Submission: What investors need from Treasury’s transition planning guidance
25 September 2025
IGCC supports Treasury’s development of transition planning guidance. Investors will use the guidance to inform their own transition planning and to scrutinise company transition plans, informing investment strategies.
IGCC’s recommendations for Treasury in refining this guidance are:
- Develop guidance that acknowledges the institutional investor sector as both users and preparers of climate-related financial disclosures (CRFD). This should be developed in partnership with asset owners and use the guidance currently under development for CRFD as an input once completed. The guidance could consider portfolio-wide transition strategies, investor specific levers and investors’ business model and value chain.
- Provide consistent and whole-of-Government guidance on the need to engage with uncertainty in transition planning and forward-looking statements. This includes Treasury guidance on transition plans as well as from ACCC and ASIC. Without this, preparers may default to overly conservative or generic disclosures that fail to provide the strategic insights investors require for informed decision-making.
- Highlight key accountability elements for credible transition planning including governance, resourcing, responsible policy engagement and advocacy.
- Strengthen the role of adaptation and resilience as core interconnected components of climate transition planning.
Read the full submission.