Date posted: 27/09/2022

Submission on 2023 Corporate Emissions Reduction Transparency report

We recommend leveraging the NGERs audit framework for voluntary limited assurance over aspects of the CERT report

The Corporate Emissions Reduction Transparency (CERT) report is a way for companies to show progress towards reducing emissions or increasing their use of renewable electricity and their use of carbon offsets using a standardised framework.  Participation is voluntary and is open to companies reporting over 50 kilotonnes of carbon dioxide equivalent (CO2-e) emissions a year under the National Greenhouse and Energy Reporting (NGER) scheme. The CERT report is released annually and was undertaken as a pilot in the first year in 2022 in which 23 companies participated.

The Clean Energy Regulator sought feedback on the updated design for the 2023 CERT report. Our submission focused on the independent assurance of commitments and supporting information.

The key points of our submission are:

  • We support continuing to evolve the CERT report to better align with other climate-related reporting requirements, for example the National Greenhouse and Energy Reporting (NGER) scheme. In particular, we support the use of the ISSB standard on climate-related disclosures, as it evolves, as a reference point to align the CERT report design, particularly regarding metrics and targets. 
  • We support giving entities the option to voluntarily obtain independent external assurance on certain commitments and/or progress statements in their CERT report where the CER cannot use its data to verify progress.
  • We agree with the proposal that the minimum level of assurance be set as limited.
  • We support a requirement for the assurance engagement to be conducted in accordance with either ASAE 3000/ASAE 3410 for Australian commitments; or ISO 14064-3 and/or ISAE 3000/3410 for international commitments, as applicable.
  • We also support Category 2 individuals from the Register of Greenhouse and Energy Auditors being considered suitably qualified and experienced auditors for the purpose of this proposed regime.
  • We recommend using the NGER audit framework for this proposed assurance regime because in our view the assurance engagements are comparable to a Part 6 audit under the NGER scheme and the NGER audit framework has been proven to be workable and effective over time.

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