Calling all CFOs: Your 90-day plan to AASB S2 readiness

A CFO-led plan for AASB S2 readiness

Most CFOs already hold 80% of what's required to comply with Australia's new sustainability disclosure standards. The general ledger, risk registers, governance frameworks, and financial oversight are already there. The challenge isn't starting - it's structuring.

Across finance, the message is clear: this isn't a sustainability side project. It's a financial reporting standard. And that means the CFO leads it.

As Rachel Riley, CFO and Co-Founder of Drova, put it during our recent strategic webinar:

"Climate creates financial risks and opportunities that affect cash flow, cost of capital, and strategy. That's why S2 sits under IFRS - it's fundamentally financial."

The good news? You can build a defensible, assurance-ready foundation in just 90 days.

Step 1: Map what you already own (Weeks 1-4)

Start with the data you already trust - your general ledger, enterprise risk frameworks, risk registers, governance bodies, and more.

Your general ledger is where most of your Scope 1 and Scope 2 emissions sit. Add spend-based data to estimate early Scope 3 categories such as freight, suppliers, and travel. This establishes your first defensible baseline - not perfect, but evidence-ready.

As Misha Cajic, Co-Founder of Avarni, said:

"Start with the data finance already owns. You don't need targets in year one - you need a defensible baseline."

The goal of these first weeks isn't precision. It's completeness - the ability to show your auditors and board that you've captured all material activity and can prove how.

Step 2: Clarify ownership and accountability (Weeks 4-6)

The second step is governance clarity. Many finance teams underestimate how far S2 reaches across the organisation - from finance to risk, sustainability, operations, and the board.

Ownership must be explicit. Finance leads metrics. Risk teams operationalise climate risk in the register. Compliance interprets clauses. The board oversees direction and assurance.

Rachel Riley summarised it simply:

"This is not a one-person job - but ownership must sit with the CFO."

Without that structure, disclosures become duplicated and inconsistent, and assurance breaks down. Define who owns what now, while expectations are still manageable.

Step 3: Integrate risk and opportunities into your strategy (Weeks 6-8)

Most CFOs find the hardest part isn't the emissions data - it's the integration of climate risk and opportunities into financial strategy.

Climate risk isn't an appendix anymore. It belongs in the same risk framework that covers liquidity, operations, and cybersecurity. The finance team doesn't need to be climate experts - but it does need to connect financial exposure to environmental drivers.

As Jack Duffy, Head of Finance at Marubeni Itochu Tubulars Oceania, explained:

"What's hardest isn't the metrics - it's governance, risk integration, and strategy. It's not just reporting emissions; it's everything that comes with it."

Identify where volatility, cost, or supply pressures could impact cash flow or valuations. That's what the board - and auditors - will look for.

Step 4: Build your evidence trail (Weeks 8-10)

Audit readiness lives or dies on documentation. Auditors will want to see how you measured, what you included, and how you justified your assumptions.

"Evidence is everything," Riley said. "Auditors will look for a clear governance chain, documented risk identification, and proof that the numbers can be traced."

Start documenting now. Keep records of boundaries, methodologies, and conversations about materiality. Every spreadsheet, source, and note becomes part of your assurance trail.

By the end of week ten, your goal is transparency - being able to answer how you got every number.

Step 5: Engage the board and rehearse reporting (Weeks 10-12)

Finally, make this business-as-usual.

Bring the board in early with draft disclosures, preliminary data, and a clear plan for assurance. Regular updates turn anxiety into alignment.

Jack Duffy shared how his team keeps reporting friction low:

"We've raised this consistently for over 12 months - timelines, plans, progress. No surprises."

When your board and auditors see progress early, confidence follows naturally.

By week twelve, you're not finalising; you're refining.

What readiness looks like after 90 days

By the end of the first 90 days, finance teams should have:

• Organisational and operational boundaries defined
• Scope 1-3 data mapped to defensible sources
• Governance roles and accountabilities assigned
• Climate risks and opportunities identified, assessed and integrated into the risk register
• A draft disclosure set ready for board review

That's not theory - it's a pragmatic, finance-led path to assurance and it will drive your overall strategy. No new headcount. No endless meetings. Just structured progress.

From plan to platform: How Drova and Avarni help

Once the plan is in motion, the challenge becomes maintaining control as volume increases.

That's where Drova and Avarni come in. Avarni supplies the emissions and metrics foundation - the Scope 1-3 data, supplier insights, and financial emissions. Drova brings the governance and reporting engine - linking risks, controls, and disclosures in one auditable workflow.

Together, they give CFOs a single, connected system to track progress, assign ownership, and produce board-ready, assurance-strong disclosures every year. Your final ASRS disclosure report is automated, saving you the time it would take to build out manually.

Better yet, you can start today for free. No risk, all reward.