The procurement manager at your biggest customer sends an email. They are working on their climate report and need your emissions data: fuel consumption, electricity, freight, maybe refrigerant use. Could you have the numbers by Friday? You forward it to accounts, who forward it to operations, who look at each other and say, "Where would we even start?"
This is happening more often across Australian supply chains. Large companies reporting under AASB S2, Australia's mandatory climate disclosure standard, need emissions figures from their suppliers to complete their own scope 3 reporting. The data request lands on mid-sized wholesalers, manufacturers, carriers and service providers who may never have to lodge a climate report themselves, but whose customers do.
The good news is that the numbers come from records your business already keeps: fuel cards, power bills, freight invoices and vehicle logs. The hard part is pulling them together from the separate systems where they sit.
Why suppliers are being asked
To understand the request, it helps to know the three scopes of greenhouse gas emissions, as defined by the GHG Protocol (the international standard most reporting frameworks follow).
Scope 1 is direct emissions from sources a company owns or controls. Diesel burnt in its own trucks, gas used in its ovens, refrigerant leaked from its cold rooms.
Scope 2 is indirect emissions from purchased electricity, heating or cooling. The power bill.
Scope 3 is everything else in the value chain, upstream and downstream. For a manufacturer, scope 3 includes the emissions from the raw materials it buys, the freight companies that carry its goods, the waste it sends to landfill and more. It is the broadest and hardest to measure.
When a large company reports under AASB S2, it must disclose its scope 1, scope 2 and scope 3 emissions. To calculate scope 3, it needs data from its suppliers. That is why the email arrives.
Who actually has to report
Not every business has to lodge a climate report. Under AASB S2, mandatory climate-related financial disclosures are phased in for entities that prepare annual financial reports under Chapter 2M of the Corporations Act. According to ASIC's Regulatory Guide 280 (RG 280), the phases are:
- Group 1: Reporting periods starting from 1 January 2025.
- Group 2: Reporting periods starting from 1 July 2026.
- Group 3: Reporting periods starting from 1 July 2027.
Each group is defined by size thresholds (revenue, gross assets and employee numbers) or by being a registered corporation under the National Greenhouse and Energy Reporting Act (NGER). Group 1 covers the largest entities. Group 3 captures mid-sized entities based on revenue, asset and employee tests set out in the Corporations Act and ASIC's Regulatory Guide 280.
Separately, the NGER scheme, administered by the Clean Energy Regulator, requires corporations to report greenhouse gas emissions, energy production and energy consumption if they meet a facility or corporate group threshold. The corporate group threshold is 50,000 tonnes of CO2 equivalent, or 200 terajoules of energy produced or consumed.
A mid-sized supplier may or may not be directly caught by AASB S2, depending on its size, legal structure and whether recent threshold changes proceed. But even if it is not caught directly, its large customers are, and they will ask.
The reporting entity is the one that has to get the numbers right. Your job as a supplier is to provide the data they ask for, accurately and traceably. Whether your own business must report is a question for your accountant. This post is about the data.
What you are actually asked for
The request from a customer typically asks for one or more of the following, for a financial year or calendar year:
Fuel. Total litres of diesel, petrol, LPG or natural gas used in vehicles, equipment and heating. Some requests break this down by vehicle type or site.
Electricity. Total kilowatt hours consumed, sometimes with the source (grid, solar, generator).
Freight. Tonnes carried and kilometres travelled, if you are a transport provider. Or the total freight cost and carrier details, if you are a manufacturer or wholesaler using third-party freight.
Refrigerants. Kilograms of refrigerant topped up during the year, by type (R410A, R134a and so on). Relevant for cold storage, food manufacturing and transport with refrigerated vehicles.
Waste. Tonnes sent to landfill versus recycled. This is less commonly requested at this stage but growing.
The customer may give you a spreadsheet template to fill in, or they may ask you to complete a questionnaire through a platform like EcoVadis, IntegrityNext or a simple online form. The data they need is the same either way.
Where the data actually lives
This is the part that causes the scramble. Each data point sits in a different system, and nobody in the business has pulled them all together before.
Fuel cards. If your vehicles use a fuel card (BP, Ampol, Shell), the monthly statement shows litres and cost by vehicle. But company-owned vehicles, hired equipment and bulk fuel for forklifts or generators may not be on the same card. Bulk diesel deliveries arrive as supplier invoices in the accounting file, with litres sometimes in the description and sometimes not.
Electricity. Power bills arrive as PDF invoices, often from several retailers across several sites. The kilowatt hours are on the bill, but they rarely make it into the accounting file in a structured way. The accounting entry is usually just the dollar amount.
Fleet and vehicle records. Odometer readings, fuel logs and maintenance records may sit in a fleet management system, a spreadsheet or a folder of paper logbooks. If you operate a mixed fleet of company trucks, hired vehicles and subcontractor vehicles, working out which fuel is yours and which is the subcontractor's can take some detective work.
Freight invoices. If you use third-party carriers, the freight cost sits in accounts payable. The tonnes and kilometres, which is what the customer needs for the emissions calculation, may or may not be on the carrier's invoice. If they are not, you need the consignment notes or delivery records.
Refrigerant logs. Required under Australian law for equipment containing more than a certain charge of synthetic greenhouse gases. The records should be with your refrigeration contractor or your maintenance team, but they are often on paper.
The accounting file. The total spend on fuel, electricity, freight and waste is in the accounting file (Xero, MYOB, or your ERP). But the accounting file records dollars, not litres, kilowatt hours or kilometres. You need to go back to the source documents — fuel statements, power bills, freight invoices — to get the physical quantities.
Pulling it together without a big project
You do not need emissions software or a sustainability consultant to answer a customer's data request. You need the physical quantities from the records listed above, pulled together into a single spreadsheet with the source documents behind them.
Here is a practical approach.
Start with what accounts already has. Ask your accounts team to run a report from the accounting file for fuel and oil (by supplier), electricity (by site or supplier) and freight (by carrier). That gives you the total spend, which is a useful cross-check even though the customer wants quantities, not dollars.
Go back to the source documents for quantities. Fuel card statements give litres. Power bills give kilowatt hours. Freight invoices or consignment notes give tonnes and kilometres (sometimes). Refrigerant service reports give kilograms topped up. Pull each one into a tab of the same spreadsheet, with the period, the source document reference and the quantity.
Reconcile the quantities to the spend. If fuel card statements say 120,000 litres of diesel and the accounting file shows diesel spend that equates to about 130,000 litres at the average price, the difference is worth finding. It might be bulk deliveries on a different account, hired equipment or a supplier invoice that was coded to the wrong account.
Keep the sources. The customer or their auditor may ask how a number was built. Attach or reference the fuel card statement, the power bill or the invoice for each line. An audit trail matters more than precision: a number you can trace is more useful than a number that is round but unexplained.
Ask the customer what format they need. Some want raw quantities. Some want CO2 equivalent, calculated using published emission factors from the Australian National Greenhouse Accounts Factors workbook (published by the Department of Climate Change, Energy, the Environment and Water). Some just want you to fill in their template. Find out before you spend time on the calculation.
If it becomes a regular request
The first time is a manual exercise. If the request comes back every year, or if several customers start asking, it is worth automating the data collection.
That usually means setting up a regular pull of fuel card data, electricity usage and freight records into a single place, reconciled to the accounting file each month. Not a new system, but a connection between the ones you already have, so the numbers are ready when the request arrives instead of being assembled in a panic.
A reporting dashboard over your accounting file, fleet system and supplier records can show fuel, electricity and freight quantities alongside costs, by site and by period, updated monthly. The same data feeds the customer's request and your own cost management.
If your business also reports under NGER, the data requirements overlap heavily. The NGER reporting post covers the thresholds and the data work for mining, but the data sources — fuel, electricity, production records — are the same for any industry.
What we would not do
We would not tell you whether your business must report under AASB S2 or NGER. That is a question for your accountant or your auditor, using your own financial statements and the thresholds in ASIC's Regulatory Guide 280 and the Clean Energy Regulator's guidelines.
We would not build you a carbon accounting system or prepare your sustainability report. There are specialist consultants and software for that. What we do is the plumbing underneath: connecting your fuel records, power bills, fleet data and accounting file so the numbers are available, reconciled and traceable, whether the request comes from a customer, a reporting obligation or your own management.
If the data is simple enough — one site, one fuel card, one power bill — a spreadsheet and a few hours of accounts time is the right answer. We would tell you that.
Frequently asked questions
What are scope 1, 2 and 3 emissions?
Scope 1 is direct emissions from sources you own or control, like fuel burnt in your trucks or gas used in your factory. Scope 2 is indirect emissions from the electricity you buy. Scope 3 is everything else in your supply chain: the emissions from your suppliers, your freight carriers, your waste, and the use and disposal of your products. The scopes are defined by the GHG Protocol, the international standard that Australian reporting frameworks follow.
Does my business have to report its emissions?
It depends on your size and legal structure. Under AASB S2, mandatory climate reporting is being phased in for entities that prepare annual financial reports under the Corporations Act, starting with the largest entities from 1 January 2025 and reaching smaller entities from 1 July 2027. The NGER scheme has separate thresholds based on emissions and energy (50,000 tonnes CO2 equivalent or 200 terajoules at the corporate group level). Ask your accountant or adviser, using ASIC's Regulatory Guide 280 and the Clean Energy Regulator's website, to confirm where your business sits.
Why is my customer asking for my emissions data?
Because their own climate report requires scope 3 emissions, which include the emissions from their supply chain. To calculate scope 3, they need data from their suppliers: how much fuel you use, how much electricity, how much freight, and so on. You are not reporting on their behalf. You are providing the raw numbers so they can include them in their report.
What format should I provide emissions data in?
Ask your customer. Some provide a spreadsheet template. Some use a platform like EcoVadis. Some just want raw quantities (litres of fuel, kilowatt hours of electricity, tonnes and kilometres of freight) and will do the conversion themselves using the National Greenhouse Accounts Factors published by the Australian Government. Provide the source references alongside the numbers so the figures can be verified.
Do I need emissions software?
For most mid-sized suppliers, no. A spreadsheet that pulls together fuel card data, power bills and freight records, reconciled to the accounting file, is enough to answer a customer's request. Software becomes worthwhile when you have many sites, multiple fuel sources, complex fleet arrangements or a reporting obligation of your own. The first step is getting the data out of the systems you already have.
If a customer has asked for your emissions data and you are not sure where to start, get in touch for a free initial chat. We will look at what data you already have and tell you whether a system connection would help or whether a spreadsheet is the right answer.