This consultation is now closed. We have published the outcomes on this page.
We want feedback on the design of a corporate emissions reduction transparency report and its proposed guidelines.
Background
Business has an important role to play in reducing Australia’s carbon emissions. Interest in voluntary action is growing and can be seen through the increasing number of companies setting commitments to reduce emissions and increase the use of renewable electricity.
The Corporate Emissions Reduction Transparency (CERT) Report is a voluntary initiative. It will support National Greenhouse and Energy Reporting (NGER) Scheme companies that meet the publication threshold to publicly report on emissions reduction commitments and their progress on meeting them.
Timeline
- Public consultation 1: 19 February to 19 March 2021
- Public consultation 2: 18 October to 1 November 2021
- Pilot: 30 November 2021 to 7 July 2022
- Public consultation 3: 5 September to 26 September 2022
Consultation stages
Find out more about each stage of the consultation process.
Stakeholders are increasingly seeking greater transparency and data around voluntary corporate emissions reduction and renewable electricity commitments. While many Australian companies voluntarily report their emissions data and target information, the varying formats and detail can make comparisons difficult. We have been collaborating with industry to develop a simple way of presenting a company’s net emissions position.
The initial design of the CERT Report was established with draft guidelines and a simple format. The report presented key emissions, renewable energy carbon offset information and data for participating NGER Scheme companies.
We published a consultation paper seeking feedback on a possible design of the report and its proposed guidelines.
What we heard
We received 55 submissions in response to our consultation paper. Most submissions stated that they valued an independently published report that presented the net emissions position of participating companies as well as progress against their voluntary commitments. Stakeholders also expressed support for the report to:
- provide flexibility in how emissions reduction commitments were presented, including the ability to present multiple commitments
- align with other domestic and international sustainability reporting frameworks where practical
- allow context statements to be included to aid understanding
- cover both net scope 1 and net scope 2 emissions.
Submissions
Some submissions are confidential and have not been published. Submissions are not owned by us, and we can't guarantee they meet accessibility requirements.
- CERT submission – Australian Energy Council
- CERT submission – Australian Gas Infrastructure Group
- CERT submission – AGL Energy Limited
- CERT submission – Alinta Energy
- CERT submission – Australian Aluminium Council
- CERT submission – Appea
- CERT submission – Business Council of Australia
- CERT submission – BHP
- CERT submission – Bioenergy Australia
- CERT submission – Bureau of Steel Manufacturers of Australia
- CERT submission – Citizens’ Climate Lobby Australia
- CERT submission – City of Melbourne
- CERT submission – Clean Gas Council
- CERT submission – Climateworks Australia
- CERT submission – Chamber of Minerals and Mining of Western Australia
- CERT submission – Cooper Energy
- CERT submission – CSIRO
- CERT submission – Hydro Tasmania
- CERT submission – Investor Group on Climate Change
- CERT submission – NAB
- CERT submission – NABERS
- CERT submission – National GreenPower Accreditation Program
- CERT submission – Ndevr Environmental
- CERT submission – Northmore Gordon
- CERT submission – Orica
- CERT submission – Property Council of Australia
- CERT submission – Rio Tinto
- CERT submission – SANTOS
- CERT submission – Six Capitals Consulting
- CERT submission – South East Water Attachment A
- CERT submission – South East Water
- CERT submission – Tim Kelly
- CERT submission – Town of Gawler
- CERT submission – Wilmar
- CERT submission – Woodside
- CERT submission – World Kinect Energy Services
- CERT submission – WWF and Global Compact Network Australia
We published a consultation paper seeking feedback on the practical implementation of the guidelines for the report.
What we heard
We received 34 submissions (10 of which were confidential). Most submissions supported the report in principle and agreed that the proposed guidelines were a suitable basis for the pilot. Beyond the pilot, stakeholders were of the view that the report should evolve in the following ways:
- Include the ability to verify data associated with scope 3 emissions commitments, emissions intensity commitments, and international commitments and activities.
- Recognise large-scale generation certificate surrenders as part of jurisdictional renewable energy targets in the calculation of progress on renewable electricity commitments.
- Publish more detail about carbon units.
- Support participation by a broader group of companies beyond those that currently meet the NGER publication threshold.
- Update state emissions factors for scope 2 emissions and expand eligible inputs to the calculation of the renewable electricity percentage.
Many submissions sought further clarity around the operation of specific aspects of the guidelines. Stakeholders also suggested improvements to the proposed company view, especially around the presentation of certificates and carbon units.
Stakeholders welcomed the public consultation and recent co-design process. Many noted the positive progress that had been made on the report's design.
Submissions
- AGL Energy Limited
- Alinta Energy
- APA
- Australian Aluminium Council
- Australian Petroleum Production and Exploration Association Ltd
- Bioenergy Australia
- Cement Industry Federation
- Chartered Accountants Australia and New Zealand
- Clean Energy Council
- ClimateWorks Australia
- Electricity Working Group of South Australian Councils
- EnergyAustralia
- Engineers Australia
- GFG Alliance Australia
- Green Building Council of Australia
- Hydro Tasmania
- Iberdrola Australia
- KPMG
- NABERS
- Neoen Australia
- Pangolin Associates
- Property Council of Australia
- Six Capitals Consulting
- Tim Kelly
- Water Corporation of Western Australia
What we will do
We made minor updates to the guidelines and the company view as outlined below. We will also consider key themes raised in submissions and undertake further work where required, either during the pilot, the pilot evaluation or as part of the report's future design.
Updates to the guidelines
We updated the report guidelines to provide further clarity on the operation or context of specific elements. The guidelines now more clearly allow progress to be presented in terms of tonnes carbon dioxide equivalent (CO2-e), as well as a percentage, where relevant to a company's commitment.
Examples and explanatory information
Supporting information, including a suite of examples, will be published to assist companies to understand and use the report guidelines.
Updates to the company view
We have adjusted the company view. This includes:
- visually separating large-scale generation certificates from carbon offset units.
- presenting progress in terms of tonne CO2-e alongside the percentage value.
- highlighting scope 3 efforts by including an icon for relevant commitments.
You can view an updated version of the company view. The company view will continue to be refined.
Design elements for future consideration
During public consultation, stakeholders raised themes for us to consider as part of the report’s evolution. Our proposed approach is set out in the table.
| Suggestions from stakeholders | Our approach |
| Include large-scale generation certificate surrenders made under jurisdictional renewable energy targets. | We will consider this issue in parallel with the pilot. |
| Recognise emissions intensity and renewable generation commitments as ‘progress verified’ using agency data; recognise contractual agreements as evidence. | We will consider this for the future design of the report, noting that further work is required to be able to verify data associated with emissions intensity commitments. To avoid double counting, PPAs and contractual commitments for renewable electricity will not be accepted in the report. |
| Broaden eligibility to companies beyond NGER reporters above the publication threshold. | We will consider this issue during the evaluation of the pilot. |
| Recognise global commitments and associated emissions reduction activities. | Participants can include international commitments in the ‘Other commitments - company assured’ section. At this stage, we do not intend to expand the report to include verification of data associated with international emissions commitments or activities. We're open to considering how international commitments may best be presented in the company view as part of the report’s future design. |
| Recognise Scope 3 emissions commitments as progress verified, particularly where a higher level of independent assurance has been undertaken by third parties (e.g SBTi commitments). | Participants can include Scope 3 emissions commitments in the ‘Other commitments - company assured’ section and include notes or links regarding any independent verification undertaken. We are open to exploring how independently audited information may best be presented in the company view as part of the report’s future design. |
| Recognise Climate Active certified products (electricity, fuels, etc.) and related units. | We will consider how best to address this as part of the report’s future design, in consultation with relevant government agencies. |
| Review the residual mix factor calculation methodology. | We will consider how best to address this as part of the report’s future design, in consultation with relevant government agencies. |
| Include other sources of emissions generated from activities that are not reportable as part the NGER Scheme. | We will consider how best to address this as part of the report’s future design, in consultation with relevant government agencies. |
| Review scope 2 accounting methodology, including emission factors. Recognise small-scale generation and other sources of electricity generation. | We will consider how best to address this as part of the report’s future design, in consultation with relevant government agencies. |
| Review renewable percentage calculation and recognise below baseline renewables and other types of electricity generation. | We will consider how best to address this as part of the report’s future design, in consultation with relevant government agencies. |
| Company view: Publish more detail on carbon units attributes. | We will consider further transparency on units in parallel with pilot for potential inclusion in future design of the report. |
| Company view: Consider an alternate way to present progress towards long-term, capital-intensive commitments that result in step-change emissions reductions | We will consider whether further changes would aid comprehension in future design of the report, noting that capital-intensive targets (step change) can already be described in commitment context statement. |
| Company view: Clarify where the report aligns or diverges from Climate Active and GHG Protocol. | We will provide guidance on any areas of divergence between the report, Climate Active and the GHG Protocol. |
| Company view: Allow groupings of subsidiaries rather than just subsidiaries and parents. | We will undertake further work during the pilot to consider alternative groupings of subsidiaries. For example, we can consider adding further icons or other visual elements to the company view to aid readability. |
We published a consultation paper seeking feedback on the updated design for the 2023 report.
What we heard
We received 15 submissions (2 of which were confidential). Stakeholders continued to support the report and appreciated the public consultation, co-design and engagement undertaken.
Most submissions were broadly supportive of the proposed updates to the guidelines. In regard to the future of the report, stakeholders expressed support for the following updates:
- Make the level of independent assurance clear and refine assurance requirements over time as auditing and assurance expertise and technology matures.
- Continue to improve alignment with other reporting frameworks, including the Greenhouse Gas Protocol and the Australian Government’s Climate Active program.
- Improve clarity on the application of residual mix factors and market-based scope 2 emissions accounting.
- Expand eligible inputs to the calculation of net emissions and renewable electricity percentage.
Stakeholders continued to support the report as a valuable information source. They noted the positive progress that has been made on the design of the report so far.
Submissions
- AGL Energy Limited
- Australian Aluminium Council
- BHP
- Bioenergy Australia
- Chartered Accountants Australia and New Zealand
- Fortescue Metals Group Ltd
- Hydro Tasmania
- National GreenPower Accreditation Program
- Property Council of Australia
- PwC Australia
- Tim Kelly
- Town of Gawler
- Trellis Technologies
What we will do
We have updated the report guidelines to address issues identified during the pilot and implement the proposed changes set out in the consultation paper. We'll continue to evolve the design of the report as the Australian and international mandatory and voluntary climate disclosure regimes develop further.
Key updates to the guidelines for the CERT Report 2023
Feedback from pilot companies, consultation submissions and other stakeholders has been incorporated into the guidelines for the 2023 report. A summary of these changes:
- Completing the picture of a company’s climate related commitments: Companies are required to report all eligible climate-related commitments in the report. This includes commitments relating to their greenhouse gas emissions and energy use.
- Recognising independently assured commitments: We represent independently assured commitments as a third commitment category. This allows companies to show progress on their commitments where progress can't be verified using our data – including commitments relating to a company’s emissions intensity, scope 3 or international emissions.
- Adding a jurisdictional power percentage: Recognising large-scale generation certificate surrenders on behalf of a jurisdiction (for example, the ACT Government’s Renewable Energy Target) better reflects the renewable electricity consumption of companies located in jurisdictions with a renewable electricity target.
- Streamlining reporting requirements: An alternative methodology has been developed for calendar year and equity reporting, where companies may report independently assured data directly to us. This addresses issues raised by companies regarding the complexities of adjusting NGER data for equity share or calendar year reporting.
- Updating the residual mix factor: The Australia Government’s Climate Active scheme is planning to update their calculation of the residual mix factor – an important factor in market-based scope 2 emissions accounting. The proposed methodology will improve accuracy and reduce the potential for double counting by excluding voluntary large-scale and small-scale renewables that could be claimed under either the report or Climate Active. The 2023 report has adopted the new methodology planned for 2022 calendar year reporting.
- Revising base period emissions in response to structural changes: Where a company has undergone a significant structural change (such as a merger, acquisition or divestment), the company should revise their base period emissions to allow meaningful comparison of the company’s progress over time.
Following public consultation one, we undertook a co-design process with a cohort of NGER reporters.
The process took into account feedback from public consultation and considered how the report could contribute to the corporate sustainability reporting of companies. A number of areas were worked on, including:
- the scope of the report
- alignment with how emissions commitments are framed
- accounting frameworks
- the options for presenting data in the report.
A key priority was balancing the need for flexibility with the need for clarity and comparability.
As a result of the co-design process, we developed updated guidelines and an improved report format.
The report pilot is now complete.
The CERT Report 2022 operated as a pilot to test and refine the guidelines, administration and reporting arrangements. The guidelines will continue to evolve beyond the pilot.
Participation in the pilot was open to companies reporting more than 50 kilo tonnes of emissions a year under the NGER Scheme.
Twenty-three companies participated in the pilot, presenting:
- progress on their emission reduction commitments
- their net emissions and renewable electricity position
- the volume and percentage of certificates and units voluntarily surrendered.
Outcomes
We created and published the first CERT Report on 7 July 2022.