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Public consultation 1
19/02/21 – 19/3/21
complete
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.
What we heard
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:
- Provide flexibility in how emissions reduction commitments were presented, including the ability to present multiple commitments.
- Align with other domestic and international sustainability reporting frameworks where practical.
- Allow context statements to be included to aid understanding.
- Cover both net scope 1 and net scope 2 emissions.
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 .
Public consultation 2
18/10/21 – 5pm 1/11/21
complete
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.
What we heard
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:
- Include the ability to verify data associated with Scope 3 emissions commitments, emissions intensity commitments, and international commitments and activities.
- Recognise large-scale generation certificate (LGC) surrenders as part of jurisdictional renewable energy targets in the calculation of progress towards renewable electricity commitments.
- Publish more detail about carbon units.
- Support participation by a broader group of companies beyond the companies that currently meet the National Greenhouse and Energy Reporting scheme publication threshold.
- Update state emissions factors for scope 2 emissions and expand eligible inputs to the calculation of the renewable electricity percentage.
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.
What we will do
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.
Updates to the guidelines
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.
Examples and explanatory information
Supporting information, including a suite of examples, will be published to assist participants understand and use the CERT guidelines.
Updates to the company view
The agency has adjusted the Company View. This includes:
- Visually separating LGCs from carbon offset units.
- Presenting progress in terms of tonne CO2-e alongside the percentage value.
- Highlighting scope 3 efforts by including an icon for relevant commitments.
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.
Design elements for future consideration
During public consultation, stakeholders raised themes for the agency to consider as part of CERT’s evolution. Our proposed approach is set out below.
| Suggestions from stakeholders | Our approach |
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Include LGC surrenders made under jurisdictional renewable energy targets. | We will consider this issue in parallel with the pilot. |
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Recognise emissions intensity and renewable generation commitments as ‘progress verified’ using agency data; recognise contractual agreements as evidence. | 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. |
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Broaden CERT eligibility to companies beyond NGER reporters above the publication threshold. | We will consider this issue during the evaluation of the pilot. |
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Recognise global commitments and associated emissions reduction activities. | 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. |
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Recognise Scope 3 emissions commitments as progress verified, particularly where a higher level of independent assurance has been undertaken by third parties (e.g SBTi commitments). | 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. |
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Recognise Climate Active certified products (electricity, fuels, etc.) and related units. | We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies. |
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Review the residual mix factor calculation methodology. | We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies. |
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Include other sources of emissions generated from activities that are not reportable as part the NGER scheme. | We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies. |
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Review Scope 2 accounting methodology, including emission factors. Recognise small-scale generation and other sources of electricity generation. | We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies. |
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Review renewable percentage calculation and recognise below baseline renewables and other types of electricity generation. | We will consider how best to address this as part of CERT’s future design, in consultation with relevant government agencies. |
Company view:
Publish more detail on carbon units attributes. | We will consider further transparency on units in parallel with pilot for potential inclusion in future design of the CERT report. |
Company view:
Consider an alternate way to present progress towards long-term, capital-intensive commitments that result in step-change emissions reductions | 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. |
Company view:
Clarify where CERT aligns or diverges from Climate Active and GHG Protocol. | We will provide guidance on any areas of divergence between CERT, Climate Active and the GHG Protocol. |
Company view:
Allow groupings of subsidiaries rather than just subsidiaries and parents. | 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. |
Public consultation 3
05/9/22 to 5pm 26/9/22
complete
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.
What we heard
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:
- Making the level of independent assurance clear and refining assurance requirements over time as auditing and assurance expertise and technology matures.
- Continuing to improve alignment with other reporting frameworks, including the Greenhouse Gas Protocol and the Australian Government’s Climate Active program.
- Improving clarity on the application of Residual Mix Factors and market-based scope 2 emissions accounting.
- Expanding eligible inputs to the calculation of net emissions and renewable electricity percentage.
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.
What we will do
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.
Key updates to the guidelines for the 2023 CERT report
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.
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Completing the picture of company’s climate related commitments: Companies will be required to report all eligible climate-related commitments in their CERT report – this includes commitments relating to their greenhouse gas emissions and/or energy use.
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Recognising independently assured commitments: The agency will represent independently assured commitments as a third commitment category. This will allow companies to show progress towards their commitments where this cannot be verified using agency-held data – including commitments relating to a company’s emissions intensity, scope 3 or international emissions.
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Addition of a jurisdictional power percentage: Recognising LGC surrenders on behalf of a jurisdiction (for example, the ACT Government’s Renewable Energy Target) will better reflect the renewable electricity consumption of companies located in jurisdictions with a renewable electricity target.
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Streamlining reporting requirements: An alternative methodology has been developed for calendar year and equity reporting, where participants may report independently assured data directly to the agency. This addresses issues raised by participants regarding the complexities of adjusting NGER data for equity share or calendar year reporting.
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Updating the Residual Mix Factor (RMF): The Australia Government’s Climate Active scheme is planning to update their calculation of the RMF – an important factor in market-based scope 2 emissions accounting. The proposed methodology will improve accuracy and reduce the potential for double counting by excluding voluntary large-scale and small-scale renewables that could be claimed under either the CERT report or Climate Active. The 2023 CERT report will adopt the new methodology when it comes into effect – planned for 2022 calendar year reporting.
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Revising base period emissions in response to structural changes: Where a company has undergone a significant structural change (such as a merger, acquisition, or divestment), the company should revise their base period emissions to allow meaningful comparison of the company’s progress over time.