Chartered Accountants Australia and New Zealand (CA ANZ) has provided feedback to the Department of Climate Change, Energy, the Environment and Water (DCCEEW) on its Draft Greenhouse Gas (GHG) Emissions Estimation and Reporting Guidelines for Agriculture, Fisheries and Forestry.

The Guidelines aim to improve the consistency and transparency of emissions estimation and reporting across the agriculture, fisheries and forestry sectors. CA ANZ supports this objective and the alignment with internationally recognised frameworks. However, we emphasise that the Guidelines must be practical and accessible to achieve broad adoption.

Key messages

Accessibility and usability

CA ANZ recommends improving clarity and usability by:

• Strengthening references to established frameworks (such as the GHG Protocol and ISO)
• Using clearer, plain language and structured guidance
• Enhancing the usability of the Common Requirements Framework

While the Guidelines are technically robust, the current level of detail and complexity may limit practical application, especially for non-specialist users.

Practical implementation in the primary sector

Feedback indicates the Guidelines are likely to:

• Require reliance on specialist tools, calculators and consultants
• Create cost and capability barriers for smaller or family-run operations
• Lead to inconsistent outcomes where tools and advisors apply the Guidelines differently

These challenges may affect uptake, particularly where reporting is voluntary.

Methodology and technical considerations

CA ANZ recommends:

• Providing clearer guidance on Scope 3 inclusions and exclusions
• Limiting application to Methods 1 and 2 at this stage
• Deferring the incorporation of emerging technologies until methodologies are updated

We also support consistent data quality criteria aligned with established frameworks to improve comparability.

International alignment

Alignment with international standards, including the GHG Protocol and ISO, is essential to support consistency, comparability and global relevance of emissions reporting.

Supporting implementation

To support adoption in practice, CA ANZ encourages DCCEEW to:

• Facilitate simple, standardised tools and calculators
• Provide proportionate pathways for smaller or less complex operations
• Clarify the expected role of third-party tools and advisors

Consideration should also be given to financial support mechanisms, such as grants or advisory support, to assist primary producers.

Overall position

CA ANZ supports the development of the Guidelines and their role in improving consistency in emissions estimation and reporting. Ensuring the Guidelines are accessible, scalable and usable in practice will be critical to achieving meaningful uptake across the sector.