Barry Li | Climate Reporting & Assurance

Insights on climate reporting, carbon markets, and sustainability assurance.

  • As we navigate through the first quarter of 2026, a significant shift in the corporate landscape has become undeniable: the era of “ESG” as a catch-all marketing slogan is effectively over. However, this isn’t a retreat from environmental or social responsibility. Instead, we are witnessing a transition toward a more mature, fragmented, and pragmatic discipline. According to recent insights from Morrison Foerster, 2026 is becoming the year where “sloganeering” is replaced by disciplined risk management and integrated financial reporting.

    Deep Dive: Fragmentation and the Rise of E-Ledgers

    The most striking trend this year is the widening “Tale of Two Worlds.” In the United States, federal policy and investor pressure have led to a significant scaling back of ESG branding in public filings. Conversely, more than 30 jurisdictions—particularly across Asia and Europe—are accelerating mandatory disclosure regimes. This divergence creates a complex compliance friction for multinationals, who must now navigate a landscape where being “too green” in one market is as risky as being “not green enough” in another.

    Amidst this fragmentation, a technical revolution is quietly taking hold: balance-sheet-based carbon accounting and “e-ledger” frameworks. Led primarily by traditional energy companies, these e-ledgers move beyond the often-criticized estimates of the GHG Protocol. As highlighted by S&P Global, these frameworks treat carbon as a financial liability, providing a level of precision that complements Scopes 1, 2, and 3 reporting. This shift allows corporations to tie sustainability initiatives directly to shareholder value, moving the conversation from “values” to “valuation.”

    Practical Takeaway

    For board directors and executives, the takeaway for 2026 is clear: Pragmatism wins.

    1. Rebrand for Substance: Shift internal and external communication away from “ESG” toward industry-specific solutions (e.g., “Energy Transition” or “Resilient Supply Chains”).
    2. Audit for Litigation: With the rise of anti-competition legal frameworks and heightened scrutiny on DEI and climate statements, ensure every sustainability claim is defensible under traditional misrepresentation frameworks.
    3. Invest in Data: Transition toward automated carbon accounting. The “e-ledger” approach isn’t just a trend; it’s the future of how sustainable finance products will be priced and de-risked.

    Sources

  • As 2026 unfolds, climate reporting and carbon markets are no longer parallel conversations?they are becoming one assurance problem. Preparers are dealing with targeted implementation changes in disclosure standards, while market participants are demanding stronger proof that carbon credits represent real and durable climate outcomes. For scholar-practitioners, the key shift is this: the market is moving from ?reporting more? to ?reporting with defensible evidence.?

    Deep Dive

    1) IFRS S2 implementation is being recalibrated for practical use, not reduced ambition

    The ISSB?s targeted amendments to IFRS S2 show a pragmatic implementation stance: preserve investor-useful information, but reduce operational friction where application has proven difficult. According to the ISSB announcement, the amendments clarify Scope 3 Category 15 treatment (financed emissions), permit alternative classification systems beyond GICS, and introduce specific jurisdictional reliefs (including for GHG measurement methods and GWP values).

    This matters for practice because implementation quality is now tied to governance design: entities need traceable methodologies that can withstand both assurance procedures and regulator scrutiny, especially when reliefs are used. The IFRS Foundation?s project page confirms the amendment package and timeline for effective application in implementation planning here.

    2) Assurance capacity is catching up with reporting complexity

    A standard is only as strong as its auditability. The IAASB?s supplementary illustrative reports for ISSA 5000 provide concrete templates for real engagement conditions, including mixed assurance levels and modified conclusions. As outlined by the IAASB guidance page, these examples move ISSA 5000 from baseline requirements to applied assurance judgement.

    From a practitioner lens, this is a critical maturation step: assurance teams can now anchor report design, evidence requests, and engagement scoping to publicly visible examples. In other words, the conversation is shifting from ?Can we disclose this?? to ?Can we support this conclusion under assurance??

    3) Carbon-market integrity infrastructure is becoming more granular and label-driven

    In voluntary carbon markets, integrity is increasingly operationalised through methodology-level screening and labeling. The Integrity Council?s announcement of first CCP-labelled credits shows how the ?two-tick? logic (program eligibility + methodology approval) is being used to segment quality in tradable supply (ICVCM announcement).

    At the registry level, Verra?s updated CCP label guidance translates that architecture into issuer workflows?when labels are automatic, when proponents must submit additional evidence, and how requantification pathways can be used to align previously issued units with CCP-eligible methods (Verra guidance).

    The practitioner implication: credit quality is no longer an abstract ?high integrity? claim; it is becoming an evidentiary chain that can be tested.

    4) Australia?s compliance market continues to reward operational discipline

    Australia?s Safeguard Mechanism remains a live laboratory for integration between emissions measurement, compliance actions, and unit use. The Clean Energy Regulator?s scheme page reports current scale indicators?including covered emissions and surrendered ACCUs/SMCs?which reinforce that compliance demand and reporting discipline are now deeply connected (CER Safeguard Mechanism).

    For reporting entities, this creates a practical bridge: internal emissions controls are no longer just for disclosure?they directly influence compliance cost, unit strategy, and assurance risk.

    Practical Takeaway

    1. Design for assurance at source, not at year-end.
      Build data lineage and control narratives when metrics are produced, especially for Scope 3 and financed emissions.
    2. Use IFRS S2 reliefs carefully and explicitly.
      Reliefs reduce burden but increase the need for transparent methodological disclosure and governance documentation.
    3. Treat carbon credits as evidence-bearing instruments.
      Move procurement and retirement decisions toward credits with clear methodology status and labeling pathways.
    4. Integrate compliance and reporting teams.
      In the Australian context, Safeguard, NGER-aligned measurement practice, and sustainability reporting should operate on a single control architecture.
    5. Reframe capability building.
      The new competitive advantage is not ?having climate data?; it is producing climate information that remains decision-useful after assurance challenge.

    Sources

  • A striking divergence is emerging in the global corporate landscape. According to The Conference Board’s 2026 C-Suite Outlook survey, 38% of US CEOs now say sustainability-focused investments are not a priority this year – nearly double the 20% global average. This marks a dramatic shift from 2025, when 39.3% of global executives named sustainability as the external ESG factor most affecting their business.

    What’s driving this recalibration? And more importantly, what does it mean for practitioners navigating climate reporting and sustainability assurance?

    Deep Dive: Understanding the Shift

    The Numbers Tell a Story

    The Conference Board surveyed over 1,700 executives, including 750+ CEOs across North America, Europe, and Asia. The findings reveal a polarized executive landscape:

    • US CEOs are twice as likely to de-prioritize sustainability compared to global peers
    • Top sustainability priorities for those still engaged: circular economy/waste reduction (17.4%) and sustainable use of key inputs like water and energy (16%)
    • Social priorities (working conditions, gender equality, human rights) ranked relatively low globally
    • AI emerged as the #1 concern (30.3%), while climate events ranked third among goods/services sector leaders

    What’s Behind the US Pullback?

    Andrew Jones, Principal Researcher at The Conference Board, attributes this to three factors:

    1. Regulatory uncertainty – The shifting federal policy landscape has created compliance confusion
    2. Political and legal scrutiny of ESG – Anti-ESG legislation and shareholder activism are forcing defensive postures
    3. Slower energy transition momentum – Infrastructure and investment challenges are tempering ambitions

    The European Contrast

    While US executives retreat, European counterparts are embedding sustainability into core business operations. This isn’t just rhetorical – the CSRD mandates and EU Taxonomy requirements are making sustainability reporting a baseline operational requirement, not a discretionary initiative.

    Practical Takeaway

    For assurance providers and sustainability practitioners, this divergence signals several strategic imperatives:

    1. Reframe the Value Proposition

    Jones notes CEOs are “prioritizing initiatives that directly improve cost efficiency, operational resilience, and supply chain stability, rather than broad or reputational ESG commitments.”

    Translation for practitioners: Connect every sustainability metric to operational value. Scope 1 & 2 emissions reduction? Frame it as energy cost management. Supply chain due diligence? Position it as risk mitigation.

    2. Anticipate Regulatory Convergence

    The UK FCA’s current consultation (closing March 20, 2026) proposes mandatory climate disclosures mirroring TCFD scope, with implementation targeted for January 2027. Whether US executives like it or not, global reporting standards are converging. Companies with international exposure will need assurance-ready data regardless of domestic political winds.

    3. Watch the Carbon Market Bridge

    As voluntary and compliance carbon markets converge (Japan’s GX-ETS launches in 2026), institutional-grade carbon accounting becomes essential. This creates natural demand for third-party assurance even among reluctant US firms with global trading partners.

    4. Quality Over Quantity

    The era of sprawling ESG reports may be ending. Focus assurance engagements on material metrics with clear audit trails. CEOs want targeted initiatives with demonstrable ROI – give them assurable data that supports that narrative.

    The Bigger Picture

    Environmental sustainability hasn’t disappeared from CEO agendas – it has become “more selective and economically grounded.” This isn’t necessarily bad news for the profession. Selective, economically-grounded sustainability claims demand rigorous assurance.

    The question for 2026 isn’t whether sustainability matters, but which sustainability metrics will survive executive scrutiny – and whether your assurance practice is positioned to validate them.


    Sources

  • As we move through February 2026, Australia’s climate reporting landscape is shifting from preparation to implementation. Group 1 entities are now deep into their first mandatory reporting cycle, while Group 2 entities face a countdown to 1 July 2026. Meanwhile, two significant developments demand attention: the AASB’s December 2025 amendments that simplify emissions reporting, and the upcoming Safeguard Mechanism review that will test Australia’s industrial decarbonisation credibility.

    This post captures the key developments emerging in early 2026, focusing on assurance readiness, recent standard amendments, and the policy signals that practitioners and preparers should be tracking.

    The Deep Dive: Key Developments

    1. AASB S2025-1: Amendments That Simplify GHG Reporting

    Source: AASB S2025-1 Amendments to Greenhouse Gas Emissions Disclosures (December 2025)

    In December 2025, the AASB issued significant amendments to AASB S2 Climate-related Disclosures. Rather than adding complexity, these changes provide targeted relief for Australian organisations navigating their first mandatory reports.

    Key Amendments:

    • Scope 3 Category 15 (Financed Emissions): Organisations can now limit disclosure to financed emissions only, removing the need to include emissions from underwriting and investment banking activities. This is particularly relevant for insurance companies and commercial banks.
    • Industry Classification Flexibility: Entities are no longer required to use the Global Industry Classification Standard (GICS). Any classification system that best explains climate-related transition risks is now acceptable.
    • Jurisdictional Relief for NGER: Australian organisations can use NGER methods for Scope 1 and 2 emissions without conflicting with global standards.
    • Global Warming Potential (GWP) Relief: Organisations reporting under NGER can continue using Australian National Greenhouse Account Factors, even where based on older GWP figures.

    Practitioner Note: Amendments #3 and #4 confirm that compliance with NGER requirements satisfies AASB S2 without complex recalculations—a significant practical relief.

    2. Assurance Readiness: What Auditors Will Look For

    Source: BDO – Ensuring Your Mandatory Sustainability Report is Assurance-Ready (February 2026)

    The first year of mandatory reporting is a transition period. While full sustainability reports must be prepared, only selected parts will be subject to limited assurance in Year One. This phased approach provides time to develop systems and documentation before moving to full limited assurance in Years Two and Three.

    Auditor Focus Areas:

    • Governance: Board and management roles clearly defined; active committees dealing with climate matters; supporting documentation in place
    • Climate Risks & Opportunities: Clear identification and assessment process; evidence that assessments inform disclosures across all pillars
    • GHG Emissions (Scope 1 & 2): Documented boundary policy; comprehensive Basis of Preparation; activity data reconciled to general ledger

    Critical Insight: ASIC’s position is clear—if an activity, assessment or process is not documented, auditors should treat it as incomplete. The mantra: “Not documented, not done.”

    3. Safeguard Mechanism 2026: Australia’s Credibility Test

    Source: Energy Insights – Safeguard Mechanism 2026: Australia’s credibility test (February 2026)

    The Safeguard Mechanism (SGM) review scheduled for 2026–27 will be a defining moment for Australia’s industrial climate policy. With declining baselines biting harder and compliance demand rising, the review will determine whether the mechanism continues to drive genuine abatement or whether its impact plateaus.

    Key Tensions:

    • Baseline Decline Rates: The indicative post-2030 rate of 3.285% falls well short of what’s required. Independent analysis suggests annual declines of 4.8%–6.9% are needed to align with Australia’s 2035 ambition.
    • Facility Performance: Covered emissions fell only ~4.3% over two years, while exceedance volumes increased by more than 50%—indicating facilities are not decarbonising fast enough.
    • Offset Integrity: As baselines tighten, the scheme’s credibility becomes tied directly to ACCU supply and integrity—itself under review in 2026.

    Expert View: Tony Wood (Grattan Institute): “This will be an important test of the government’s commitment to meeting its targets.”

    4. GHG Protocol Releases Land Sector and Removals Standard

    Source: GHG Protocol – Land Sector and Removals Standard (30 January 2026)

    The GHG Protocol has released its first-ever global standard for corporate accounting of land-sector emissions and removals. Published 30 January 2026, the LSR Standard establishes how companies should account for:

    • GHG emissions from agricultural land use
    • CO₂ removals from land-based activities
    • Emerging carbon dioxide removal (CDR) technologies

    Key Details:

    • Effective Date: 1 January 2027
    • Review Date: 2030
    • Guidance Document: Expected Q2 2026

    Why This Matters: For Australian entities in mining, agriculture, land management, and natural resources, this standard will influence future disclosure expectations.

    Practical Takeaway: What to Do in February 2026

    For Group 1 Entities:

    • Review December 2025 AASB S2 amendments—they may simplify your GHG reporting
    • Ensure governance documentation is complete before year-end
    • Reconcile all Scope 1 and 2 activity data to your general ledger

    For Group 2 Entities (1 July 2026 start):

    • You have 4+ months—use them for a gap analysis against AASB S2
    • Start documenting climate risk and opportunity assessments now
    • Consider a “dry run” sustainability report in Q1–Q2

    For Assurance Practitioners:

    For Safeguard Facilities:

    • Monitor ACCU pricing and supply signals ahead of the 2026–27 review
    • Baseline decline rates for 2030–35 will be set by July 2027

    Sources

  • As we move through February 2026, the Australian sustainability landscape is no longer in a “waiting room.” For the first wave of Group 1 entities, the reporting cycle is actively underway, and for Group 2, the July 1 deadline is no longer a distant milestone. For those of us at the intersection of practice and academia, this week’s developments underscore a shift from defining the standards to operationalising them.

    We are moving beyond the “what” of AASB S2 and into the “how” of verifiable, high-integrity data. From the modular evolution of carbon credits to the rigorous expectations of scenario analysis, the infrastructure of auditability is being built in real-time.

    The Deep Dive: Key Technical Updates

    1. The IFLM Method: A Modular Leap for Carbon Integrity

    The Clean Energy Regulator (CER) is currently in the final stages of consultation (closing 23 February 2026) for the Integrated Farm and Land Management (IFLM) method. (See the IFLM Explanatory Material.)

    The Innovation: This is Australia’s first truly “modular” carbon crediting framework. It allows landholders to combine multiple abatement activities—such as native forest regeneration and environmental plantings—within a single project area.

    The Audit Challenge: For auditors, this increases complexity significantly. We must now assure “stacked” abatement without double-counting. This requires a robust understanding of the new Unit and Certificate Registry and enhanced spatial data verification. It is a prime example of what I call “Calculative Technologies” in action—where the methodology itself must be as resilient as the sequestration it measures.

    2. ASRS 2026: From Data Architecture to Scenario Reality

    New insights from early 2026 adopters (Group 1) suggest that while “data plumbing” (systems for Scope 1 and 2) is stabilising, Scenario Analysis remains a significant hurdle for board-level approval.

    AASB S2 Requirements: Remember that Australian standards mandate at least two scenarios: a 1.5°C pathway and a “high-warming” scenario exceeding 2°C (typically 2.5°C+).

    The Practitioner’s Friction: There is a growing “literacy gap” in the boardroom. Directors are not just required to disclose these scenarios; they must demonstrate how these insights inform strategic capital allocation. The risk of “regulator-only” protected statements is fading, and the focus is shifting toward the auditability of these qualitative judgments.

    3. Safeguard Transformation: The $321M Decarbonisation Push

    On 4 February 2026, the Australian Government announced $321 million in funding specifically for trade-exposed facilities under the Safeguard Mechanism.

    Impact on Reporting: This funding—aimed at industrial decarbonisation—will directly influence “Transition Plans” disclosed under AASB S2. Practitioners should look for these grants in client disclosures as evidence of “resilience” and “planned capital expenditure.” It bridges the gap between a high-level climate commitment and a funded, operational reality.

    Practical Takeaway: What to Do This Week

    For Auditors: If your clients are involved in land-based carbon projects, review the IFLM Draft Method. Assess whether your current sampling and spatial verification tools can handle modular abatement stacking.

    For CFOs: Evaluate your “Transition Plan” narrative. If you are receiving Safeguard Transformation funding or similar grants, ensure the financial effects are clearly linked to your climate-related opportunities in your sustainability report.

    For Everyone: Re-read the AASB S2 “Proportionality Guidance.” As Group 2 prepares to start on 1 July 2026, the board has made it clear: you must use “all reasonable and supportable information” available without undue cost or effort. Don’t let the pursuit of perfect data paralyse the start of the reporting journey.

  • As we step into February 2026, Australia’s climate reporting landscape has officially entered a new phase. Group 1 entities—our largest listed companies and financial institutions—have now been operating under mandatory AASB S1 and S2 requirements since 1 January 2025, while Group 2 entities are counting down to their 1 July 2026 commencement date. For those of us working at the intersection of climate reporting and assurance, this is no longer a preparation exercise—it’s implementation reality.

    This opening post of 2026 captures the key regulatory developments that have emerged since late 2025, focusing on assurance standards, disclosure proportionality, and the tools being developed to support practitioners and preparers alike.

    The Deep Dive: Key Developments

    1. AUASB Issues ASSA 2025-10: Assurance on Voluntary Sustainability Reports

    Source: AUASB – ASSA 2025-10 (21 January 2026)

    In a significant move, the Auditing and Assurance Standards Board (AUASB) has issued ASSA 2025-10, which establishes the phasing in of assurance requirements for Group 1, 2 and 3 entities preparing voluntary sustainability reports under the Corporations Act 2001.

    Key Points:

    • The standard bridges the gap between mandatory and voluntary reporting regimes
    • Provides clarity for entities that wish to obtain assurance on sustainability reports before their mandatory commencement date
    • Aligns the assurance framework with the broader ASSA 5000 suite

    Practitioner Note: This is particularly relevant for Group 2 and 3 entities wanting to “dry run” their sustainability reports with assurance before mandatory requirements kick in.

    2. AASB S2 Scenario Analysis Workshops – March 2026

    Source: AASB Reporting Roundup December 2025 (17 December 2025)

    The Australian Accounting Standards Board has announced AASB S2 Scenario Analysis Workshops scheduled for March 2026. This is a direct response to one of the most challenging requirements of AASB S2: the climate-related scenario analysis.

    Why This Matters:

    • Scenario analysis under AASB S2 requires entities to assess climate resilience under different futures (including a 1.5°C pathway)
    • Many preparers have flagged this as a significant capability gap
    • The AASB’s workshops signal recognition that hands-on guidance is needed beyond written standards

    3. Proportionality Mechanisms in AASB S2

    Source: AASB – Proportionality Mechanisms in AASB S2 (9 September 2025)

    The AASB has published guidance on proportionality mechanisms embedded within AASB S2. These mechanisms are designed to support disclosures involving significant judgement or uncertainties.

    Key Proportionality Features:

    • Allowance for qualitative disclosures where quantification is not yet feasible
    • Recognition that smaller entities (within Group 1) may have less sophisticated data systems
    • Emphasis on “reasonable and supportable” information rather than perfect precision

    Practitioner Note: This guidance is essential reading for auditors and preparers navigating the first year of mandatory reporting.

    4. Safeguard Mechanism: 2024-25 Compliance Cycle Complete

    Source: Clean Energy Regulator – Safeguard Mechanism

    The Safeguard Mechanism continues to operate in parallel to the sustainability reporting regime. With the 2024-25 compliance cycle now complete:

    • 135.9 million tonnes CO2-e covered emissions reported
    • 7.3 million ACCUs surrendered
    • 1.4 million SMCs surrendered

    Looking Ahead: The CER’s Unit and Certificate Registry is now the single source of truth for ACCU and SMC holdings.

    Practical Takeaway: What to Do in February 2026

    1. For Group 1 Entities: Your first mandatory sustainability reports are due with your next annual report. Ensure your scenario analysis methodology is documented and defensible. Consider attending the AASB S2 workshops in March.
    2. For Group 2 Entities (July 2026 start): Now is the time to conduct a gap analysis against AASB S1/S2. Consider voluntary assurance under ASSA 2025-10 as a practice run.
    3. For Assurance Practitioners: Familiarise yourself with ASSA 2025-10 and the illustrative auditor’s reports under ASSA 5000.
    4. For Safeguard Facilities: Verify your ANREU/Registry holdings before the SMC application window closes.

    Sources

  • It’s been a big month of learning. Across the public and private sectors, climate-related reporting and assurance training has accelerated — a clear sign that Australia is moving from policy design to practical delivery. I was fortunate to take part in several technical programs recently, which deepened my understanding of both greenhouse gas (GHG) assurance and climate-risk assessment.

    Without sharing any confidential content, I want to reflect at a high level on what stood out — and why it matters.


    1. Climate risk is now a governance issue, not a niche

    A recurring theme across all programs was that climate risk is no longer an environmental add-on. It’s being embedded into enterprise risk management, financial planning and audit oversight. Public agencies and listed entities alike are being trained to treat climate risk using the same rigour as other strategic risks — complete with defined responsibilities, accountability structures and periodic reviews.

    The message: governance drives credibility. Board and executive oversight of climate-related risks is becoming mandatory, not optional.


    2. Greenhouse gas reporting is becoming standard audit territory

    Training in GHG accounting underscored how much attention is shifting to data quality, boundary setting, and assurance readiness.
    Even at a conceptual level, it’s clear that the next few years will see rapid growth in sustainability assurance — from limited to reasonable assurance engagements under ASSA 5000, mirroring financial audit practice.

    For practitioners, the implications are practical: learning to interpret activity data, apply emission factors correctly, and understand materiality in the context of non-financial reporting. For entities, it’s about building systems robust enough to withstand audit testing.


    3. Proportionality and scalability are key

    Not every organisation has the same exposure, resources, or data maturity. Training discussions emphasised the concept of proportionality — ensuring that climate-related disclosures and assurance work are scaled appropriately to entity size and complexity, while still meeting the spirit of the standard.

    This idea will help smaller organisations participate meaningfully without being overwhelmed, and help auditors focus effort where the greatest risks lie.


    4. Adaptation and resilience are gaining attention

    Beyond emissions and compliance, climate-risk practitioners are talking more about adaptation pathways — structured, staged approaches to resilience planning. Rather than one-off assessments, entities are encouraged to design “pathways” that trigger action as new information or thresholds are reached. This type of forward-looking planning connects sustainability reporting with long-term service continuity and asset resilience.


    Why this matters

    For both the public and private sectors, these capability-building efforts mark a shift from awareness to competence. Climate risk and emissions assurance are no longer theoretical — they are becoming day-to-day professional responsibilities.

    As auditors, accountants and analysts, we’re being asked to translate complex environmental data into reliable, decision-useful information. That requires not just technical skill but judgement, scepticism and ethical awareness — the same principles that define our profession.


    The work ahead is challenging, but it’s meaningful. Every training session, every new framework, brings us closer to a profession that can help navigate Australia’s low-carbon transition with integrity and confidence.

  • I’m a little late with this week’s post. A close family member has just been diagnosed with cancer — and we’ve been told there may not be much time left. It’s hard news to process. Moments like this make you stop and think about time, purpose, and what difference we really make in the brief years we have.

    As I sat with this, I couldn’t help but reflect on how often human activity has been described as a kind of cancer on the planet — consuming, spreading, and disrupting the natural systems that sustain life. But I don’t actually believe the Earth itself will die from climate change or any other human-made crisis. The planet is far more resilient than we are. Over billions of years it has survived impacts, ice ages, and extinctions. What is truly at risk is us — and the millions of other living creatures that share this moment in Earth’s long story.

    That realisation changes the way I think about climate work. The point is not to “save the planet” in some abstract sense; it’s to make life on this planet endurable and ethical for those who are here now and for those who come after.

    Even in technical fields like accounting and auditing, our choices shape that future. The systems we design to measure, disclose, and assure environmental impacts are not just compliance tools — they are moral and social instruments. They define what counts, what matters, and what is seen as progress.

    Some people cause damage and never get the chance to repair it. The rest of us, while we can, should do the best we can — whether that means challenging flawed metrics, strengthening climate reporting, or ensuring integrity in the information societies rely on to act.

    I don’t know if my loved one will live to see a more sustainable world. But I do know that our professional work — the patient, evidence-based, sometimes invisible work of building trustworthy systems — can help bring it a little closer.


  • 1. ACCU Scheme review consultation opens

    On 20 October 2025, the Climate Change Authority (CCA) formally opened its public consultation for its statutory review of the Carbon Credits (Carbon Farming Initiative) Act 2011—the legislative foundation for Australia’s ACCU Scheme. The consultation invites feedback on the Scheme’s operation and broader role in a decarbonising economy. Submissions close at 5 pm AEDT on 8 December 2025.

    📘 For more details see: CCA ACCU Scheme Reviews (Climate Change Authority)

    This consultation arrives at a critical juncture: Australia’s new 2035 emissions-reduction target (-62 to -70 % below 2005 levels) places greater expectations on the ACCU Scheme to deliver credible abatement. The questions posed by the CCA—covering methodology governance, supply/demand dynamics, and market integrity—signal that the regulatory eye is shifting from voluntary offsets to mandatory disclosure and verification.


    2. New ACCU method-development process launched

    In mid-October, the Department of Climate Change, Energy, the Environment and Water (DCCEEW) published an update on how the ACCU Scheme is evolving its methodology development processes. The new “proponent-led” route replaces earlier government-only prioritisation and invites industry ideas for innovative abatement methods.

    📘 See: Developing new ACCU Scheme methods – DCCEEW (DCCEEW)

    Key points:

    • Several methods (for soil carbon, milking-cow feed additives, industrial waste-gas reductions) are now being fast-tracked.
    • Projects under older methods nearing expiration must plan for continuity or transition.
    • The message to smaller practitioners is clear: the Scheme is opening—and so are the risks of being left behind.

    For auditors and reporting teams, this is a signal that methodological risk (i.e., which carbon credit method a project uses) could matter for disclosures, especially when credits are referenced or retired in climate-related financial statements.


    3. National Climate Risk Assessment Report released

    October also saw the release of Australia’s first National Climate Risk Assessment Report, paired with the new National Adaptation Plan, addressing ten priority hazards—including flooding, bushfires, drought and ocean warming—across multiple time horizons (+1.5 °C, +2 °C, +3 °C).

    📘 Source: Australia’s first National Climate Risk Assessment Report (Clayton Utz)

    While this is more adaptation-than-disclosure focused, the report feeds directly into the climate strategy and risk-management pillar of AASB S2. For reporting entities, the implication is clear: climate-risks are no longer theoretical or long-term—they’ll need to be disclosed in financial statements under the new regime. It also raises questions for auditors about how advised scenario-analysis, sensitivity testing and disclosures should respond to such national-level evidence.


    Practical take-aways for preparers & auditors

    • If you’re involved with ACCUs or offsets, the consultation from the CCA is your chance to influence future policy—but also your signal to review any exposure now (method choice, expiry risk, documentation).
    • Audit & assurance teams should start factoring in method-risk assessment for carbon-credit-related disclosures: which method, who approved it, what documentation supports it?
    • Smaller entities not yet in scope for full climate disclosure should still track these developments: adaptation-risk reporting cue-cards and offsets market reforms hint at future expectations.
    • Boards and audit committees should ensure minutes reflect discussion around scenario-analysis and adaptation risks, especially as national assessment data becomes publicly available and integrates with disclosures.

    Final thoughts

    October 2025 reaffirmed that the intersection of mandatory climate disclosure (via AASB S2) and carbon-credit markets (via the ACCU Scheme) is becoming increasingly integrated. For reporting entities and assurance practitioners, this means moving beyond “Would we need it?” to “How do we prepare now?” The policy signals are unmistakable: method integrity, transparency, market dynamics and adaptation risk are now part of the disclosure and assurance agenda.

    As always, stay tuned for next month’s update—more developments are already in motion.

    🔗 Further reading:

    Note: This article reflects my interpretation of public information and does not constitute professional or financial advice.

  • The Climate Change Authority (CCA) has opened its public consultation for the 2026 review of the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act) — the legislation that underpins the Australian Carbon Credit Unit (ACCU) Scheme.
    Submissions are open until 5 pm AEDT, 8 December 2025 via the CCA Consultation Hub 💬.

    This review marks a pivotal moment for Australia’s climate policy architecture. It’s the first comprehensive review since the Safeguard Mechanism reforms, and comes as the nation ramps up ambition toward a 62–70 % reduction in emissions by 2035.
    The consultation paper — Enhancing the ACCU Scheme to Support Australia’s 2035 Emissions Reduction Target — asks how the scheme can evolve to maintain integrity, scalability, and credibility in a decarbonising economy.


    What’s in focus

    1. Strengthening the scheme’s role in meeting the 2035 target

    The CCA’s framing is clear: the ACCU Scheme remains a “high-integrity, high-impact tool,” but it must now deliver abatement at a scale that supports net-zero alignment.
    As Australia’s industrial emitters rely more heavily on offsets through the Safeguard Mechanism, the review will examine whether the supply of high-quality credits can keep pace — without discouraging direct decarbonisation.
    📘 Official source: CCA Issues Paper (October 2025, PDF)

    2. Methodologies – the engine room of the scheme

    Methodologies determine how carbon projects earn ACCUs — from soil carbon and environmental plantings to energy efficiency and landfill gas conversion.
    The CCA notes that several methods expired in 2025 and more will lapse in 2026, creating potential supply constraints. Four new methods are being developed, and a proponent-led method process is underway to accelerate innovation.

    However, the consultation flags three persistent challenges:

    • Slow method approval due to technical complexity and governance bottlenecks.
    • Transparency in how methods are reviewed and endorsed.
    • Scalability barriers for smaller or regional proponents.

    📘 See more: Clean Energy Regulator – ACCU methods list

    3. Market dynamics and price signals

    As the government steps back from being the main buyer, Safeguard Mechanism entities now dominate demand for ACCUs.
    Prices remain below the cost-containment threshold of $82.68 per tonne (for 2025/26), but analysts expect demand — and price — to rise steadily through the 2030s.
    Interestingly, the market is showing price differentiation: ACCUs with biodiversity or community co-benefits often attract premiums, while generic industrial offsets trade lower.

    📈 Market data: Reputex ACCU Market Dashboard and Jarden Carbon Market Report.

    The CCA is inviting comment on how to design the right incentives:

    • What role should government still play in purchasing or guaranteeing demand?
    • How can co-benefits (biodiversity, social impact, durability) be priced in fairly?

    My take: the assurance and legitimacy angle

    From an audit and assurance perspective, this consultation is fascinating.
    It signals that the integrity architecture of the carbon market — methodologies, monitoring, and verification — is under as much scrutiny as the credits themselves.
    For auditors, this raises several implications:

    • Auditability of carbon credits: When corporates include ACCUs in climate disclosures or offset statements under AASB S2, assurance practitioners will need to understand how each credit’s integrity is established.
    • Legitimacy through accounting: The consultation’s focus on transparency and public confidence echoes what I explore in my research — how assurance practices make markets legitimate by defining what counts as “real” abatement.
    • Future overlap with S2 assurance: As sustainability audits mature under ASSA 5000, ACCU verification processes may evolve toward shared assurance principles.

    Put simply: this review isn’t just about carbon farming — it’s about who gets to define credible carbon accounting in Australia’s next policy era.


    What businesses and auditors should do now

    • Engage early: If your organisation buys, sells, or reports on ACCUs, consider making a submission through the CCA’s Consultation Hub.
    • Map exposure: Identify which of your decarbonisation or reporting strategies rely on offsets — and which methodologies those credits come from.
    • Track method updates: Projects using soon-to-expire methods should plan for transition or re-registration.
    • Prepare for enhanced scrutiny: As integrity and transparency reforms advance, expect more robust documentation and assurance expectations in future reporting cycles.

    Final thoughts

    The ACCU Scheme has always been a cornerstone of Australia’s climate policy — but it’s also been controversial.
    This fifth review gives policymakers, industry, and auditors a chance to strengthen trust in the system before it scales further.
    By participating in the consultation, stakeholders can help shape a scheme that balances integrity, efficiency, and inclusiveness — one that rewards genuine abatement rather than paperwork.

    🔗 Further reading:


    This post reflects my interpretation of public documents and does not constitute professional or financial advice.