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They have also been active participants in the implementation of sustainability reporting standards in Australia.1 Our members support the Bill in principle and are pleased to note that it has addressed many of the issues of concern noted in our Submission on the Exposure Draft and in previous Submissions.2 However, our members remain concerned about the following aspects of the Bill: Summary of i. [...] • While the proposed requirement for entities which have no material risks or opportunities to produce a climate statement to that effect is acceptable, to require an audit of that statement to be conducted imposes a significant and unjustified regulatory and cost burden on these entities as the auditor will need to form the view that the statement is correct for the reasons stated by the entity. [...] Alternatively, climate-related financial disclosures should be located within existing reports and cross referencing enabled, noting that the current ASIC instrument only permits cross-referencing in financial reports.3 • Our members remain concerned at the breadth of the Ministerial discretion in the proposed section 296A(5) giving the Minister power to require a sustainability report to include. [...] • Excluding not-for-profits from the requirements • A simplified climate-related financial disclosure regime for entities eligible to use the Simplified Disclosures Tier 2 financial reporting framework to align with that Framework, particularly for Group 3 unlisted entities and assurance requirements appropriate to the size of these entities, and • Removing the requirement for audits of statements. [...] Page 4 Using the term ‘sustainability report’ in the legislation is problematic because while on the face of it the term used in the draft legislation relates to climate matters, as a practical matter entities and their investors generally consider a sustainability report as covering a broader range of issues.