If your business runs a few large sites — solar or wind farms, a battery, a mine, a manufacturing plant — there is a good chance it has to report its greenhouse gas emissions and energy use to the Australian Government every year under the National Greenhouse and Energy Reporting scheme — NGERs. This guide explains the scheme, the process, and the habits that keep a company compliant without a scramble every October.
What NGERs is
NGERs is the National Greenhouse and Energy Reporting scheme: the national framework for reporting greenhouse gas emissions, energy production and energy consumption. It was established by the National Greenhouse and Energy Reporting Act 2007 and is administered by the Clean Energy Regulator. Corporations that meet a threshold must register, report every year, and keep the records behind the numbers.
The data is not just filed away. The Regulator publishes corporate totals, uses them to administer the Safeguard Mechanism, and — since 2026 — the same figures feed into mandatory climate reporting under the Corporations Act, where they are reviewed by an auditor.
Who has to report
Reporting is triggered by thresholds, assessed on the corporate group for a financial year. There are two levels:
- Facility threshold — any single facility that emits 25 kilotonnes or more of CO₂-e (scope 1 and 2 combined), or produces or consumes 100 terajoules or more of energy.
- Corporate group threshold — 50 kilotonnes of CO₂-e, or 200 terajoules, added up across every facility under the group's operational control.
“Operational control” is the concept that decides which sites belong in your report. Broadly, it sits with the entity that has authority over the site's operating, health and safety, and environmental policies — which is not always the entity that owns it, and not always the one whose name is on the gate. Contracted operations, joint ventures and project companies are exactly where this gets contested.
Renewable energy portfolios usually cross on energy produced rather than emissions: a single utility-scale solar or wind farm clears 100 terajoules comfortably, while emitting almost nothing. A business can be well inside the scheme without anyone thinking of it as an emitter. Check your figures against the thresholds →
The reporting year and key dates
- 1 July – 30 June
- The reporting year. Data is collected for this period.
- 31 August
- Deadline to apply for registration, if you met a threshold for the first time in the year just ended.
- 31 October
- Report due to the Clean Energy Regulator through the EERS portal.
- 28 February
- The Regulator publishes reported corporate emissions and energy data.
What gets reported
For each facility, a report covers:
- Scope 1 emissions — released directly on site: fuel combustion, process emissions, fugitive losses.
- Scope 2 emissions — from purchased electricity.
- Energy produced — electricity generated, fuels extracted or manufactured.
- Energy consumed — fuels burned and electricity used.
The calculations follow the National Greenhouse and Energy Reporting (Measurement) Determination 2008, which sets out the permitted methods and emission factors for each source. For most sources there is a choice of methods, from default factors through to direct measurement; the method used should be recorded, and a change of method needs a reason that would satisfy a reviewer.
The process, step by step
- 01
Map the boundary
List every facility the corporate group has operational control over — including sites run by contractors, joint ventures and special-purpose entities. Decide where each facility starts and ends. This is the step most reporting problems trace back to, and it needs revisiting every year as assets are bought, sold and commissioned.
- 02
Register what's new
A corporation registers once, but new facilities have to be added in EERS as they come online. A site that reached commercial operation in March is a reporting facility for that year.
- 03
Collect the data
Meter readings, fuel deliveries, invoices, dispatch and generation records — usually held by whoever operates each site rather than by head office. Issue a clear data request early, follow it up, and keep what comes back as evidence.
- 04
Calculate
Apply the methods and factors set out in the Measurement Determination to turn activity data into scope 1 and scope 2 emissions and energy figures, site by site. The method used for each source should be recorded, and changed only with a documented reason.
- 05
Review
Reconcile this year to last, explain every material movement, check the boundary list against reality, and confirm the evidence for each figure is filed where a reviewer could find it.
- 06
Lodge and keep records
Submit through EERS before 31 October and retain the underlying records for five years. The Regulator can request them, and from 2026 an auditor is likely to.
What changed in 2026
Until recently, an NGERs report was a filing: lodged with the Regulator, checked for completeness, and rarely examined further. That changed with Australia's mandatory climate-related financial disclosures.
The second group of companies came into that regime on 1 July 2026, and it captures NGERs reporters. Because the accounting standard lets NGERs reporters use their NGERs methods for scope 1 and 2, the figures lodged with the Regulator are the same figures that appear in a director-signed sustainability report — and under the assurance standard, scope 1 and 2 are subject to limited assurance from the first year of reporting. For a June year-end, that first year is the one running now.
The practical consequence: the evidence behind each number has to exist as the year goes, in a form an auditor can follow. A spreadsheet that was good enough for the Regulator is not necessarily good enough for a review.
Where compliance usually slips
Very few companies fail to report. What goes wrong is quieter than that — and the same handful of things, year after year.
- Boundary drift. Sites acquired, divested, restructured or handed to a new operator without the facility list being updated. The report then describes a business that no longer exists.
- Late or incomplete data from contractors. The people who hold the meter reads are not the people who lodge the report. Every year a site's data arrives in October, half-filled, in a different format from last time.
- New sites nobody registered. An asset energises mid-year, the project team moves on, and nobody tells whoever runs NGERs. It surfaces the following year as an omission.
- Undocumented method changes. A different calculation approach from one year to the next, with no record of why. It is often correct — and impossible to defend.
- A spreadsheet with no version control. One file, many editors, no change history. Fine until someone asks how a number was arrived at.
- Evidence assembled after the fact. Working papers reconstructed in October to support figures already lodged. Under assurance, this is the pattern that produces findings.
- Key-person risk. The whole process lives in one person's head. When they leave, so does the method.
Staying compliant
None of this needs new software. It needs a process that runs on a calendar rather than on memory.
- Review the facility list and each boundary every year, and after every acquisition, divestment or commissioning.
- Keep a site register that names who operates each facility and who supplies its data.
- Issue data requests on a calendar — quarterly, not once in September.
- Record the calculation method for each emission and energy source, and the reason for any change.
- Keep working papers as you go: source documents, calculations and reconciliations, filed by site and year.
- Reconcile to the previous year and write down why each material figure moved.
- Diarise 31 August and 31 October, and start the year's work in July.
If most of that list already happens in your business, the annual report is a couple of weeks of work. If it does not, the first year of putting it in place is the hard one — and it is the year to get help with.
General information only, current at the time of writing. It is not legal or professional advice. Verify thresholds, dates and assurance requirements against the current legislative instruments before relying on them.