NGER Health Check: Strengthening NGER Data Integrity and Reporting Confidence

Dr. Junbo Chen

Consultant

Thomas Hodgson

Director

Table of Contents

• Common Problems
• Set-and-forget mindset
• NGERs Metadata
• Operational control
• Health check to strengthen data

Share this article

• Share via Linkedin
• Share via Facebook
• Share via X
• Share via Email

The National Greenhouse and Energy Reporting (NGER) scheme is Australia’s mandatory framework for companies to report their greenhouse gas emissions, energy production and consumption. It plays a vital role in ensuring transparency, supporting national climate policy, and helping organisations understand and manage their emissions profile. We guide NGER reporters across a wide range of sectors with expert, tailored insights that support more accurate, efficient, and confident reporting. Drawing on over a decade of experience, we’ve developed a targeted NGER Health Check system designed to help organisations identify common reporting issues, improve data quality, reduce compliance risk, and build long-term reporting capability.

NGER reporting – common problems

In our experience, we’ve identified a few key problems that underlie most NGER misreporting.

Set-and-forget mindset

The worst culprit is the set-and-forget mindset. That is, reporters have taken a position early on that has not been reviewed in the intervening years. This leads to significant increases in administrative burden and non-compliant reporting.

An example of this is the reporting of E10 fuel. Initially, NGERs didn’t have a minimum threshold for reporting an instance of a source. That meant a reporter was required to report everything once they breached the corporate reporting threshold. An organisation that used 100lt of E10 fuel would reasonably report 10lt of ethanol use. And would diligently keep records and make associated entries.

Now, there are mechanisms to increase reporting efficiency. Minimum reporting thresholds (1,000lt per instance of a source) to avoid immaterial reporting and incidental reporting/reporting by percentages to drive efficiency for minor amounts can be used.

Organisations that don’t routinely test their reporting compliance however, miss these changes and continue labour-intensive, non-compliant reporting.

In our recent analysis of underground mine ventilation data, we found that overlooking humidity, particularly in high-moisture environments, can lead to overstated emissions by up to 3.5%, driven largely by methane dilution. With carbon prices rising and regulatory scrutiny increasing, small data assumptions like this can add up , costing organisations hundreds of thousands annually.

This highlights why continuous improvement in data quality and system transparency is essential not just for compliance but for building credible decarbonisation pathways. Sometimes, it’s not about changing the strategy; it’s about refining the inputs.

Further reading: Top NGERs Mistakes And 5 Ways To Avoid Them | Anthesis Australia

NGERs Metadata

In NGER reporting, it’s easy to focus on emission factors and activity data but metadata like the number of facilities aggregated under a Section 19 (s19) report plays a crucial role in ensuring accuracy and auditability. These details often fly under the radar, yet they influence how corporate emissions are interpreted and assessed by regulators.

To support this, we’ve developed a tool that helps automatically track and validate key s19 metadata across reporting groups, reducing the risk of misreporting and supporting full NGER compliance. It’s one more step in embedding rigour and transparency into every layer of emissions reporting.

Operational control – a key concept for NGER reporting

Operational control is a key concept for NGER reporting requirements, as it determines which corporation holds the reporting obligations for a facility’s emissions, energy consumption, and production. A corporation is considered to have operational control over a facility if it has the authority to introduce and implement operating policies, including health, safety and environmental policies.

Evaluating and assessing operational control is critical when there are changes in administrative circumstances, such as mergers, acquisitions, or divestments, since these events can affect which entity within a corporate group exercises control over the facility. If operational control changes during the financial year, reporting requirements apply only to the period in which the corporation held control.

Failing to re-evaluate operational control under these scenarios can result in compliance risks, inaccurate reporting and potentially regulatory breaches. A timely assessment of operational control strengthens the integrity of reporting obligations and supports effective compliance under the NGER framework.  

Strengthen your NGER data and reporting with a health check

Effective NGER reporting goes beyond emissions factors and spreadsheets — it requires continuous attention to detail, system integrity and evolving compliance requirements. From refining NGER data inputs to validating metadata and reassessing operational control, these practices underpin credible, auditable emissions data. Our Anthesis NGER Health Check is designed to surface issues early, strengthen reporting processes, and help you manage risks while uncovering opportunities for improvement and innovation.

Watch a short case study on how the NGER Health Check helped a large technology client.

Curious to learn more about our NGER Health Check?

Our team has deep expertise and a strong track record in delivering support to NGER reporting companies. We have supported many of Australia’s largest emitting organisations navigate complex reporting obligations, enhancing the accuracy and efficiency of their processes. Our close collaboration with the Clean Energy Regulator enables us to address challenging or uncertain reporting scenarios.

Call us for a chat on +61 3 7035 1740 to find out more, or reach out to our experts via email or the form below.