. Sorting them by which criterion moved separates two things the score cannot: the machinery of the disclosure, and what the disclosure claims.

Criterion pairs
19
Assessed twice each
Improved
17
Net upward movement
Regressed
1
Net downward movement
Defeats closed
38
Entities no longer failing
Passes gained
54
Entities newly passing
A1
No material category excluded
up 5 · held 27 · down 1
defeated 2019 · passing 48
A2
A single reconcilable footprint
up 12 · held 19 · down 2
defeated 50 · passing 1119
A3
Method, boundary and version transparency
up 10 · held 21 · down 2
defeated 1915 · passing 47
A4
Granularity and assurance sufficient to lift
up 8 · held 20 · down 5
defeated 77 · passing 1215
I1
Physical risk relevant and transparent
up 9 · held 23 · down 1
defeated 21 · passing 1017
I2
Transition risk: derivable target headroom
up 3 · held 28 · down 2
defeated 1514 · passing 33
I3
Targets met by real reduction, progress stated honestlyClaim criterion
up 6 · held 26 · down 1
defeated 3025 · passing 00
I4
Portfolio and financed-emissions completeness
up 2 · held 30 · down 1
defeated 77 · passing 2021
I5
Flow-through and look-through exposure
up 2 · held 30 · down 1
defeated 1212 · passing 23
I6
Reconstructable by a sophisticated reader
up 2 · held 29 · down 2
defeated 67 · passing 910
R1
Headline matches evidence without cross-document work
up 8 · held 24 · down 1
defeated 2318 · passing 03
R2
Targets cover the material sources; achievement honestClaim criterion
up 0 · held 32 · down 1
defeated 2627 · passing 11
R3
Material risks legible
up 8 · held 25 · down 0
defeated 00 · passing 1523
R4
Caveats findable and fairly presented
up 6 · held 25 · down 2
defeated 118 · passing 45
P1
Claims literally true within their implied boundary
up 6 · held 25 · down 2
defeated 1610 · passing 811
P2
No misleading composite impressionClaim criterion
up 4 · held 27 · down 2
defeated 3028 · passing 00
P3
Genuine climate action evidenced
up 4 · held 28 · down 1
defeated 01 · passing 1821
G1
Standards compliance and readiness
up 9 · held 22 · down 2
defeated 02 · passing 816
G2
Cross-source and audience consistencyClaim criterion
up 10 · held 23 · down 0
defeated 3020 · passing 11
Defeats fell by 38. Passes rose by 54. 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, programme-wide

I4
Portfolio and financed-emissions completeness
52/82 · 63%
R3
Material risks legible
45/82 · 55%
P3
Genuine climate action evidenced
44/82 · 54%
A2
A single reconcilable footprint
36/82 · 44%
A4
Granularity and assurance sufficient to lift
30/82 · 37%
I1
Physical risk relevant and transparent
30/82 · 37%
G1
Standards compliance and readiness
27/82 · 33%
I6
Reconstructable by a sophisticated reader
25/82 · 30%
P1
Claims literally true within their implied boundary
23/82 · 28%
A1
No material category excluded
13/82 · 16%
A3
Method, boundary and version transparency
13/82 · 16%
R4
Caveats findable and fairly presented
12/82 · 15%
I2
Transition risk: derivable target headroom
7/82 · 9%
I5
Flow-through and look-through exposure
5/82 · 6%
G2
Cross-source and audience consistency
4/82 · 5%
R1
Headline matches evidence without cross-document work
3/82 · 4%
R2
Targets cover the material sources; achievement honest
2/82 · 2%
I3
Targets met by real reduction, progress stated honestly
0/82 · 0%
P2
No misleading composite impression
0/82 · 0%

Share of all 82 live reviews in the programme, single-period reviews included, in which each criterion passes outright. Sorted from most to least often passed. The four at the foot are the ones that test what the disclosure asserts rather than how it is assembled.

§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; Partial marks a partial pass; M marks a criterion met outright.

EntityI3 · Real reduction, honest progressR2 · Targets cover material sourcesP2 · No misleading composite impressionG2 · Cross-source consistencyDefeated
001 TelstraPartialPartialPartialPartial0/4
005 Origin EnergyPartialPartialDPartial1/4
041 South32PartialDPartialPartial1/4
004 CBAPartialDDPartial2/4
009 FortescueDDPartialPartial2/4
011 ColesPartialDPartialD2/4
027 ASXDDPartialPartial2/4
039 BramblesDPartialDPartial2/4
003 Bendigo BankPartialDDD3/4
010 WoolworthsDPartialDD3/4
019 NEXTDCPartialDDD3/4
024 QantasDPartialDD3/4
025 XeroDM ✓DD3/4
029 WesfarmersPartialDDD3/4
030 TransurbanDDDPartial3/4
031 SuncorpDDDPartial3/4
036 IMB BankDDDPartial3/4
043 IGODDDPartial3/4
044 Vicinity CentresDDDPartial3/4
046 Super RetailDDDM ✓3/4
008 GoodmanDDDD4/4
012 MedibankDDDD4/4
013 MacquarieDDDD4/4
014 AGLDDDD4/4
015 nibDDDD4/4
021 BHPDDDD4/4
028 StocklandDDDD4/4
037 BlueScopeDDDD4/4
038 DexusDDDD4/4
040 MirvacDDDD4/4
042 CochlearDDDD4/4
045 CodanDDDD4/4
049 Beach EnergyDDDD4/4
Defeated, by criterion25/3327/3328/3320/33100/132

The four claim criteria in the first mandatory year, one row per paired entity. Across these 132 assessments there are two passes, Xero on target coverage and Super Retail on cross-source consistency. Across all 328 in the programme there are six, held between four entities.

Two of the four 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. Between them they have been assessed 164 times.
Zero passes in 82 reviews
§08  Improvements seen

13 entities gained points

The pattern is consistent across the thirteen that moved: the first mandatory statements forced completeness, assurance and a single audited home for the climate content, and completeness is what the accounting audience is rated on.

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. 041 · FY2025FY2026
+2

South32

2222121222
Score 810 · criteria not met 51 (-4)

The largest single improvement in the programme on the criterion count, five not met to one, and the highest score any company other than Telstra has reached. Reasonable assurance covers Scope 1 and both Scope 2 bases, an organisational boundaries table says which basis governs which disclosure, and a five-year Scope 3 category series is published on two portfolio definitions in a year when none was required at all. The gross target has been set equal to the net target, which is a commitment to deliver the reduction physically rather than to buy it. The year itself produced no net abatement: emissions rose 4.7% on the basis the target and the audit both use, value-chain emissions rose 22% under no reduction target, and decarbonisation spending fell 68% to US$3.4 million against US$1,441 million of capital expenditure.

First recommendation

Publish the residual portfolio's FY2026 emissions beside the 1.7 MtCO₂e pro-forma baseline that the announced sale of the aluminium value chain would leave, and say whether the FY35 target is retained, recalibrated or withdrawn. A reader currently cannot tell whether the retained business starts above or below its own new line.

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. 039 · FY2025FY2026
+1

Brambles

2222111112
Score 78 · criteria not met 64 (-2)

Where the standard excused Brambles from publishing Scope 3 it published all fifteen categories anyway, which is a decision to be measured on 98% of its footprint rather than 2% of it. It also carries the only regulators row that has ever sat at 1, and that row moved to 2 this year. Two assured percentages, 36% in Scope 1 and 2 and 16% in Scope 3, are measured from an FY2020 baseline whose tonnages appear nowhere in the FY2026 documents and which the report itself discloses is on a different boundary. The 36% is contractual: certificates in both scopes are worth 16,200 tCO₂e against a reported reduction of 15,500, and physical Scope 1 combustion is 2.5% above the baseline.

First recommendation

Publish the FY2020 baseline tonnages, restated for the structural changes the report already discloses, beside every percentage measured from them. Then report gross Scope 1 and location-based Scope 2 as the headline, with the certificate deductions shown as separate lines beneath.

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.

Diagnosis No. 030 · FY2025FY2026
+1

Transurban

1211111122
Score 67 · criteria not met 118 (-3)

Three criteria closed and the accounting row lifts. Physical risk is modelled at asset level under named scenarios, with adaptation plans and a quantified shadow carbon cost. Emissions from customers driving on its roads sit outside the inventory, a boundary judgement Transurban discloses, and that same customer travel carries a second target that is separately credited.

First recommendation

State in figures, wherever the net-zero target is claimed, what share of its measured emissions that target covers. The boundary judgement is legitimate and disclosed; what a reader never gets is the number needed to size the claim.

Diagnosis No. 049 · FY2025FY2026
+1

Beach Energy

1112111122
Score 67 · criteria not met 1310 (-3)

Better in every respect the standard reaches and thinner in every respect it does not. The boundary the targets run on now carries an absolute figure, 1,038,315 tCO₂e of equity Scope 1 and Scope 2; the Scope 2 basis is stated; gross abatement is separated from net for the first time; and a gross target that no purchase can satisfy has been set beside the net one. In the same year the Scope 3 category detail, the methane measure and its target, the stand-alone transition plan, the trajectory chart and every comparative figure went away.

First recommendation

Publish the 2018 base year value, before and after the equity recalculation, with its effect on the reported reduction, and reconcile the stated 65% abatement share to the published 10% and 18%, which make it about 56%.

Diagnosis No. 013 · FY2025FY2026
+1

Macquarie

1111121122
Score 67 · criteria not met 37 (+4)

The one pair in which the score rose while the count went the other way, three criteria not met to seven. The statement is thorough and broadly assured and its claims are honestly scoped. What the three unmoved audiences cannot see is whether the real footprint is being capped and reduced, only whether two intensity ratios are easing. In the same year three quantifications published voluntarily a year earlier were withdrawn rather than uplifted, the group 2050 financing-alignment ambition was dropped, the Net-Zero Banking Alliance left, the motor-vehicle target withdrawn and two further 2030 targets removed, while the book grew.

First recommendation

Publish an absolute financed and facilitated trajectory, or state the headroom and the reason for it, and quantify the emissions tied to the roughly $722bn of managed assets and capital-markets activity that sits outside the reported number.

§09  Improvements needed

19 entities held their score, 1 scored lower

Nineteen entities scored the same in both periods and one scored lower. In fifteen of the twenty the underlying criterion count improved or held; in five it deteriorated. The common residue is the public-facing claim: the number a reader meets first, and what it is taken to mean.

Diagnosis No. 046 · FY2025FY2026
-1

Super Retail

1111112122
Score 76 · criteria not met 56 (+1)

The only entity in the programme to score lower in its first mandatory year, and the statement itself is well made. It cites both transitional reliefs by paragraph, early adopts the December 2025 amendments, tabulates its key judgements and estimation uncertainty, discloses that it has no internal carbon price and no interim milestones, carries an unmodified limited-assurance conclusion, and reconciles to the regulator's register on location-based Scope 2 to within three tonnes on 54,897. Seven of the nineteen criteria pass, and it holds one of the six passes recorded anywhere on the four claim criteria. Every emissions measure rose in the reviewed year: Scope 1 by 25.8%, total location-based Scope 1 and 2 by 3.2% and total market-based by 6.7%, while the operating review reports that progress towards net zero by 2030 was made.

First recommendation

Publish the Scope 3 estimate as a range with its method and limits stated. It exists at supplier level, it is required for FY2027, and until it appears no figure in the disclosure can be put in proportion. Then state the emissions movement in the same place as the progress statement.

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. 036 · FY2025FY2026
0

IMB Bank

1111111122
Score 66 · criteria not met 1412 (-2)

The first statutory statement lands on all four pillars with a directors' declaration and an unmodified limited-assurance conclusion, and a method table appears for the first time. The score does not move: the 85% progress figure is market-based, the same electricity measured physically gives a 21.5% reduction, and the operational footprint rose 4.3% during the year. The prior year's statement that financed emissions were measured under the PCAF standard is gone, and with it any mention of what the loan book funds.

First recommendation

Publish the FY2021 baseline value and report progress on one stated basis, so a member can check the 85% from the page in front of them. Then extend the assurance perimeter to that figure, which currently sits outside it in the same document.

Diagnosis No. 042 · FY2025FY2026
0

Cochlear

1111111122
Score 66 · criteria not met 1210 (-2)

A better document reporting a worse year. The statutory report states its organisational boundary, its emission factor sources by jurisdiction, its residual-mix treatment and both transition reliefs taken, publishes the location-based electricity figure for the first time and for three years, and withdrew every quantified environmental claim from the front of the report. What the new figure shows is the point of publishing it: the grids Cochlear draws from emitted 13,103 tCO₂e, while the figure it reports, and that its 2030 target is measured on, is 2,089. One claim remains at the front, and it is the one the numbers contradict: “Net zero emissions targets on track” is the only environmental statement on the highlights page, and the operational position it refers to rose 5.3%.

First recommendation

Give the 2030 target a published baseline, a series and at least one interim milestone, and state the emissions movement in the same place as the on-track status. The target is four years away and needs about 772 tCO₂e a year against 230 tCO₂e achieved over the last three years in total.

Diagnosis No. 037 · FY2025FY2026
0

BlueScope

2222111122
Score 88 · criteria not met 54 (-1)

The first mandatory statement brings nine years of absolute and intensity data, a full method statement and quantified financial effects for every risk into the annual report, from a 2024 document a reader had to go and find. The score holds because the target architecture does not move: value chain emissions, 54% of the footprint on BlueScope's own figure, carry no target, and Scope 1 and Scope 2 have no absolute cap and have sat at 10,200,000 tCO₂e for two years running.

First recommendation

Set a Scope 3 target with a baseline, a target year and stated category coverage, and replace the 2030 steelmaking intensity target, which the current result already sits four percentage points ahead of and which the company states it will not revise.

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. 031 · FY2025FY2026
0

Suncorp

1111111122
Score 66 · criteria not met 1110 (-1)

One criterion closed, and the physical-risk work is the strongest part of the disclosure: net natural hazard costs projected to rise 3% to 7% around 2040 and 3% to 11% around 2050 against a published $1,770m allowance, with the year's actual experience of $2,024m, $254m above allowance, disclosed beside it. Costs rise under both scenarios modelled.

First recommendation

Publish the per-category upstream Scope 3 split and a bounding estimate for purchased goods and services, including the claims supply chain, so that the largest thing a general insurer buys stops being invisible.

Diagnosis No. 040 · FY2025FY2026
0

Mirvac

1111111122
Score 66 · criteria not met 1211 (-1)

A well-built first mandatory report that reports continued success on a measure that stopped being able to move three years ago. The 88% reduction it leads with is, on Mirvac's own published figures, 79 percentage points of renewable electricity certificates. The emissions Mirvac physically causes on the same boundary have fallen 5.7% since FY2019, its direct emissions are 39.5% higher than the base year, and both its electricity use and its total location-based footprint rose during the year the target was reported as met.

First recommendation

Print the location-based Scope 2 row beside the market-based one in the annual report, and say beside the net positive result what share of it is offsets. Both figures exist, both are assured, and one of them is currently visible only in a spreadsheet.

Diagnosis No. 044 · FY2025FY2026
0

Vicinity Centres

1111111122
Score 66 · criteria not met 98 (-1)

The measurement layer was fixed and the architecture left untouched. The consolidation approach, the three assets outside it by name, the factor source and vintage, the gases, the apportionment between common mall and tenant areas and the data quality are all now stated, and Vicinity says without being asked that its target is not independently validated, was not sectorally derived, has no gross counterpart and is not connected to any executive incentive. The Net Zero 2030 target still covers the common mall areas of the wholly-owned centres, 32,596 tCO₂e, which is 10.6% of what Vicinity measures and slightly less than the share it covered a year ago. That figure appears nowhere in the report.

First recommendation

Publish the arithmetic behind the headline. The reduction against the FY16 baseline is reported as 45% where a year earlier it was 39%, while the underlying intensity fell 2% in the year; the restatement and the portfolio reshaping that produced most of the rest are both disclosed as policies, which is why the missing reconciliation is what matters.

Diagnosis No. 045 · FY2025FY2026
0

Codan

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

A substantial first report that is not decision-useful for four of the five audiences. The machinery arrived: scenario analysis, named emission factors, a stated boundary, a full set of judgements and uncertainties, limited assurance over the operational scopes, and the DTC UK plan set out in full, which closes the largest gap the prior period identified. What did not arrive is any measurement of the part of the footprint the report itself says matters most, or a target of any kind.

First recommendation

Correct the remuneration disclosure, which is the only statement in the report a reader can show to be wrong from Codan's own documents filed the same day: state the Environmental, Social, Governance and Safety objective, its 15% weighting, what it was awarded for, and that no emissions outcome is linked to pay because no emissions target exists.

Diagnosis No. 043 · FY2025FY2026
0

IGO

1111111122
Score 66 · criteria not met 76 (-1)

A competent statutory statement whose limitations are almost all stated by the company itself, in plain words, in the section a reader is already in. None of that reaches the position underneath. Operational emissions fell 24%, and two thirds of that is one asset ramping down into care and maintenance and another sold in February. The remaining operation reached net zero for a second year by cancelling 46,000 carbon credits against 45,632 tonnes it emitted, having abated at most about 600 of them. In the year the disclosure became statutory the long-term commitment moved from 2035 to 2050, the transition-risk register was emptied, and the asset carrying 73.7% of the balance sheet sits outside the goal.

First recommendation

Bound Categories 10 and 11, which is a week's work on published conversion factors and IGO's own sales volumes and would tell a reader whether the counted footprint is most of the real one. Then give the 2050 goal a baseline year, a baseline value and at least one dated point before 2050.

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. 025 · FY2025FY2026
0

Xero

2211221122
Score 88 · criteria not met 23 (+1)

The measurement is among the most complete in the programme for a business of this type: all fifteen value chain categories are addressed with a stated relevance test, ten are quantified, the acquisition is separated into its own column, and the location-based and gross-of-certificate figures sit beside the market-based and net figures throughout. That construction is what lets a reader establish, from Xero's own tables, that the year's reported reductions are certificate purchases and emission-factor changes rather than emitting less, and that the underlying footprint grew beneath them. Xero holds one of the two passes recorded on target coverage anywhere in the programme.

First recommendation

Publish the split between real abatement and accounting movement beside each headline reduction figure. Xero already does this for the acquisition, quantified to the tonne, and the same treatment applied to the supplier-factor change, the certificates and the DEFRA revision would make the reported story match the underlying one without a single new measurement.

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.

Diagnosis No. 038 · FY2025FY2026
0

Dexus

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

The reporting got materially better and the claims got materially looser in the same year. A full AASB S2 report arrived a year before the standard binds Dexus, with a directors' declaration, a paragraph-level index, two independent assurance engagements and restatements disclosed with their prior values. Against that, the net-zero claim covered Scope 1, Scope 2 and five Scope 3 categories for four years and now covers Scope 1 and 2, which leaves 16,676 tCO₂e unoffset on last year's basis; the quantified Scope 3 reduction target was retired with nothing testable in its place; and the front-of-book claim moved from “100% of electricity” to “100% Renewable energy”, which the company's own data pack puts at 83%.

First recommendation

Correct the renewable claim to electricity, and put the emissions figures and the boundary change into the annual report, so that the document carrying the directors' declaration says what the company emitted and what its claim covers. Then give the 2040 aspiration a milestone that requires a reduction: three are published and all three were satisfied before the year began.

§10  Method

How this comparison was produced

  • 1

    Population. The thirty-three entities that now have reviews for two consecutive periods. Sixteen 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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