NGER reporting and the Safeguard Mechanism are related but distinct obligations that often capture the same facilities.

NGER is a measurement and transparency framework. It requires eligible facilities to measure, verify, and report their greenhouse gas emissions and energy data to the Clean Energy Regulator annually. It does not impose emissions limits – it creates the data infrastructure for accountability.

The Safeguard Mechanism is a performance and compliance framework. It applies to Australia’s largest industrial emitters – those with facilities releasing more than 100,000 tCO₂-e per year – and sets a declining annual baseline emissions limit for each covered facility. From July 2023, those baselines decrease each year, requiring facilities to reduce emissions or purchase Australian Carbon Credit Units (ACCUs) or Safeguard Mechanism Credits (SMCs) to cover any excess.

In short: NGER tells you what you emit. The Safeguard Mechanism tells you how much you’re allowed to emit and what happens when you exceed it.

We help clients understand both obligations, build robust NGER data systems, and develop strategies to stay within Safeguard baselines.

Australia’s new mandatory climate reporting regime – the Australian Sustainability Reporting Standards (ASRS), implemented through AASB S2 – requires eligible businesses to disclose climate-related risks, opportunities, and greenhouse gas emissions with the same rigour as financial statements.

The regime is phased across three groups: Group 1 (500+ employees or $1B+ revenue or assets) reports from FY2025; Group 2 (250+ employees or $500M+ revenue or assets) from FY2026; and Group 3 (smaller listed entities) from FY2027.

Disclosures must cover four areas: governance (how your board oversees climate risk), strategy (how climate risks and opportunities affect your business), risk management (how you identify and manage climate risk), and metrics and targets (your Scope 1, 2, and 3 emissions and any net zero or reduction targets).

For Australian companies in mining, resources, agriculture, logistics, and manufacturing, the ASRS obligations are particularly significant because emissions profiles tend to be large and complex.

[SSE NOTE] We help organisations assess their ASRS obligations, build the data infrastructure needed for compliant disclosure, and prepare audit-ready reports on time and at lower cost than traditional consulting approaches.

The Safeguard Mechanism is an Australian Government policy that sets facility-level emissions baselines for the country’s largest industrial emitters and requires them to keep net emissions at or below those baselines.

It was reformed significantly in July 2023, introducing declining baselines that require covered facilities to reduce emissions by approximately 4.9% per year on average through to 2030, in line with Australia’s national emissions targets.

The Safeguard Mechanism applies to any facility reporting 100,000 tonnes of CO₂-e or more in direct (Scope 1) emissions under NGER in a given year. Covered sectors include mining and resources, oil and gas, manufacturing, waste, and other heavy industry.

Facilities that exceed their baseline must surrender ACCUs or SMCs. Facilities that manage their emissions well and come in below baseline can generate SMCs – tradeable credits that can be sold to other covered facilities, creating a genuine financial incentive to decarbonise ahead of the curve.

We help Safeguard-covered facilities understand their baseline trajectory, develop compliance strategies, and evaluate carbon offset options where reduction alone is insufficient.

Climate scenario analysis is a structured process by which organisations assess how different possible future climate outcomes would affect their business model, financial position, and strategy. It asks: if the world limits warming to 1.5°C (requiring rapid decarbonisation and significant policy intervention), how does that affect our operations and assets? If warming reaches 3–4°C (with limited policy action but severe physical climate impacts), what risks does that create for our facilities and supply chains?

Yes – climate scenario analysis is required under AASB S2. It is one of the most technically demanding elements of the standard. Entities must disclose how they have used scenario analysis to assess the resilience of their strategy under different climate pathways, including at least one scenario consistent with limiting warming to 1.5°C and one higher-warming scenario.

Transition relief in early reporting years allows less quantitative approaches initially, with expectations for increasing sophistication over subsequent years.

[SSE NOTE] We conduct AASB S2-aligned climate scenario analysis for clients in mining, resources, and industry – identifying physical and transition risks and opportunities material to each business and quantifying their potential financial impacts in a form suitable for board reporting and external disclosure.

The Greenhouse Gas Protocol (GHG Protocol) is the world’s most widely used accounting standard for measuring and managing greenhouse gas emissions. Originally developed in 1998 by the World Resources Institute and the World Business Council for Sustainable Development, it establishes the definitions, boundaries, and methodologies for calculating Scope 1, 2, and 3 emissions used in virtually every major corporate climate framework globally.

For Australian businesses, the GHG Protocol matters because it is the foundational methodology underpinning AASB S2, NGER, the Science Based Targets initiative, CDP, GRI, and TCFD. Any emissions inventory that doesn’t follow GHG Protocol methodology will not be accepted by auditors, investors, or regulators as credible.

In Australia, GHG Protocol methodologies are supplemented by the National Greenhouse Accounts (NGA) emission factors published annually by the Department of Climate Change, Energy, the Environment and Water – providing country-specific, state-specific, and fuel-specific factors required for Australian reporting.

We apply GHG Protocol and NGA-compliant methodologies in all greenhouse gas assessments and NGER/ASRS reporting we deliver for clients.

Calculating greenhouse gas emissions for a mining services or logistics company follows the GHG Protocol’s Corporate Accounting and Reporting Standard and, for Australian mandatory reporting, the methodologies prescribed under NGER. The emissions profile of a services provider differs meaningfully from that of a mining operator – the focus shifts from fixed plant and extraction processes toward mobile fleets, contracted equipment, and the emissions embedded across a dispersed service delivery model.

Scope 1 emissions – direct emissions from owned or controlled sources – for mining services and logistics companies typically include diesel combustion in light and heavy vehicle fleets, mobile plant and equipment operated on client sites, and fuel used in workshops, depots, or maintenance facilities. These are calculated by multiplying fuel consumption data (litres of diesel or petrol) by the relevant National Greenhouse Accounts (NGA) emission factors published by the Australian Government.

Scope 2 emissions cover purchased electricity consumed at owned or leased facilities – including depots, workshops, offices, and camp accommodation – calculated using location-based grid emission factors for each state and territory.

Scope 3 emissions are often the most material and complex category for services providers. Key categories include fuel extraction and processing upstream of Scope 1 combustion, purchased goods and services (tyres, parts, subcontracted labour), employee commuting and business travel, and waste generated at operational facilities. For companies subject to ASRS, identifying and disclosing the most material Scope 3 categories is required – and for a fleet-intensive business, upstream fuel emissions alone can represent a significant portion of the total footprint.

[SSE NOTE] We build measurement frameworks tailored to the operational structures of mining services and logistics businesses – automating data collection from fleet management systems and fuel records, applying current NGA emission factors, and producing auditable workbooks aligned with both NGER methodology and AASB S2 requirements.

Electrification – replacing diesel and gas-powered equipment with electric alternatives powered by renewable energy – is the most significant lever available to mining companies seeking to reduce Scope 1 emissions. Mining operations are typically diesel-intensive: haul trucks, loaders, drills, and processing plant can account for 70–90% of a mine site’s total direct emissions.

Transitioning these to battery-electric or trolley-assist equivalents eliminates combustion emissions at source. The benefit is compounded when electricity is sourced from renewables – whether through on-site solar or wind generation, grid renewable energy procurement, or power purchase agreements (PPAs).

Beyond emissions reduction, electrification delivers operational benefits including:

Lower energy costs – electricity is typically significantly cheaper than diesel on an energy-equivalent basis.
Reduced ventilation requirements in underground operations.
Lower maintenance costs on simpler electric drivetrains.
Reduced heat and noise in enclosed environments.

We help mining clients evaluate electrification feasibility – assessing which equipment classes are ready for conversion, capital and operating cost implications, viable renewable energy supply options, and how to sequence a transition that minimises disruption while maximising cost and emissions savings.

A Science Based Target is an emissions reduction target validated by the Science Based Targets initiative (SBTi) as being consistent with limiting global temperature rise to 1.5°C above pre-industrial levels, in line with the Paris Agreement. SBTi-validated targets are the global standard for credible corporate climate commitments, recognised by investors, customers, and regulators as demonstrating genuine, science-grounded ambition.

To set an SBTi-aligned target, a company must first complete a baseline emissions inventory covering Scope 1, 2, and material Scope 3 emissions. It then selects a target pathway consistent with SBTi’s framework for its sector – different methodologies apply to different industries. Near-term targets (to 2030) must demonstrate at least a 4.2% absolute reduction per year for a 1.5°C pathway.

Once submitted, SBTi validates the targets against its framework and, if approved, lists the company publicly – providing significant reputational and commercial benefits in supplier and investor relationships.

We guide clients through baseline development, target-setting methodology, SBTi submission, and the implementation planning needed to achieve validated targets.

Carbon offsets are tradeable units representing the avoidance or removal of one tonne of CO₂-equivalent greenhouse gas emissions. They allow organisations to compensate for emissions that cannot yet be eliminated by investing in projects that reduce or remove emissions elsewhere – such as reforestation, avoided land clearing, landfill gas capture, or industrial efficiency projects.

In Australia, the primary offset mechanism is the Australian Carbon Credit Unit (ACCU), issued by the Clean Energy Regulator under the Emissions Reduction Fund. ACCUs are generated by registered Australian projects and can be purchased voluntarily or used for Safeguard Mechanism compliance.

The key principles for credible offset use are: prioritise genuine emissions reduction first; use offsets only for residual, hard-to-abate emissions; select high-quality, permanent offsets with robust co-benefits; and disclose offset use transparently in sustainability reporting. Using offsets as a substitute for genuine reduction is increasingly scrutinised by ASIC under greenwashing provisions.

We advise clients on offset strategy – which project types align with their values, what constitutes a credible offset claim under AASB S2, and how to source and retire ACCUs cost-effectively.