NGERs Reporting: New Amendments and Tips for Success from Experts

23rd August 2023

ngers reporting - abstract factory
diana perea

Diana Perea

Principal Consultant


The National Greenhouse and Energy Reporting Scheme (NGERs) is Australia’s reporting framework for the largest emitters to disclose their carbon emissions. Despite the reporting complexity, you can evade many common errors by taking a few simple steps. As a follow up to our other NGERs reporting piece Top mistakes made under the National Greenhouse and Energy Reporting (NGER) Scheme and 5 ways to avoid them, our seasoned experts have curated some new tips for navigating NGERS reporting with success, and outlined the recent changes to the legislation for those getting into the data this NGERs reporting season.

NGERs Reporting Update – What are the new amendments to the NGERs legislation?

In June 2022 the government released amendments to the NGER legislation for FY2022-23 reporting period; these include:

  • Updated emission factors for calculating scope 2 emissions,
  • Updated provisions for reporting emissions from leakages in natural gas distribution networks, losses of hydrofluorocarbons (HFCs) and sulphur hexafluoride (SF6), and from decommissioned underground coal mines,
  • Integrating 3 new fuel types by adding biomethane, passenger car tyres and truck and off-road tyres into the NGER Measurement Determination.

For more detailed information on the amendments and NGER Measurement Determination for FY23 see the Clean Energy Regulator website.

NGERs Reporting Update – Tips for success and what to do now

1. NGERs legislation amendments

Make sure to review the amendments to the NGERs legislation as listed above in more detail on the Clean Energy Regulator’s (CER’s) website if you think they will apply to your organisation.

Understand how they may affect your operations and the potential impacts to your organisation’s NGERs report. If required, do a deep dive into the legislation to understand the consequences in full.

If you are struggling to understand the risks or opportunities these changes present, get in touch with our team.

Pro Tip: It’s also good to do an early review of the changes coming up next year to the Measurement Determination to understand if there are new data collection systems your organisation would need to implement ahead of FY24 reporting. This could include the optional reporting of scope 2 electricity emissions using a market-based approach supplementary to the required location-based approach.

2.  Reconfirm your NGERs reporting boundary

When collecting data ensure you have considered new sites, even if they are only included for a portion of the year. Clients are often aware of the new sites, but they miss the fact that they have not collected data for the new site.

Pro Tip: Make sure to capture your new sites in the Emissions and Energy R​eporting System (EERS) and remove sites that were not part of your organisation for the reporting period.

3. Engage your data holders early on

Ensure your data holders are aware of the accuracy and completeness requirements of the NGER scheme. Changes in team members from year to year and, as we have mentioned, new amendments such as the latest NGER Determination update can mean increased time required to gather the necessary data and produce a compliant NGERs report.

Pro Tip: Review your measurement criterion for each data source and make sure any changes in the data collection process are captured with updated measurement criteria if needed. The Regulator’s Methods and measurement criteria guideline is a helpful and useful tool to employ here.

4. Review your metadata such as addresses and ANZSIC codes

A simple and sometimes overlooked issue is to verify that your site addresses are correct. 

As part of your NGERs submission you agree that your address and coordinates are correct. If they are not correct or have been updated and this is not reflected in your report, you are submitting non-compliant data.

Pro Tip: We suggest validating internally all of the addresses, ANZIC codes and geo locations for your sites. The Regulator has recently updated the system to link coordinates based on your address, so double check your data.

Additionally, remember to review how some reporting regulations also depend on ANZIC codes, such as facility aggregates and refrigerant reporting.

5. Sensor check your NGERs data

Reporters can get caught out by failing to pick up changes in data that should be clear red flags.

Review how your energy and emissions have changed since last year and if the data doesn’t seem to be accurate, for example if your emissions on a decommissioning site should be going down and they are actually increasing, this is a red flag to sense check your NGERs data to ensure it is correct.

Pro Tip: Ways you could do this:

  1. Review year-on-year trends, and compare emissions and energy production and consumption against facility outputs
  2. Don’t forget to review Matters To Be Identified (MTBIs) – key metrics to report and part of your reporting obligations. As EERS is updated every year, the system sometimes changes the place where these MTBIs are reported in the platform. Make sure you don’t forget to add them and refer back to the NGER Measurement Determination to ensure you’ve included all your MTBIs
  3. Take note of operational changes which may have had an impact on your emissions or energy over the FY23 reporting period

6. Understand greenwashing is evolving as a government compliance priority

As NGERs is a compliance scheme the data must be accurate and transparent. The Australian government has stated it is taking steps to address greenwashing in relation to NGERs reporting, using the data that is collected and submitted for NGERs to verify reporters’ carbon emissions claims. The CER works closely with other regulators, such as the Australian Competition and Consumer Commission (ACCC) and the Australian Securities and Investments Commission (ASIC) and provides data and information in support of their potential regulatory action.

Your facility’s NGER data is also used to determine if you are liable under the Safeguard Mechanism. Currently, facilities with scope 1 emissions over 100 ktCO2e are considered Safeguard facilities. Having confidence in the accuracy of your data is key to understanding how your liability may change moving forward.

For more information visit the Regulator’s website.

Note: The accuracy of NGER data underpins Australia’s emissions and energy policy and establishes Australia’s position against the government’s emissions reduction targets and global Nationally Determined Contributions (NDCs) as per the Paris Agreement. Having accurate data is also valuable for the government to monitor and determine if changes to the legislation are required to achieve the national targets.

Pro Tip: Ensure transparent, accurate emissions reporting with verified data, clear communication, consistent standards adherence, and independent third-party validation to prevent the possibility of greenwashing practices.

Re-reviewing your NGERS reporting obligations

With the recent NGERs reporting update it’s essential that reporting entities understand any changes to their NGERs reporting obligations to ensure continued compliance.

The tips our NGERs experts have outlined will also assist in picking up small but often overlooked things that will improve your data and reporting and help you avoid common NGERs reporting and compliance mistakes.  

Need assistance with the NGERs Reporting Update or your NGERs obligations?  

If any of these issues raise a red flag with you, get in contact with the Regulator early because this is their busiest time of the year. Long communication times might jeopardise your ability to meet the reporting deadline of October 31st.

The Regulator also has a handy FAQs sheet on their website, but if you need specialist advice experts we are here to help. Learn more about our wider Clean Energy Regulator compliance services for the Safeguard Mechanism and NGERs here.