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(Cth) Mandate Public Disclosure of Offset Reports, Audit Reports and Supporting Data for ACCU Projects
- Jonathan Adams and Lauren Finnerty
- Jan 7
- 8 min read
Author: Jonathan Adams and Lauren Finnerty | Publish date: 7/1/2026
P: The Clean Energy Regulator (CER) does not publicly disclose offset reports, audit reports and supporting data for Australian Carbon Credit Unit (ACCU) Projects on the ACCU Project and Contract Register (the Register).
S: The Minister for the Environment and Water should amend section 168 of the Carbon Credits (Carbon Farming Initiative) Act 2011 (Cth) to include the disclosure of offset reports, audit reports, and supporting data to the Register.
Problem Identification:
Section 168 of the Carbon Credits (Carbon Farming Initiative) Act 2011 (Cth) mandates the entry of ACCU project information, such as name, project methodology, location, crediting information and proponent details, into the Register. However, whilst offset reports, audit reports and supporting data are submitted to the CER to demonstrate compliance with method requirements and the integrity of credited abatement, mandated disclosure of these reports is not included in the Act.
According to Macintosh et al. (2024), this means that information relating to project performance, audit findings and method compliance is not available for external examination, limiting the external review of method application and abatement estimates. Independent carbon project ratings agency BeZero Carbon has stated that reduced visibility of information may also influence perceptions of the scheme’s transparency and decrease public trust and confidence for market participants.
Context:
An ACCU project refers to an activity undertaken by a project proponent, under an approved emissions-abatement method, to reduce or remove greenhouse gas emissions. Projects can include abatement activities such as reforestation, landfill gas capture, savanna burning, industrial energy efficiency and other emissions-abatement activities.
An ACCU refers to a carbon credit issued by the CER. One ACCU represents one tonne of CO₂-equivalent emissions abatement. ACCUs can be traded or sold to private companies and the Commonwealth Government to offset emissions, meet voluntary net-zero commitments, or comply with baseline legal obligations (under the Safeguard Mechanism).
In order to earn ACCUs, projects must be lodged with the CER and included on the Register. The Register refers to the publicly accessible CER database that records basic information about each ACCU project (e.g. name, method and location). To comply with CER registration requirements, project proponents must submit offset reports, audit reports and supporting data to demonstrate compliance. This reporting is used by the CER to calculate crediting, ensure integrity and review methodology and is not publicly disclosed.
Arguments:
The 2022 Independent Review of ACCUs outlined that the current disclosure restrictions are ‘undermining transparency, trust and confidence in the scheme.’ An international study by Delacote et al. (2025) found that scientists routinely identify crediting that overstates real emissions reductions. However, without access to information, Sasaki et al. (2025) highlighted that it ‘makes it nearly impossible for independent third parties to assess the legitimacy of claimed emission reductions.’ Further, Macintosh et al. (2024) argued that underperforming projects can persist in the absence of third-party scrutiny, which can undermine the integrity of the scheme.
BeZero Carbon has noted that without independent scrutiny, investors are not able to select effective projects with confidence. The Climate Change Authority outlined that confidence in the integrity of ACCUs is key for market participants, and this requires ‘access to sufficient information’.
Advice/Solution Identification:
Macintosh et al. (2023) and the Carbon Market Institute (CMI) and BeZero Carbon have recommended the public disclosure of offset, audit and supporting data on the Register. Further, the Climate Change Authority and Woodside Energy, among others, have called for greater public disclosure of information within the ACCU scheme. CMI has suggested that improved disclosure ‘may support project verification and/or public confidence’. Further, the 2022 independent review stated that ‘more transparent data and information sharing arrangements would enable communities and carbon market stakeholders to assess, understand and manage potential project impacts and opportunities more effectively.’
Precedent:
There is international precedent for the public disclosure of offset reports, audit reports and supporting data. In France and the UK, and in global voluntary markets like the UN’s Clean Development Mechanism (CDM), the Verra Verified Carbon Units program, and the World Wildlife Fund’s Gold Standard Market, it is standard practice for carbon markets to publicly disclose offset reports, audit reports and supporting data.
Public Support:
Broad support (called for greater public disclosure of information within the ACCU scheme):
News Coverage:
The Guardian - “Australia’s Carbon Credit System a failure on a global scale, study finds”. This article reported a major study that found Australia’s carbon credits system had largely failed to increase forest cover or deliver real emissions reductions and was doing little to address the climate crisis on a global scale. By: Adam Morton | 27 Mar 2024 - Read the article here.
ABC News - “Insider blows whistle on Australia's greenhouse gas reduction schemes”. This article reported that a former insider within Australia’s carbon credit system alleged that key greenhouse gas reduction schemes were being misused to generate credits that did not represent real emissions cuts, warning that the system lacked integrity and transparency. By: Stephen Long & Alex McDonald | 24 Mar 2022 - Read the article here.
Australian Financial Review - “Investors warned of ‘false assumptions’ in carbon credits”. This article reported that many companies may be spending money on carbon credits that do not deliver genuine emissions reductions because of flawed metrics and a lack of transparency in the carbon credit system. By Lucy Dean | 02 Oct 2022 - Read the article here.
The Guardian - “Australia’s biggest industrial polluter receives millions in carbon credits despite rising emissions”. This article reported that Chevron’s Gorgon facility had received millions of dollars in carbon credits in 2024 despite increasing its emissions, thereby highlighting major transparency and policy integrity flaws in the country’s carbon-crediting system, and undermining confidence in offset-based accountability. By: Adam Morton | 21 Apr 2025 - Read the article here.
ABC News - “Industry bosses making money from carbon credits say the system needs to change”. This article reported that several major companies profiting from Australia’s carbon credit system publicly criticised it for generating “meaningless” credits. They argued the system needed reform because it failed to incentivise real emissions reductions and could even increase overall emissions. By: Michael Slezak | 06 Sep 2022 - Read the article here.
Where to go to learn more:
Independent Review of Australian Carbon Credit Units (ACCU) - The report examined the integrity, design and governance of the ACCU Scheme and made a series of recommendations to improve transparency, clarify governance roles, strengthen method approval and increase public trust in the carbon-credit system. Find the link here.
CER Consultation: Submission by BeZero Carbon - The submission by BeZero Carbon to Clean Energy Regulator (CER) argued that a new Australian carbon-credit registry should require full public disclosure of project documents, detailed carbon accounting, and monitoring/verification data to ensure transparency and robust assessment of carbon credit integrity. Find the link here.
Australian National Audit Office (ANAO) review of the ACCU Scheme - The ANAO found that the Clean Energy Regulator’s administration of ACCU issuance and compliance was largely effective, while identifying areas for improvement in information systems, monitoring and reporting, and transparency around committee interests. Find the link here.
The Integrity Council for the Voluntary Carbon Market (ICVCM) Core Carbon Principles - The Core Carbon Principles (CCPs) established a global benchmark for high-integrity carbon credits that set rigorous thresholds on disclosure and sustainable development. Find the link here.
Carbon Credits (Carbon Farming Initiative) Act 2011 (Cth) - Read the full Act here.
Human Perspective:
Ben, the sustainability manager at MegaCorp Steel, personally staked his reputation on buying a large volume of ‘high-integrity’ ACCU credits from an avoided deforestation project to meet the company's net-zero goals. However, an NGO exposé challenged the credits, claiming the project grossly inflated its baseline using data that should have been public. Ben urgently needed the CER's full offset report and supporting data to verify the NGO's claims or defend his choice to the board. Because the CER does not publicly disclose the details, Ben could not access the primary documents he needed to perform due diligence or prove that the credits are delivering real and additional abatement. He realised the system is a ‘black box’ and now his genuine effort to make a good choice has been exposed to public and internal ridicule. He never would have invested in the project if he had been able to see the reports showing underperformance. Ben is glad the scheme exists and was excited when it was introduced, but he is now seriously concerned about the ACCU’s transparency. He now cautions others that the ACCU scheme is not fit for purpose, surrounding conscientious environmental action and real emissions reduction.
To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.
Conflict of interest/acknowledgment statement:
BeZero Carbon confirmed its support for this solution and discussed barriers to implementation in a meeting with FORE Australia held on 27 November 2025.
Support
If your organisation would like to add your support to this paper or suggest amendments, please email Info@foreaustralia.com.
Reference list:
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