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On 3 May 2023, the Minister for Climate Change and Energy made a direction to the Clean Energy Regulator (CER) concerning the administration of Human-Induced Regeneration (HIR) projects. It includes a direction on the implementation of audits under section 215 of the Carbon Credits (Carbon Farming Initiative) Act 2011 for HIR projects.

From 6 May 2023 onwards, all regeneration gateway check reports submitted to the CER will be subject to an audit to confirm that the regeneration gateway check complies with the legislative requirements in particular section 9AA and 70(3A) of the Carbon Credits (Carbon Farming Initiative) Rule 2015, taking into account the Guidelines on stratification, evidence and records.

As you may be aware, the CER conducts an annual audit program as part of its broader compliance monitoring strategy. The CER will expand its audit program to cover 5 yearly regeneration gateway audits.

The CER will appoint auditors for these engagements from the current panel for Greenhouse and Energy Audit Services (SON3658866). When appointing the auditor, the CER will need to be satisfied that the auditor or one or more audit team members have expertise in relation to ecological assessment, either through an appropriate qualification and/or relevant experience.

The CER will also commission an independent expert to regularly review and report on HIR regeneration gateway checks in aggregate for publication. This will provide greater transparency about the outcome of regeneration gateway checks across the HIR project portfolio. Audit reports undertaken under s215 of the Carbon Credits (Carbon Farming Initiative) Act 2011 will be included as part of independent expert’s review. Australian Carbon Credit Units will be issued once the CER is satisfied that the requirements of a regeneration gateway check have been met.

The CER has also recently developed guidance that outlines the implementation of the Australian Carbon Credit Unit (ACCU) Review Recommendation 8 for HIR projects. The CER expects that in undertaking audits of HIR projects, including for scheduled audits, auditors will take into account the requirements of these guidelines for project proponents. This includes information and record keeping requirements at both registration and crediting, and requirements for the recommended causal relationship for suppression, demonstration of the removal of suppressors, and consistent application of FullCAM guidance. Auditors must also continue to assure that HIR projects meet the requirements of the Guidelines on stratification, evidence and records.

Please contact CER-Audit@cer.gov.au if you have any questions about audits of regeneration gateway checks.