Staying the course: What September’s climate announcements mean for governance Professionals

An opinion piece by Dr Turlough Guerin FGIA

Executive summary

September 2025 delivered an unprecedented suite of Federal climate documents: the 2035 Nationally Determined Contribution, Climate Change Authority’s Targets Advice, the National Adaptation Plan, and the National Climate Risk Assessment. Together, they establish binding emissions commitments and a national blueprint for resilience. For governance professionals, these cut through the noise of partisan debate, providing authoritative direction. Directors now face legal and fiduciary obligations to embed climate commitments into risk, disclosure, and strategy. The task is clear: align to national signals, anticipate regulatory change, and remain anchored to organisational purpose amidst an increasingly contested climate landscape.

A pivotal month for national climate governance

September 2025 marked a watershed moment in Australia’s climate response. The Federal Government released a suite of interlinked documents: the 2035 Nationally Determined Contribution (NDC), committing to a 62-70% reduction in emissions from 2005 levels; the Climate Change Authority’s statutory Targets Advice; the nation’s first National Adaptation Plan; and the National Climate Risk Assessment.

At first glance, these reports risk being drowned out in what many directors already see as an avalanche of climate information, opinion, and contested commentary. Yet these are not just more voices in the debate. They are government-mandated frameworks, legally binding in parts, and grounded in the best available science. For governance professionals, they represent a chance to cut through the noise and focus on what truly matters for organisations: credible, nationally endorsed guidance on mitigation, adaptation, and resilience.

Why the NDC matters – and the legal dimension

The NDC is not just a policy statement; it is Australia’s formal commitment under international law pursuant to Article 4 of the Paris Agreement. Once lodged with the UNFCCC, it binds Australia to report, track, and progressively ratchet ambition. Importantly, under the Climate Change Act 2022, government must consider independent advice before setting targets – which it did in adopting the Climate Change Authority’s recommendation.

Climate has long been recognised as a material director’s duty under Australian law. What the September 2025 announcements do is reinforce and formalise this status, shifting climate governance decisively from a discretionary ESG issue to an explicit compliance and fiduciary matter. For listed entities, climate risk now falls squarely within Corporations Act disclosure obligations. For all organisations, directors face heightened expectations as regulators, investors, and counterparties increasingly treat climate targets and commitments as binding benchmarks that must be backed by credible plans and disclosures. This is not just a matter of optics. It is about ensuring corporate strategy, capital allocation, and reporting frameworks are aligned with a national commitment that carries international and legal weight.

Adaptation and risk: frameworks for organisational resilience

The National Adaptation Plan sets out seven priority systems, from economy and trade to health, infrastructure, and defence. The accompanying Climate Risk Assessment identifies cascading risks, such as concurrent natural disasters overwhelming critical infrastructure, biosecurity threats to agriculture, and health system vulnerabilities.

Governance professionals must translate these national priorities into organisational risk frameworks. That means testing whether existing registers, scenario analyses, and resilience plans adequately account for compounding climate events, and whether adaptation opportunities (for example, in infrastructure hardening or supply chain resilience) are being seized.

Questions governance professionals should be asking

In previous Governance Directions articles, I have argued that one of the most practical contributions governance professionals can make is to frame the right questions for their boards and executives. That reminder is particularly timely now. While many organisations have been proactive, others have lagged or deliberately delayed action. The September announcements provide a clear signal that delay is no longer a defensible posture.

Some of the critical questions to be asking include:

• Purpose and alignment: How is our organisation’s purpose reflected in our climate and adaptation strategy? Are we at risk of straying into greenwashing or short-term positioning rather than building durable resilience?

• Risk registers: Do our enterprise risk systems account for the nationally significant risks identified in the Climate Risk Assessment – such as cascading infrastructure failures, climate-driven biosecurity threats, and compounding disaster events?
• Capital allocation: Are our investment decisions aligned with a 62–70% emissions reduction pathway by 2035? What assumptions underpin our business case models, and are they still valid under the government’s new trajectory?
• Disclosure readiness: Are we prepared for mandatory climate and nature-related reporting regimes, including alignment with the Taskforce on Nature-related Financial Disclosures (TNFD) and strengthened ASIC/ASX guidance?
• Adaptation strategy: Beyond mitigation, are we investing sufficiently in resilience measures – such as physical asset hardening, workforce adaptation, and supply chain redesign?
• Stakeholder trust: How do we ensure our communications remain evidence-based, anchored in data and science, and not distracted by political cycles or contested commentary?

By asking these questions, governance professionals help boards shift from reactive compliance to proactive stewardship.

Anticipating required changes

What practical steps should board and governance professionals now take?

1. Update risk registers and disclosures: Integrate findings from the National Climate Risk Assessment, particularly around infrastructure, health, and supply chain vulnerabilities.
2. Review adaptation alignment: Test whether organisational strategies align with the adaptation priorities outlined in the National Adaptation Plan.
3. Strengthen climate governance: Ensure boards have access to climate-literate expertise and embed NDC-aligned pathways into medium- and long-term strategy.
4. Scenario planning and resilience: Move beyond single-event risk to compounding hazards and stress-test business continuity plans accordingly.
5. Maintain focus on purpose: Reaffirm organisational purpose as the anchor through which to assess climate strategy, avoiding distractions from political rhetoric or non-evidence-based claims.

Staying true to purpose amidst political “noise”

As September’s announcements generated media commentary and partisan debate, governance professionals face a familiar challenge: separating enduring obligations from political cycles. The role of directors is not to adjudicate politics, but to keep organisations aligned to their purpose, strategy, and long-term resilience.

In this environment, purpose becomes a compass. It allows directors to filter out short-term distractions – whether from political machinations, pressure groups, or unverified claims – and to privilege evidence, law, and science in governance decisions. Cutting through the noise is not about ignoring debate; it is about recognising which signals carry institutional authority and legal consequence, and which do not.

Conclusion

September’s announcements signal that climate and adaptation governance are now mainstream legal and institutional expectations. For directors, this is not a matter of voluntary alignment but of fiduciary duty, accountability, and strategic foresight.

The message is clear: boards and governance professionals must not only respond to the regulatory and legal signals embedded in the NDC, Climate Change Act, and Adaptation Plan, they must also act as stewards of purpose, guiding their organisations to remain resilient, credible, and focused in an environment where climate risk is no longer a distant future but a present governance reality.

References

Australian Government (2025). Australia’s 2035 Nationally Determined Contribution. Department of Climate Change, Energy, the Environment and Water.

Climate Change Authority (2025). 2035 Targets Advice Report. Climate Change Authority, Canberra.

Department of Climate Change, Energy, the Environment and Water (2025). National Adaptation Plan. Commonwealth of Australia, Canberra.

Australian Climate Service (2025). National Climate Risk Assessment: First Pass Assessment Report and Appendix. Commonwealth of Australia, Canberra.

Guerin, T. F. (2025). When the Map Is Not the Territory: Rethinking National Environmental Governance. Governance Directions, 77(8), 11–15.

Dr Turlough Guerin FGIA is a non-executive director, board advisor and an Honorary Fellow at the University of Melbourne.