Frequently Asked Questions
A realistic planning horizon for a Group 2 entity is 12 to 18 months from initiation to a lodgement-ready disclosure. Working backwards from your reporting deadline, a well-structured program typically covers:
Months 1–3: Readiness assessment and gap analysis – understanding current governance, data, and reporting capability against AASB S2 requirements.
Months 3–6: Governance formalisation – establishing board-level climate oversight structures, management accountability, and risk assessment processes.
Months 4–8: Emissions data collection – building data systems to capture Scope 1, 2, and material Scope 3 emissions for the reporting period.
Months 6–10: Climate risk and scenario analysis – identifying, assessing, and quantifying physical and transition risks.
Months 10–12: Report drafting, internal review, and external assurance engagement (limited assurance is required in early reporting years).
Organisations that already have NGER reporting in place have a significant head start on Scope 1 and 2 data quality.
We help clients accelerate this timeline by bringing proven data systems, templates, and methodology frameworks that reduce the effort required at every stage.
The Greenhouse Gas Protocol (GHG Protocol) is the world’s most widely used accounting standard for measuring and managing greenhouse gas emissions. Originally developed in 1998 by the World Resources Institute and the World Business Council for Sustainable Development, it establishes the definitions, boundaries, and methodologies for calculating Scope 1, 2, and 3 emissions used in virtually every major corporate climate framework globally.
For Australian businesses, the GHG Protocol matters because it is the foundational methodology underpinning AASB S2, NGER, the Science Based Targets initiative, CDP, GRI, and TCFD. Any emissions inventory that doesn’t follow GHG Protocol methodology will not be accepted by auditors, investors, or regulators as credible.
In Australia, GHG Protocol methodologies are supplemented by the National Greenhouse Accounts (NGA) emission factors published annually by the Department of Climate Change, Energy, the Environment and Water – providing country-specific, state-specific, and fuel-specific factors required for Australian reporting.
We apply GHG Protocol and NGA-compliant methodologies in all greenhouse gas assessments and NGER/ASRS reporting we deliver for clients.
Carbon offsets are tradeable units representing the avoidance or removal of one tonne of CO₂-equivalent greenhouse gas emissions. They allow organisations to compensate for emissions that cannot yet be eliminated by investing in projects that reduce or remove emissions elsewhere – such as reforestation, avoided land clearing, landfill gas capture, or industrial efficiency projects.
In Australia, the primary offset mechanism is the Australian Carbon Credit Unit (ACCU), issued by the Clean Energy Regulator under the Emissions Reduction Fund. ACCUs are generated by registered Australian projects and can be purchased voluntarily or used for Safeguard Mechanism compliance.
The key principles for credible offset use are: prioritise genuine emissions reduction first; use offsets only for residual, hard-to-abate emissions; select high-quality, permanent offsets with robust co-benefits; and disclose offset use transparently in sustainability reporting. Using offsets as a substitute for genuine reduction is increasingly scrutinised by ASIC under greenwashing provisions.
We advise clients on offset strategy – which project types align with their values, what constitutes a credible offset claim under AASB S2, and how to source and retire ACCUs cost-effectively.
Climate scenario analysis is a structured process by which organisations assess how different possible future climate outcomes would affect their business model, financial position, and strategy. It asks: if the world limits warming to 1.5°C (requiring rapid decarbonisation and significant policy intervention), how does that affect our operations and assets? If warming reaches 3–4°C (with limited policy action but severe physical climate impacts), what risks does that create for our facilities and supply chains?
Yes – climate scenario analysis is required under AASB S2. It is one of the most technically demanding elements of the standard. Entities must disclose how they have used scenario analysis to assess the resilience of their strategy under different climate pathways, including at least one scenario consistent with limiting warming to 1.5°C and one higher-warming scenario.
Transition relief in early reporting years allows less quantitative approaches initially, with expectations for increasing sophistication over subsequent years.
We conduct AASB S2-aligned climate scenario analysis for clients in mining, resources, and industry – identifying physical and transition risks and opportunities material to each business and quantifying their potential financial impacts in a form suitable for board reporting and external disclosure.
Calculating greenhouse gas emissions for a mining services or logistics company follows the GHG Protocol’s Corporate Accounting and Reporting Standard and, for Australian mandatory reporting, the methodologies prescribed under NGER. The emissions profile of a services provider differs meaningfully from that of a mining operator – the focus shifts from fixed plant and extraction processes toward mobile fleets, contracted equipment, and the emissions embedded across a dispersed service delivery model.
Scope 1 emissions – direct emissions from owned or controlled sources – for mining services and logistics companies typically include diesel combustion in light and heavy vehicle fleets, mobile plant and equipment operated on client sites, and fuel used in workshops, depots, or maintenance facilities. These are calculated by multiplying fuel consumption data by the relevant National Greenhouse Accounts (NGA) emission factors published by the Australian Government.
Scope 2 emissions cover purchased electricity consumed at owned or leased facilities – including depots, workshops, offices, and camp accommodation – calculated using location-based grid emission factors for each state and territory.
Scope 3 emissions are often the most material and complex category for services providers. Key categories include fuel extraction and processing upstream of Scope 1 combustion, purchased goods and services (tyres, parts, subcontracted labour), employee commuting and business travel, and waste generated at operational facilities. For companies subject to ASRS, identifying and disclosing the most material Scope 3 categories is required – and for a fleet-intensive business, upstream fuel emissions alone can represent a significant portion of the total footprint.
We build measurement frameworks tailored to the operational structures of mining services and logistics businesses – automating data collection from fleet management systems and fuel records, applying current NGA emission factors, and producing auditable workbooks aligned with both NGER methodology and AASB S2 requirements.
The Safeguard Mechanism is an Australian Government policy that sets facility-level emissions baselines for the country’s largest industrial emitters and requires them to keep net emissions at or below those baselines.
It was reformed significantly in July 2023, introducing declining baselines that require covered facilities to reduce emissions by approximately 4.9% per year on average through to 2030, in line with Australia’s national emissions targets.
The Safeguard Mechanism applies to any facility reporting 100,000 tonnes of CO₂-e or more in direct (Scope 1) emissions under NGER in a given year. Covered sectors include mining and resources, oil and gas, manufacturing, waste, and other heavy industry.
Facilities that exceed their baseline must surrender ACCUs or SMCs. Facilities that manage their emissions well and come in below baseline can generate SMCs – tradeable credits that can be sold to other covered facilities, creating a genuine financial incentive to decarbonise ahead of the curve.
We help Safeguard-covered facilities understand their baseline trajectory, develop compliance strategies, and evaluate carbon offset options where reduction alone is insufficient.
Australia’s new mandatory climate reporting regime – the Australian Sustainability Reporting Standards (ASRS), implemented through AASB S2 – requires eligible businesses to disclose climate-related risks, opportunities, and greenhouse gas emissions with the same rigour as financial statements.
The regime is phased across three groups: Group 1 (500+ employees or $1B+ revenue or assets) reports from FY2025; Group 2 (250+ employees or $500M+ revenue or assets) from FY2026; and Group 3 (smaller listed entities) from FY2027.
Disclosures must cover four areas: governance (how your board oversees climate risk), strategy (how climate risks and opportunities affect your business), risk management (how you identify and manage climate risk), and metrics and targets (your Scope 1, 2, and 3 emissions and any net zero or reduction targets).
For Australian companies in mining, resources, agriculture, logistics, and manufacturing, the ASRS obligations are particularly significant because emissions profiles tend to be large and complex.
We help organisations assess their ASRS obligations, build the data infrastructure needed for compliant disclosure, and prepare audit-ready reports on time and at lower cost than traditional consulting approaches.
NGER reporting and the Safeguard Mechanism are related but distinct obligations that often capture the same facilities.
NGER is a measurement and transparency framework. It requires eligible facilities to measure, verify, and report their greenhouse gas emissions and energy data to the Clean Energy Regulator annually. It does not impose emissions limits – it creates the data infrastructure for accountability.
The Safeguard Mechanism is a performance and compliance framework. It applies to Australia’s largest industrial emitters – those with facilities releasing more than 100,000 tCO₂-e per year – and sets a declining annual baseline emissions limit for each covered facility. From July 2023, those baselines decrease each year, requiring facilities to reduce emissions or purchase Australian Carbon Credit Units (ACCUs) or Safeguard Mechanism Credits (SMCs) to cover any excess.
In short: NGER tells you what you emit. The Safeguard Mechanism tells you how much you’re allowed to emit and what happens when you exceed it.
We help clients understand both obligations, build robust NGER data systems, and develop strategies to stay within Safeguard baselines.
NGER stands for the National Greenhouse and Energy Reporting Act 2007 – Australia’s primary federal legislation requiring businesses to measure and report their greenhouse gas emissions and energy use to the Clean Energy Regulator each year.
NGER reporting is mandatory for any Australian corporation that operates a facility meeting threshold triggers: 200 terajoules (TJ) or more of energy production or consumption at a single facility, or 25,000 tonnes of CO₂-equivalent (tCO₂-e) or more in greenhouse gas emissions at a facility. At the corporate group level, thresholds are 200 TJ or 50,000 tCO₂-e across all controlled facilities.
Industries most commonly captured include mining, oil and gas, agriculture, manufacturing, logistics, and large commercial property. Even if you fall below mandatory thresholds, voluntary NGER reporting can significantly strengthen your ASRS and AASB S2 disclosures.
We conduct NGER threshold assessments, manage annual data collection, prepare and lodge reports with the Clean Energy Regulator, and provide ongoing audit support.

