Maintain your registration as an auditor

You must follow the Code of Conduct set out in section 6.46 of the Regulations.

Under this code, it’s expected you will:

• comply with the law and regulations that apply to you as a registered greenhouse and energy auditor
• behave with integrity and objectivity
• apply professional competence and due care
• be honest and truthful in marketing or self-promotion
• ensure other audit team members follow the code if you’re the audit team leader
• avoid doing anything that could discredit you or greenhouse and energy auditors in general.

Marketing and self-promotion

Misleading marketing or self-promotion is a breach of the Code of Conduct. You must make sure that any public or confidential marketing is done in line with the legislation.

You must not make exaggerated claims about:

• the audits services you provide
• your qualifications
• your experience as an auditor.

You also must not make negative comments or unsupported claims about the work of other audit teams.

Only use Category 1 auditor and Category 2 auditor terms as defined in section 6.25(3) of the Regulations. You cannot use other categories that are not defined in the Regulations, such as:

• Category 1 NGER technical registered greenhouse and energy auditor
• Category 1 Non technical registered greenhouse and energy auditor
• Category 1 CFI technical registered greenhouse and energy auditor
• Category 3 registered greenhouse and energy auditor
• other terms like 'Category 1 NGER auditor' and 'NGER auditor'.

If you are not a registered greenhouse and energy auditor, you cannot mention registration as a greenhouse and energy auditor. This includes terms like 'in training' or 'in progress'.

We only register greenhouse and energy auditors, not accredit or employ them. We only register individuals, not audit firms or teams.

Registration as a greenhouse and energy auditor is not a qualification. It doesn't represent membership of a professional association.

You must continue to meet fit and proper person requirements to keep your registration.

To act independently, you must not participate in the schemes we administer. It’s also important you're separate from the entity you audit.

You have a conflict of interest if you:

• participate as a proponent, agent or investor in an Australian Carbon Credit Unit (ACCU) Scheme project
• bid in ACCU auctions
• trade in Australian carbon credit units.

If you find a conflict of interest during an audit, you should do everything you can to resolve it. If the conflict is not resolved or you don't have permission to continue, you must stop working on the audit.

For more information, visit conflicts of interest for auditors.

You must have adequate professional indemnity insurance when preparing for or doing an audit. It protects you against claims of professional negligence.

Your professional indemnity insurance should cover all aspects of your work. Generic policies may not provide enough coverage.

The type of work you do affects how much you pay for insurance. Insurance firms often see auditors as risker than consultants, so auditors usually have higher premiums. It's important to accurately describe your work to make sure you have enough coverage.

You should regularly review your insurance to make sure it still meets your needs.

Section 6.60 of the Regulations sets out the minimum insurance standards for audit team leaders during an audit. You need to determine whether your insurance meets your obligations under the Regulations.

Under regulation 6.66 of the Regulations, you must participate in a substantial way in at least 3 audits every 3 years.

We assess participation within each 3-year period of registration. We only count audits that were done during the 3-year period under review.

Category 1 auditors

For Category 1 auditors, you must meet both of following requirements every 3 years:

• participate as a team member in audits for a total of 90 hours or more
• participate as a team member in 3 audits.

Participation can be spread across multiple audits. There is no minimum or maximum number of hours per audit.

Peer review is not acceptable for Category 1 participation requirements.

Category 2 auditors

For Category 2 auditors, you must perform as team leader in one audit every 3 years. In addition to this, you must also meet one of the following criteria in the same 3-years period:

• perform as team leader in 2 audits
• perform as team leader in one audit and as peer reviewer in at least 3 audits
• perform as peer reviewer in at least 6 audits
• perform as team leader in one audit and as a team member in one or more audits for at least 30 hours
• perform as a team member in 2 or more audits for at least 60 hours.

When performing as a team member, hours can be spread across multiple audits. For example, you can do 30 hours across 4 audits or 30 hours across 2 audits.

We prefer you meet your participation requirement by performing as team member in a total of 3 or more audits.

You can perform in as many team leadership, peer review and team member roles as you want.

Accepted audit types

To meet participation requirements, audits must be either a Part 6 audit or an alternative audit.

A Part 6 audit is:

• an ACCU Scheme audit
• a safeguard mechanism audit
• a greenhouse and energy audit conducted under sections 73 or 74 of the National Greenhouse and Energy Reporting Act 2007.

An alternative audit is comparable to a Part 6 audit and is:

• a voluntary audit conducted under the National Greenhouse and Energy Reporting Scheme or the ACCU Scheme that is in addition to specified requirements
• an exemptions certificate audit conducted under the Renewable Energy Target
• any other audit we commission.

We must review an alternative audit to determine if it's comparable to a Part 6 audit. To do this, you must submit the complete audit to us voluntarily.

You must complete 15 days or 112 hours of CPD within each 3-year period of registration.

For more information, visit professional development for auditors.

You must submit a report to us each year on the anniversary of your registration as a greenhouse and energy auditor.

Reports must contain information about any audits and continuing professional development you did in the previous 12 months.

We may request further information from you as part of your annual reporting. For example, if we’ve observed a performance issue in a previous review period or if we have placed a condition on your registration.

We'll assess the information in your annual report and let you know if you aren't meeting the requirements to keep your registration.

To submit annual reports, download our registered greenhouse and energy auditor annual report form.

You will receive written notice if we plan to review your registration or conduct an inspection.

Reviews

We may review your registration as an auditor.

Typically, this will occur every 3 years on the anniversary of your registration. We'll review information provided through your annual reports but may request extra information as part of a review.

If the requirements to maintain your registration were updated during your 3-year review period, we'll consider your activity under previous requirements as part of our assessment.

Inspections

Under section 6.5.6 of the Regulations, we may inspect your performance as an auditor.

The purpose of an inspection is to:

• review how you make decisions during Part 6 audits
• ensure you comply with the requirements set out in the Determination and Regulations during Part 6 audits
• collect information to help us manage auditor performance.

We consider a range of criteria like risk, performance and activity when selecting auditors to participate in an inspection.

An independent team of inspectors conducts inspections. Inspections may be conducted up to 5 years after the completion of a Part 6 audit.

If you’re a Category 2 audit team leader and use supervisory hours to show audit team leadership, you'll be inspected after you lead at least one audit. This inspection may occur within the first 12 months of your registration.

Based on the outcomes of an inspection, we may take compliance action. For example, we may:

• recommend you make improvements to your performance and follow up to confirm you have made them
• impose conditions on your registration, like completing training or restricting you from conducting audits in specific schemes
• deregister or suspend you.

For more information, watch our webinar on the top 10 findings from auditor inspections.

On-site inspections

During an on-site inspection, inspectors will visit your premises to review Part 6 audit files. This process usually takes 2 to 3 days. If you’ve been selected, we’ll contact you to arrange a date and time.

Inspectors require full, free access to audit files and other relevant documents during the inspection. They may need to take copies of documents to prepare their assessments and reports. We may also ask you to provide copies of key audit documents before the inspection.

Following an inspection, you can comment on the draft findings and clarify any errors or misunderstandings before the report is finalised. We use the final report to decide whether further action is required.

Report findings also help us identify areas where you may require additional support and inform future policy decisions.

Audit team leaders must keep records related to an audit for 5 years from the date of the audit report. Records should be complete and include details about the audit and its findings.

If you’re leaving your employer, make sure you can still access records for 5 years from the date of the report. We suggest including this requirement in your employment contract.

Before you can agree to the terms of the engagement, you must give the person who appointed you to do the audit a signed declaration of independence and conduct. This must be signed by you and all the audit team members.

This declaration must state:

• if you or any team members have a conflict of interest or breach independence requirements under the Regulations
• if you will breach the auditor rotation requirements, and if so, whether an exemption has been granted
• you will comply with the Code of Conduct.

The audit team leader is personally appointed. Audit team leaders can't appoint another Category 2 registered greenhouse and energy auditor as an audit team leader.

For more information, see Part 2 of the Determination.

Audit team leaders must not be the audit team leader for more than 5 consecutive Part 6 audits of the same kind for one audited body.

After every set of 5 consecutive Part 6 audits, the audited body should engage a different audit team leader for at least the next 2 Part 6 audits.

We also recommend that auditors don't audit the entire life cycle of an ACCU project. We recommend participants engage at least 2 auditors from different audit firms. If they do, they’re less likely to be selected for additional audits.

If you've been the audit team leader for a Part 6 audit, you must wait at least 2 years before becoming a peer reviewer for the same type of Part 6 audit for that audited body. This is in line with the assurance standard ASQM 2 Engagement Quality Reviews.