NGER Reporting Thresholds: Do You Have to Register?

NGER is often the first climate-related obligation an Australian company runs into, sometimes before anyone has looked closely at ASRS. It is the national scheme for reporting greenhouse gas emissions and energy use, and if your corporate group is large enough you are required to register and report each year, whether or not you have started thinking about climate disclosure. Because the obligation is triggered by size rather than by choice, businesses regularly cross the threshold without realising it. This guide sets out the two thresholds that determine whether you are covered, the registration and reporting deadlines that follow, and the way NGER feeds into the newer ASRS climate reporting regime.

What NGER is

NGER, the National Greenhouse and Energy Reporting scheme, is Australia's mandatory framework for reporting greenhouse gas emissions, energy production and energy consumption. It's run by the Clean Energy Regulator under the NGER Act 2007, and it's been in place far longer than the ASRS climate reporting regime. If your business crosses a size threshold, registration isn't optional: you have to apply, report each year, and keep records the Regulator can audit. It underpins a good deal of Australian climate policy, including the Safeguard Mechanism, which builds directly on NGER reporting.

Who has to report: the two thresholds

There are two ways in, and you're caught if you meet either one. The first is the corporate group threshold: total up emissions and energy across everything the controlling corporation controls, and if the group crosses the line, it registers. The second is the facility threshold: a single large site can trigger the obligation on its own, even if the group as a whole is under. Emissions are measured as Scope 1 and 2 CO2-e; energy counts whether you produce it or consume it.

Test at the level of the controlling corporation, across the whole group, the same consolidated logic that catches people out under ASRS. A business that looks small on any one site can still cross the group threshold once every facility, fleet and energy bill is added up.

The two dates that matter

NGER runs on the Australian financial year, 1 July to 30 June. If you cross a threshold during a year, two fixed deadlines follow. Miss the registration date and it's a contravention of the Act, with civil penalties attached, so it pays to work out early whether you're likely to be caught rather than discover it in September.

NGER and ASRS: the overlap that catches people

Being a registered NGER reporter pulls your group into ASRS climate reporting regardless of size, and this is the overlap most first-timers miss. You don't get to sit out the ASRS regime on the revenue, assets and employee tests if you're already an NGER reporter. That draws energy-intensive businesses with modest revenue or headcount straight into mandatory climate disclosure. The connection is not accidental. Your NGER emissions are calculated under the NGER (Measurement) Determination, and the activity data behind them, the fuel, electricity and energy records, is the same data that feeds your ASRS Scope 1 and 2 figures. Building that foundation once serves both regimes, even though each applies its own emission factors: the Measurement Determination for NGER, and the National Greenhouse Accounts Factors for ASRS estimation. If NGER is on your radar, the plain-English ASRS guide is the natural next read, and AASB S1 vs S2 explains the standard you'll report against.

NGER and the Safeguard Mechanism

NGER is the reporting layer. The Safeguard Mechanism sits on top of it for the largest facilities, those whose covered emissions exceed 100,000 tonnes CO2-e a year, and sets a baseline they have to keep emissions below. Every Safeguard facility reports through NGER, but most NGER reporters are well under that line and only carry the reporting obligation, not a baseline. If you're crossing the NGER threshold for the first time, the Safeguard Mechanism almost certainly isn't your concern yet; getting the emissions and energy numbers right is.