Business has an important role to play in reducing Australia’s carbon emissions. Interest in voluntary action is growing and can be seen through the increasing number of companies setting commitments to reduce emissions and increase the use of renewable electricity.
The Corporate Emissions Reduction Transparency (CERT) report is a voluntary initiative that will support National and Greenhouse and Energy Reporting (NGER) participants that meet the publication threshold to publicly report on their emissions reduction commitments and progress towards meeting them.
Stakeholders are increasingly seeking greater transparency and data around voluntary corporate emissions reduction and renewable electricity commitments. While many Australian companies voluntarily report their emissions data and target information, formats and detail vary, making comparisons difficult. Industry and the Clean Energy Regulator have been collaborating to develop a simple way of presenting a company’s net emissions position.
The initial design of the Corporate Emissions Reduction Transparency (CERT) report was established with draft guidelines and a simple report format that presented key emissions, renewable energy and carbon offset information and data for participating National Greenhouse and Energy Reporting (NGER) scheme companies.
The Clean Energy Regulator published a consultation paper seeking feedback on a possible design of the CERT report and its proposed guidelines. Consultation was open from 19 February to Friday 19 March 2021.
We received 55 submissions in response to our consultation paper. Most submissions stated that they valued an independently published report that presented the net emissions position of participating companies as well as progress against their voluntary commitments. Stakeholders also expressed support for the CERT report to:
Some submissions are confidential and have not been published. Submissions are not owned by the Clean Energy Regulator and we cannot guarantee that they meet accessibility requirements .
The Clean Energy Regulator published a consultation paper seeking feedback on the practical implementation of the Guidelines for the Corporate Emissions Reduction Transparency (CERT) report. Consultation was open from 18 October to 1 November 2021.
We received 34 submissions (10 of which were confidential). Most submissions supported CERT in principle and agreed that the proposed guidelines were a suitable basis for the pilot. Beyond the pilot, stakeholders were of the view that CERT should evolve to:
Many submissions sought further clarity around the operation of specific aspects of the guidelines. Stakeholders also suggested improvements to the proposed Company View, especially around the presentation of certificates and carbon units.
Stakeholders welcomed the public consultation and recent co-design process, and many noted the positive progress that has been made on CERT's design.
We have made minor updates to the guidelines and the Company View as outlined below. We will also consider key themes raised in submissions and undertake further work where required, during the pilot, the pilot evaluation or as part of CERT’s future design.
We have updated the CERT guidelines to provide further clarity on the operation or context of specific elements. The guidelines now more clearly allow progress to be presented in terms of tonnes CO2-e, as well as a percentage, where relevant to a participant’s commitment.
Supporting information, including a suite of examples, will be published to assist participants understand and use the CERT guidelines.
The agency has adjusted the Company View. This includes:
An updated version of the Company View is provided below. The Company View will continue to be refined during the pilot.
Please click on the image below to download a high resolution version.
During public consultation, stakeholders raised themes for the agency to consider as part of CERT’s evolution. Our proposed approach is set out below.
We will consider this issue in parallel with the pilot.
We will consider this for the future design of CERT, noting that further work is required to be able to verify data associated with emissions intensity commitments.
To avoid double counting, PPAs and contractual commitments for renewable electricity will not be accepted in CERT.
We will consider this issue during the evaluation of the pilot.
Participants can include international commitments in the ‘Other commitments - company assured’ section. At this stage, we do not intend to expand CERT to include verification of data associated with international emissions commitments or activities.
We are open to considering how international commitments may best be presented in the Company View as part of CERT’s future design.
Participants can include Scope 3 emissions commitments in the ‘Other commitments - company assured’ section and include notes or links regarding any independent verification undertaken.
We are open to exploring how independently audited information may best be presented in the Company View as part of CERT’s future design.
We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies.
We will consider further transparency on units in parallel with pilot for potential inclusion in future design of the CERT report.
We will consider whether further changes would aid comprehension in future design of the CERT report, noting that capital-intensive targets (step change) can already be described in commitment context statement.
We will provide guidance on any areas of divergence between CERT, Climate Active and the GHG Protocol.
We will undertake further work during the pilot to consider alternative groupings of subsidiaries. For example, we can consider adding further icons or other visual elements to the Company View to aid readability.
The Clean Energy Regulator published a consultation paper seeking feedback on the updated design for the 2023 CERT report.
Consultation was open from 5 September to 26 September 2022.
We received 15 submissions (2 of which are confidential). Stakeholders continued to support the CERT report, and appreciated the public consultation, co-design and engagement undertaken to date.
Most submissions were broadly supportive of the proposed updates to the CERT guidelines. As the CERT report evolves in future, stakeholders expressed support for:
Stakeholders continued to support the CERT report as a valuable information source, noting the positive progress that has been made on the design of the CERT report thus far.
We have updated the CERT guidelines to address issues identified during the pilot and implement the proposed changes set out in the consultation paper. We will continue to evolve the design of the CERT report as the Australian and International mandatory and voluntary climate disclosure regimes develop further.
Feedback from pilot participants, consultation submissions and other stakeholders has been incorporated into the guidelines for the 2023 CERT report. A summary of these changes is provided below.
Following public consultation 1, the Clean Energy Regulator undertook a co-design process with a cohort of NGER reporters.
The co-design process took into account feedback from public consultation and considered how the CERT report could contribute to corporate sustainability reporting by companies. The scope of the CERT report, alignment with how emissions commitments are framed, accounting frameworks and options for presenting data in CERT were worked on. A key priority was balancing the need for flexibility with the need for clarity and comparability.
As a result of the co-design process, updated guidelines and an improved report format were developed.
The CERT report pilot is now complete.
The 2022 report operated as a pilot to test and refine the guidelines, administration, and reporting arrangements. The guidelines will continue to evolve beyond the pilot.
Participation in the pilot was open to companies reporting more than 50 kilotonnes of emissions a year under the National Greenhouse and Energy Reporting (NGER) scheme.
23 companies participated in the pilot, presenting:
2022 CERT report was published on 7 July 2022.
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