ACCU Scheme project activities, suppressors and agents

On 19 June 2025, we published new information on the Australian Carbon Credit Unit (ACCU) Scheme project register. This is the second of 3 releases published on the register made possible by the recent amendment to the Carbon Credits (Carbon Farming Initiative) Rule 2015. 

The publication of this new information enhances transparency about how projects within the ACCU Scheme operate and are regulated as well as how they deliver ACCUs. It reinforces the integrity of the scheme and supports Australia’s efforts to accelerate carbon abatement. 

The new data includes: 

• project activities
• project suppressors (if applicable)
• project agents. 

We’ve analysed this new data to help explain and provide insights into ACCU Scheme participation and administration. 

This release also allows project proponents to voluntarily supply details of any significantly involved persons they have relied on when registering or administering projects. Significantly involved persons are not carbon service providers or agents. They are other individuals who support proponents, such as by providing technical advice or undertaking work to deliver a project. Proponents can provide this information when completing registration and crediting applications. It will then be added to the project register.  

Project activity data

Project activities are actions that a project proponent implements during the crediting period to deliver carbon abatement outcomes. Project activities must be new or materially different from what was being undertaken during the baseline period to achieve real and additional carbon abatement under the ACCU Scheme. 

Project activity data has been continuously collected, primarily for internal administrative purposes, since the ACCU Scheme began in 2011. Some methods require proponents to specify an implementation under a broadly defined project activity. Where possible, we have included that level of detail in the project register publication. 

Eligible project activities

Eligible activities are often defined by the methodology determination that the project is declared under. Project proponents identify project activities at registration, and the eligibility of these activities is assessed (including whether they meet the newness, regulatory additionality and in lieu of government program requirements).  

Proponents requesting to vary a project’s method may also need to identify new activities for the project to meet the eligibility criteria of the new method.

Some methods only have a few eligible activities. For example, the reforestation by environmental or mallee plantings methods (the current 2024 method and previous 2014 method) only permit permanent plantings of mixed-species environmental plantings or permanent mallee plantings (see figure 1). Other methods define a greater number of possible project activities. The estimating soil organic carbon sequestration using measurement and models method (2021 soil carbon method), for example, lists 13 options (see figure 2).

Multiple project activities

Projects may undertake multiple activities under a method.  

Implementing multiple project activities may increase project outcomes, resulting in greater carbon sequestration or avoidance, and may produce better environmental or agricultural outcomes.  

Figure 3 shows the number of activities being undertaken at any one time by projects registered under the 2021 soil carbon method.

Changes in project activities

Throughout the conduct of a project, proponents are required to notify us of any reportable changes to their projects through the submission of offsets reports. This includes any significant changes to the way the project is being conducted, including any new or removed activities.

As such, project activities listed for a project in the register may not always align with the activities that a project is undertaking at a specific point in time. Any updates will be published after the project’s next offsets report has been assessed.

Introducing a new activity into an existing project can strengthen current carbon abatement efforts or address limitations in the existing approach, ultimately enhancing the project's resilience and helping proponents manage risk.

This is particularly relevant for sequestration projects, as land management is complex and involves the need to adapt to local circumstances and climatic conditions. As a result, it is expected that project management will adapt and change over the life of the project to maximise carbon sequestration and manage risks.

Project suppressors data

Suppression mechanisms only apply to regeneration projects and refer to something that prevented the development of forest cover during the project’s baseline period.

Suppression mechanisms determine the types of project activities that can be conducted. For example, for a project to apply the activity ‘cessation of mechanical or chemical destruction, or suppression, of regrowth’, the land used for the project must have experienced such destruction or suppression during the baseline period. If the land was subject to mechanical or chemical suppression before – but not during – the baseline period, this activity is not eligible.

All projects are prohibited from significantly damaging vegetation within their carbon estimation areas throughout the permanence period.

Suppression mechanisms and project activities

Suppression mechanisms for each project are listed on the register.  

These mechanisms must be sufficiently evidenced, and a causal relationship must be established with the project activities being implemented. This was clarified through recommendation 8 of the Independent Review of ACCUs 2022, and subsequently by our implementation of the recommendation.

The causal relationship approach defines the set of activities that apply to human-induced regeneration projects (see figure 4).

Not all supporting actions undertaken by proponents to manage regeneration threats can be considered eligible project activities. 

For example, if feral animals become a problem during the project period, but were not a problem during the baseline period, the management of feral animals can’t be listed as a project activity even if it occurs. This is because the cause of suppression must occur in the baseline period. 

Other examples of supporting actions for regeneration projects that are not considered eligible project activities include: 

• establishing and maintaining fire breaks  
• managing weeds
• controlling erosion
• maintaining access tracks. 

Despite these actions not being considered eligible project activities, they may reflect actions taken to ensure the project’s permanence obligations are met. These actions ensure the carbon stock within the project area is protected.  

Project activities and outcomes

Regardless of the activities identified in a project, the realisation of carbon abatement is inherently complex and influenced by a wide range of factors, such as: 

• geography
• the biophysical condition of the land
• historical land use practices
• the proponent’s capacity to effectively implement the project and identify and manage risks.

Consequently, attempts to establish a direct relationship between a specific activity and resulting carbon abatement are unlikely to produce meaningful results.

The CER manages risks in project execution by only crediting actual carbon sequestration abatement that is validated through project offsets reports, audits and independent in-field verification.  

Agent data

Participating in the ACCU Scheme can require support from specialist firms and experts. While project proponents are ultimately responsible for delivering the project and bearing the associated risks, help is available to navigate the technical and administrative challenges involved.

There are 3 common models used to support participation in the ACCU Scheme:

• Agent model: Many project proponents engage agents to help with project management. Similar to tax agents, these individuals or organisations are authorised to act on behalf of the proponent in managing specific aspects of an ACCU project. This relationship is governed by a formal agreement, and proponents may change agents in line with the terms of that agreement. The agent listed on the project register reflects the most recent agent information provided to us.
• Carbon service providers: Landholders or leaseholders may transfer the right to conduct a project to another party – often a carbon service provider (also known as an aggregator or project developer). These commercial entities specialise in developing and operating carbon abatement projects. They take on key aspects of project risk and responsibility, while the landholder often continues to play a fundamental role in the project’s delivery on the ground.
• Proponent-managed: In this model, the individual or entity who owns the property or facility is directly responsible for managing all aspects of scheme participation. They may seek advice or outsource specific tasks to specialist firms or experts to assist in project administration.

Figure 5 shows the number of projects operating under these different models. Of the 2,298 currently registered ACCU Scheme projects, 578 (25%) used an agent to support the management and administration of their project (note that carbon service providers that also have an agent in place have not been included). A further 1,228 projects (53%) had a carbon service provider undertaking the delivery of the project as a project proponent. The remaining 492 projects were managed by the land or facility owner (21%). 

An analysis of the key agents and carbon service providers by the number of projects they support shows that agents and service providers tend to specialise in one method type, such as vegetation or agriculture. This suggests the high level of technical understanding and proficiency that is required to support the administration of ACCU Scheme projects at scale, and the people, processes and systems that must be in place.