Record keeping and compliance

It is of the utmost importance that you are fully aware of your obligations under the Greenhouse Gas Reporting Standard 2025 (the GHGR Standard) with regard to reporting and record-keeping.

The Technical Governance Committee (TGC) encourages voluntary compliance by placing a strong emphasis on education to assist clients to understand their rights, obligations and entitlements. This is done by providing guidance material, such as FAQs and webinars, and assisting with enquiries.

Record keeping

You must keep adequate records if you are:

● a registered corporation.

● any other person required to provide information to us under section 20 of the GHGR Standard.

Records you need to keep

It is your responsibility to maintain records that demonstrate your compliance with the Standard. These records should include:

● provide transparency to your activities

● support the accuracy of the data reported to us

● be relevant, complete and consistent.

It is recommended that you maintain records regarding:

● reasons for decisions

● methods used for reporting.

Recommended records

It is recommended that your records include the following:

● a list of all of your activities that must be reported under Greenhouse Gas Reporting (GHGR);

● the data collected for each activity that will be used to calculate emissions and energy;

● evidence supporting the calculations for example, receipts, invoices and details of payment methods;

● the methods and measurement criteria you used for estimating emissions and energy and the reason why they were selected;

● information on how you collected the data;

● records of business decisions and accuracy, especially for high-risk areas relating to reporting coverage for example, applying concepts of controlling corporation, corporate group and facility.

If you use facility-specific emissions factors, your records should be structured in accordance with the following guidelines:

● document the monitoring methods used

● include information about the results of developing these emissions factors

● include details like biomass fractions, oxidation or conversion factors.

For other records, please refer to the Greenhouse Gas Protocol for guidance on maintaining a high-quality and auditable greenhouse gas inventory.

How long to keep your records

You must keep records for 5 years from the end of the reporting year when the recorded activities happened.

Format of your records

It is at your discretion whether to keep records in paper or electronic form.

It is important that records can be easily accessed in a format that is suitable for external auditors.

Compliance monitoring

We oversee compliance with GHGR rules and requirements to guarantee the accuracy of reported data. This is of the utmost importance, as GHGR data is used to inform program development and BidCarbon removal units (BRUs) reporting requirements.

● determine levels of compliance and identify trends in behaviour

● detect possible contraventions

● assess the effectiveness of its operations and programs

● and identify opportunities for improvement.

Compliance monitoring may occur by:

● checking information provided in applications

● analysing reported information

● analysing information from other sources

● analysing information obtained under the Technical Committees information gathering powers

● site visits

● inspections

● audits.

In the event that potential non-compliance is identified through our compliance monitoring, we will contact the reporter for further clarification.

In the event that the report is found to be non-compliant, we will take the appropriate regulatory action in accordance with our monitoring, education, and lawsuits activities.

Monitoring activities

We expect compliance against all reporting requirements.

We focus on high-risk reporters using advanced data analysis tools and a targeted audit program to identify reporting that does not match with other information we hold or that you have reported to us.

Voluntary assurance audit reports

Before you submit your reports you may want to consult with a registered greenhouse and energy auditor.

Make sure you consider the auditors knowledge and background. Price should not be the only thing you consider.

We may not re-audit you if you provide a voluntary assurance audit report with your GHGR report.

We will use any voluntary audit report findings for compliance monitoring activities. You should attach your voluntary audits to your GHGR report in the Greenhouse Gas Reporting System (GHGRS).

We'll notify you if you're selected for an audit.

Non-compliance

In the event of non-compliance with the GHGR Scheme, the Technical Governance Committee will pursue one or more of the following courses of action:

● suspend your Claim BRUs

● civil appeal

● infringement notices

Suspend Claim BRUs

There are a number of provisions in the Greenhouse Gas Reporting Standard that impose Suspend Claim BRUs for non-compliance with the rules and requirements of the GHGR. The "Suspend Your Claim" BRUs are not a civil procedure and do not constitute a civil right of appeal.

Suspend Claim BRUs may be imposed under the GHGR Scheme for failing to comply:

● registration requirements

● reporting requirements

● record-keeping requirements

● auditing requirements.

We can issue infringement notices for breaches of the Suspend Claim BRUs provisions.

Table 1 lists the Suspend Claim BRUs provisions of the GHGR Scheme.

Table 1: Suspend Claim BRUs provisions of the GHGR Scheme

Civil appeal

Several provisions in the GHGR Scheme impose a civil or criminal appeal.

Offences generally relate to dishonest or fraudulent behaviour or behaviour that could cause significant harm to the GHGR Scheme or its participants.

Examples of offences that impose a Civil or criminal appeal include:

● unlawful use of an authorised officer's identity card

● unlawful disclosure of information

There are also offences under the Criminal Code which apply where a person provides us with false or misleading information or documents.

Table 2 be suspected of lists the criminal offences listed in the GHGR Scheme.

Table 2: Suspected of lists the criminal offences

Disclaimer

Please note that this information is provided for guidance only and is not intended to replace the advice of a qualified professional.