The 2025–26 reporting year closed on 30 June. Reports are due by 2 November. That is enough time to do the job properly — if the work starts now rather than in late October.
By Emission StatementNGER Reporting4 min read
EERS is open for the 2025–26 reporting year. Because 31 October falls on a Saturday, section 19 reports are due by 2 November 2026, and there is no provision for extensions under the NGER legislation.
In most organisations, that deadline is met in the final fortnight. Data is gathered quickly, the totals are checked against the prior year, and the report is lodged. It arrives on time and it balances — and the questions that were never quite resolved get carried forward to next year, again.
It does not have to run that way. There are still around eleven weeks, and eleven weeks is comfortably enough to collect the data properly, resolve the anomalies, and lodge a report you can stand behind.
What “right” actually means
Lodging on time is the easy part. A report that is genuinely right is one where every figure can be traced back to where it came from — a meter reading, a retailer extract, a supplier record, a bill — and where the estimates are identified as estimates rather than sitting quietly among the measured data.
That distinction rarely shows up in a total. Totals reconcile perfectly well with a missing site inside them, a zero that was never confirmed, or a meter that dropped out of the retailer extract two years ago. The only way to know is to look underneath.
The question being asked of emissions data is shifting from “is this the right number?” to “show me how you know”.
The things worth checking now
A short review of this year’s data against last year’s will usually surface most of what matters. In particular:
- Sites that appeared or disappeared since last year, and whether that reflects a real change in the portfolio.
- Zeros. A nil figure should be supported by a closure, a disconnection or a nil bill — otherwise it may simply be a failed data pull.
- Consumption without a meter identifier. A number with no NMI or MIRN behind it cannot be re-derived, however accurate it is.
- Embedded network sites, which routinely fall out of standard retailer extracts and need to be sourced through the network operator instead.
- Estimates. Percentage reporting for small facilities is entirely legitimate, but it is worth knowing how much of the report rests on it.
- Method changes for 2025–26, particularly the requirement that a market-based approach to scope 2, once elected, be applied consistently across every facility in the group.
An anomaly found in August is a data request. The same anomaly found in the last week of October is something you have to lodge and explain later.
One date before the deadline
If your corporate group crossed a threshold for the first time in 2025–26, the application to register under section 12 of the NGER Act is due by 31 August — not 2 November. That one is worth confirming this week.
Why it matters more this year
Mandatory climate disclosure has changed who reads this data. Group 2 reporting periods commenced on 1 July 2026, and registered NGER reporters are captured regardless of their size. Scope 1 and scope 2 emissions attract external assurance from the first reporting period, and they sit outside the transitional liability relief that applies to other parts of the disclosure.
In practical terms, the NGER dataset stops being something submitted to a regulator and becomes something handed to an assurer alongside the financial statements. The report lodged this November is the year immediately before that, which makes it the comparative.
Support, if you would like it
We prepare NGER reports for organisations across aged care, education, community services and property, and every report we prepare is built to be handed to a third-party assurer: each figure traced to a named source, estimates identified as estimates, methods and factors recorded, and any item an assurer would question raised early rather than discovered late.
To be clear about where we sit: we prepare reports, we do not assure them. Preparing to an assurance-ready standard is simply how we work, not an extra.
If you have inherited the reporting function, if last year’s file came from someone who has since moved on, or if you would simply like a second set of eyes before lodging, there is still time. There will not be in October.
Talk it through
A short conversation is usually enough to tell whether this year is a straightforward submission or one with questions to resolve first. We are happy to review where things stand, with no obligation either way.Get in touch →
Emission Statement has been providing sustainability services to Australian and New Zealand organisations since 2006. Our core services are NGER reporting, carbon audit, scope 3 and supply chain analysis, mandatory climate disclosure preparation, CDP and voluntary disclosure support, Climate Active and offset arrangement, sustainable events, and sustainability education.
Helping clients “Make a Positive Statement Towards the Environment” since 2006.
