NGER Reporting

The National Greenhouse and Energy Reporting (NGER) Scheme is Australia’s mandatory framework for reporting greenhouse gas emissions, energy production and energy consumption to the Clean Energy Regulator. Emission Statement prepares those reports from start to finish, to a documented standard that stands up to scrutiny.

What we do

We act as your preparer. We collect the activity data, apply the methods and factors set out in the Measurement Determination, build the submission, and lodge it through the Emissions and Energy Reporting System on your behalf. The reporting obligation remains with your organisation; the work of meeting it is ours.

A typical annual engagement covers:

• Threshold assessment and registration, where you are approaching or newly over the line
• Corporate group and operational control boundary — which entities and facilities are in the report, and on what basis
• Facility identification, including aggregated small facilities
• Data collection across the full energy mix: grid electricity, reticulated gas, LPG, diesel and petrol in stationary equipment, fleet fuel, heating oil, and refrigerants
• Calculation under the National Greenhouse and Energy Reporting (Measurement) Determination 2008, with the method and factor recorded against every activity
• Preparation and lodgement of the section 19 report
• A basis of preparation document explaining how each figure was arrived at
• Support if the Regulator raises questions, or if your report is selected for external audit

Prepared to a documented standard

Every report we prepare is built so that it holds up when someone else checks it — the difference between a number in a portal and a number that withstands review.

We are preparers, not assurers. We prepare your report to a documented standard a reviewer can pick up and work with, and we do not review or validate reports we have prepared ourselves. Keeping that boundary clear is part of what makes the work credible.

In practice that means:

• Traceable data. Every figure ties back to a source — a retailer or network extract, a metering data request, a supplier record, or a bill.
• Tagged data quality. Each data point is marked as measured, provided or estimated, with the overall mix visible to you rather than held in a working file.
• Method traceability. The NGER method applied to each activity — Method 1, Method A1 and so on — and the energy content and emission factors used, recorded line by line.
• A flagged-items register. The matters an assurer is likely to query — estimates, boundary decisions, refrigerant assumptions, use of percentage reporting — identified up front rather than discovered later.
• A clear boundary statement. Prepared to a documented standard. Not an engagement under ASSA 5000. Not assured.

How we collect the data

Most of the difficulty in NGER reporting sits in data collection rather than calculation. Bills are held by the people who pay them, sites change hands, and information gathered by email over several months tends to arrive in inconsistent formats with little supporting evidence.

We use a structured, source-tagged collection process built around meter identifiers. Sites — or clusters of sites, such as a region, a network or a business unit — supply their electricity NMIs and gas MIRNs once. With your written authority, we then request consumption data through the relevant network’s metering data provision process, rather than asking site staff to locate twelve months of past invoices. Fuels without a meter identifier — LPG, diesel, petrol, heating oil — are captured against supplier statements and fleet records.

The result is a dataset that carries its own evidence, and a report that can be rebuilt from source at any point.

The small-facility question

Organisations with a long tail of small sites commonly rely on the aggregated facility percentage estimate permitted under the NGER Regulations. It is legitimate, it is compliant, and for many reporters it remains the right approach.

Its limitation is granularity. A single extrapolated percentage across hundreds of sites does not tell you which of them are the heavy consumers, where capital is best directed, or how close the estimate is to actual consumption. As climate disclosure expectations sharpen, an estimate that was adequate for a compliance return may look thin in an annual report.

Where it matters, we can replace the estimate with measured site-level data, introduced progressively and starting with the sites most likely to move the number.

Who has to report

Registration and reporting under the National Greenhouse and Energy Reporting Act 2007 is triggered when a corporation meets or exceeds:

• Facility threshold — 25 kilotonnes CO₂-e of emissions, or 100 terajoules of energy produced or consumed, at any single facility
• Corporate group threshold — 50 kilotonnes CO₂-e of emissions, or 200 terajoules of energy produced or consumed, across the group

Once the group threshold is crossed, every facility under the group’s operational control must be accounted for — including small sites that would never have triggered reporting on their own.

Reports are due by 31 October for the financial year just ended, or the next business day where 31 October falls on a weekend or ACT public holiday. Reports for the 2025–26 year are due by 2 November 2026.

NGER and mandatory climate disclosure

NGER registration now carries a second consequence. Entities required to report under the NGER Act are captured by Australia’s mandatory climate-related financial disclosure regime and must prepare a sustainability report under AASB S2 — for most NGER reporters, from annual periods beginning on or after 1 July 2026.

This is a financial reporting obligation rather than an environmental one. It sits under the Corporations Act, forms part of the annual report, carries a directors’ declaration, and is subject to a phased assurance mandate. Jurisdictional relief allows NGER measurement methods to carry across for Scope 1 and Scope 2 in the early years, which means an NGER dataset prepared to an assurance-ready standard is already much of what a first-year discloser needs to produce.

More detail on what is required and when is on our mandatory climate disclosure page.

Reviewing a report prepared by others

Where a report has been prepared in-house or by another consultant, we can review it before lodgement: methods and factors, boundary and operational control, use of percentage estimates, data provenance, and the items an assurer or the Regulator is most likely to query.

This is an independent review rather than an assurance engagement under ASSA 5000, and we offer it only on reports we have not prepared ourselves.

Why Emission Statement

• Since 2006. We were preparing greenhouse and energy reports before the NGER scheme existed, and have prepared NGER submissions since its early reporting years.
• Continuity. For long-standing clients we hold the meter-level history and prior-year working papers, so each year begins from a known base rather than a blank page.
• Dispersed portfolios. Hundreds of small sites across a state, managed locally by staff and volunteers, is a data problem we have spent years solving.
• A clear role. We prepare, we say so, and we build the report so that a reviewer’s work is straightforward.
• Direct engagement. You work with the person preparing your report.

Talk to us

Whether you are reporting for the twelfth year or working out whether you have crossed the threshold for the first time, a short conversation is usually enough to establish what is involved.

Get in touch