Clear Carbon - Enterprise Environmental Management Platform

Is there NGER Scope 3 reporting?

NGER Scope 3 reporting does not exist. The Clean Energy Regulator states that Scope 3 emissions are not reportable under the NGER Scheme, which covers Scope 1 and Scope 2 emissions, energy production and energy consumption.

Key points

  1. Scope 3 emissions are not reportable under NGER
  2. The NGER Act defines an emission as Scope 1 or Scope 2 only
  3. AASB S2 requires Scope 3 disclosure, with first-year transitional relief
  4. The National Greenhouse Accounts Factors can be used to estimate Scope 3

Why Scope 3 sits outside NGER

The NGER Act defines an emission of greenhouse gas as a Scope 1 or a Scope 2 emission. Its obligations attach to facilities under a corporation’s operational control, while Scope 3 emissions occur elsewhere in the value chain.

Where Scope 3 is required

AASB S2 Climate-related Disclosures, the standard applied under Australia’s mandatory sustainability reporting regime, requires entities to disclose Scope 3 greenhouse gas emissions, with transitional relief in an entity’s first annual reporting period. A corporation can therefore have no Scope 3 obligation under NGER and still need Scope 3 data for its sustainability report.

How the two regimes differ

AASB S2 also requires Scope 1 and Scope 2 emissions, with Scope 2 on a location-based basis. The boundaries differ, though. NGER reports facilities under a corporation’s operational control, while AASB S2 separates the consolidated accounting group from other investees. An NGER inventory is a strong starting point for Scope 1 and Scope 2 under AASB S2, but the two boundaries need to be reconciled. AASB S2 also requires an entity to state which of the Scope 3 categories in the GHG Protocol Corporate Value Chain (Scope 3) Standard are included in its measure.

What this means in practice

For a corporation in both regimes, one dataset can serve both, provided each figure carries its boundary, method and emission factor source. NGER figures must use the Measurement Determination for the reporting year, while Scope 3 estimates can draw on the National Greenhouse Accounts Factors and data from suppliers and customers.

Estimating Scope 3

The Regulator points reporters to the National Greenhouse Accounts Factors, published by DCCEEW, for estimating Scope 3 emissions. DCCEEW states that those factors are not to be used for NGER reporting, which must follow the Measurement Determination.

References & sources

Primary regulatory documents and authoritative references underpinning this answer.

  1. Clean Energy Regulator: Emissions and energy typescer.gov.au
  2. AASB S2 Climate-related Disclosures (September 2024)standards.aasb.gov.au
  3. DCCEEW: National Greenhouse Accounts Factorsdcceew.gov.au
  4. GHG Protocol: Corporate Value Chain (Scope 3) Standardghgprotocol.org
  5. National Greenhouse and Energy Reporting Act 2007 (section 7)legislation.gov.au