NGER reporting and AASB S2 climate reporting now reach well beyond the big miners. Under ASIC's rules, a company that is a registered corporation under the NGER Act (or must apply to register) falls into Group 2 for climate reporting, for financial years starting on or after 1 July 2026, whatever its revenue. For a diesel-heavy mine or a mining services contractor, the hard part is usually not the report. It is getting fuel, electricity and production data out of separate systems, matching it to the ledger and being able to show how every number was built. This article explains who the rules can reach and what the data work looks like. Whether your business is in scope is a question for your accountant or adviser, not for us.
Who NGER reporting and AASB S2 can reach
This is a summary of the published rules, not legal or accounting advice. Check your own position with your adviser and the regulators' websites.
NGER thresholds
According to the Clean Energy Regulator (cer.gov.au), a corporation must register for the National Greenhouse and Energy Reporting (NGER) scheme if it meets a threshold. The facility thresholds are 25,000 tonnes or more of carbon dioxide equivalent (CO2-e), or 100 terajoules (TJ) or more of energy produced or consumed. The corporate group thresholds are 50,000 tonnes CO2-e, or 200 TJ of energy produced or consumed.
The Clean Energy Regulator says a corporation must apply to register by 31 August after the financial year it first met a threshold, and NGER reports are due by 31 October each year.
Mine sites burn a lot of diesel in haul trucks, loaders and generators, so a single site can approach the energy threshold at a size that would not count as large in any other sense. Your adviser can work out where you sit from your fuel and electricity records, which is one more reason to have those records in order.
The Safeguard Mechanism
The Safeguard Mechanism is a separate scheme. According to the Clean Energy Regulator, it applies to facilities that emit more than 100,000 tonnes CO2-e of covered emissions a year. Most small and mid-tier operations sit well below that, but the emissions data behind it is the same NGER data.
AASB S2 climate reporting in Australia
AASB S2 is the Australian standard for climate-related financial disclosures. ASIC's Regulatory Guide 280 sets out who must prepare a sustainability report and when. In summary, according to RG 280 (Table 2):
- Group 1 (periods from 1 January 2025): large entities meeting two of three size tests, plus NGER registered corporations in a group that meets the NGER corporate group emissions threshold.
- Group 2 (periods from 1 July 2026): entities meeting two of revenue of 200 million dollars or more, gross assets of 500 million dollars or more, or 250 or more employees, or entities that are registered corporations under the NGER Act or are required to apply to be registered.
- Group 3 (periods from 1 July 2027): entities meeting two of revenue of 50 million dollars or more, gross assets of 25 million dollars or more, or 100 or more employees.
These obligations apply only to entities that must prepare an annual financial report under Chapter 2M of the Corporations Act. RG 280 also says that Group 3 entities that find they have no material climate-related risks or opportunities can lodge a statement saying so, with an explanation of how they decided.
For a mid-tier miner with a 30 June year end, a Group 2 start means the 2026–27 financial year, which is already under way. Mining services contractors may not be caught directly, but miners that are caught will ask their contractors for fuel and emissions data for their own reports.
Where the data actually comes from
Climate reporting for a mine or a mining contractor is built from ordinary operating records. The trouble is that they live in different places:
- Fuel. Bulk diesel deliveries are invoiced into the accounts. Fuel issued to each machine is recorded in a fuel management system, on dockets or in a spreadsheet. Light vehicles use fuel cards with their own statements.
- Electricity. Power bills arrive as supplier invoices, sometimes several per site, with usage buried in a PDF.
- Contractor fuel. Some contractors bring their own fuel, some draw from your tanks, and the arrangement changes from contract to contract.
- Production. Tonnes mined, moved and processed sit in production or weighbridge systems, and you need them to show emissions per tonne.
- Site and facility structure. NGER reports by facility. Your ledger reports by cost centre, entity and site. The two don't always line up.
In most businesses, someone exports from each source at year end, pastes it into a workbook, converts litres and kilowatt hours, and hopes the totals agree with the accounts. That works until someone asks how a number was built, or the person who built the workbook leaves.
What good looks like: reconciled and traceable
The aim is not new emissions software. Specialist tools and consultants handle the calculations and the report itself. The aim is to make the data going into them complete, matched to the ledger and traceable.
Pull from the source systems
Fuel issues, bulk fuel invoices, fuel card statements, electricity bills and production tonnes are collected from the system where each is recorded: the ERP or accounts (Xero, MYOB, MYOB Acumatica, Pronto, Business Central and so on), the fuel system and site records. Each record keeps its date, site, machine or meter, and source document.
Reconcile to the ledger
Litres issued on site should agree with litres bought. Electricity usage should tie to the invoices paid. Any difference is shown each month, not discovered at year end. Because AASB S2 disclosures sit beside the financial report, the climate numbers and the accounts need to agree.
Keep an audit trail
Every reported figure should trace back to the dockets, invoices and readings behind it, with a record of any manual adjustments and who made them. That is what an auditor, an adviser or a customer asking for your emissions data will want to see.
Report monthly, not once a year
When the data flows each month, NGER, AASB S2 and customer requests become a matter of running a report. A reporting dashboard over Xero or MYOB or a wider business intelligence setup can show fuel, power and emissions per site and per tonne next to the financials.
When you don't need a project
If you have one site, one fuel supplier and one power bill, a well-kept spreadsheet and your adviser may be all you need. The case for connecting systems grows with the number of sites, contractors, fuel sources and entities, and with how often people ask for the numbers.
Frequently asked questions
Does AASB S2 apply to my mining company?
It depends on your size, whether you must report under NGER and whether you prepare financial reports under Chapter 2M. ASIC's RG 280 sets out the groups. Ask your accountant or adviser to confirm your position.
What is the NGER reporting deadline?
According to the Clean Energy Regulator, NGER reports are due by 31 October each year, and registration is due by 31 August after the financial year in which a corporation first met a threshold. Check cer.gov.au for current dates.
Is NGER data the same as the data needed for AASB S2?
Not entirely. NGER data is a strong starting point for scope 1 and scope 2 emissions, but AASB S2 has its own requirements. Your adviser can tell you what extra is needed.
We are a mining contractor. Why would we need emissions data?
Miners preparing climate reports may ask their contractors for fuel use and emissions on their sites. Capturing fuel per job or per machine from your dockets makes those requests much easier to answer.
Can you prepare our NGER report?
No. We don't prepare NGER reports or give compliance advice. We connect your systems so the fuel, power and production data your adviser or emissions provider needs is complete and matches your accounts.
If your emissions data is built from exports and spreadsheets each year, book a free initial chat. We'll look at where your fuel, power and production data sits and tell you honestly whether it needs a project. See also our mining services page.