Sustainability reporting helps stakeholders assess sustainability risks, evaluate sustainability performance and improve sustainability policy. The field continues to evolve, and organisations now face a wide range of reporting initiatives across both mandatory and voluntary reporting environments. Sustainability reporting can cover many humanitarian and ecological aspects, but the following conversation focuses on greenhouse gas emissions and climate change.
Q: Malcolm, you’ve worked across a pretty diverse range of industries. What has your career in sustainability involved?
I’ve specialised in carbon management since 2010 and delivered projects across Australia, Asia and Europe. My work has included greenhouse gas accounting, climate change risk assessments, environmental impact assessments, management planning, emissions reporting, R&D, auditing and training.
A lot of my experience was developed on large projects in the resources sector. These projects are technically complex and have significant compliance requirements. I’ve also worked with local governments, NGOs and progressive organisations that have made voluntary commitments to improve emissions performance and climate resilience.
Q: Can you explain how emissions compliance reporting has changed over time in Australia?
The Australian mandatory emissions reporting landscape has been evolving since 1998. The National Pollutant Inventory (NPI) began in 1998 and focuses on tracking polluting substances released into the air, land and water. The NPI has expanded over time and currently requires more than 4,000 facilities to disclose emissions of up to 93 different substances. At one point, the NPI also included greenhouse gas emissions.
In 2008, the National Greenhouse and Energy Reporting Scheme (NGERS) was introduced to track greenhouse gas and energy metrics from large organisations. NGERS now requires more than 5,000 Australian facilities to report greenhouse gas emissions and energy data. I’ve been lucky enough to help some of Australia’s largest emitters meet and exceed their NGERS and NPI reporting requirements.
Changes to the Australian Corporations Act in September 2024 created new mandatory reporting requirements for Australian companies. The new requirements began to take effect in 2025, and by 2027, all Australian companies with a legal requirement to prepare a financial report will also be required to prepare an annual sustainability report. The sustainability report must include greenhouse gas and climate risk disclosures.
Q: How is the sustainability report different from NGERS?
The sustainability report and NGERS are designed for different purposes and target audiences. NGERS was designed to help the Australian Government develop and evaluate policy and underpin mitigation programs such as the ETS and the Safeguard Mechanism. NGERS captures energy and greenhouse gas emissions data (Scopes 1 and 2) from Australia's largest emitters.
The sustainability report is based on a framework developed by the Task Force on Climate-related Financial Disclosures (TCFD). It is designed to help investors evaluate climate-related risks. The sustainability reporting requirements apply to a much wider range of companies than NGERS, and the report must also disclose climate-related risks and a broader range of emissions (Scopes 1, 2 and 3).
The sustainability report must be prepared in accordance with the Australian Sustainability Reporting Standard AASB S2, which allows companies to use a slightly more generalised set of greenhouse gas accounting methods than NGERS.
Both NGERS and sustainability reporting have similar audit requirements.
Q: You mentioned different standards. Could you elaborate?
Greenhouse gas reporting standards and methodologies help provide transparency and credibility in emissions disclosures. Uniform standards and methodologies allow reported emissions to be compared, benchmarked and audited.
Emissions reported under NGERS must be calculated in accordance with the National Greenhouse and Energy Reporting (Measurement) Determination. The NGER Measurement Determination provides a very detailed methodology that has been developed specifically for Australian industry.
Sustainability reports must comply with AASB S2, which requires emissions disclosures to follow the Greenhouse Gas Protocol. The Greenhouse Gas Protocol is a widely used global standard that has evolved since 2001.
The Greenhouse Gas Protocol and the NGER Measurement Determination overlap in many ways. However, the Greenhouse Gas Protocol provides greater flexibility and is better suited to global supply chains.
It’s important to note that AASB S2 does allow organisations to use their NGERS data in their sustainability reports. Large organisations that already report under NGERS are not required to recalculate their greenhouse gas emissions using the Greenhouse Gas Protocol.
Q: Can you give an example of where you’ve used different greenhouse gas accounting standards?
I’ve done a lot of NGERS reporting for Glencore Coal, Bechtel (WA), Baralaba Coal, Aurelia Metals and the Real Pet Food Company. All these projects involved preparing greenhouse gas and energy use disclosures based on the NGER Measurement Determination. In a few instances, reported emissions were audited by the Australian Government to ensure they complied with the NGER Measurement Determination.
I’ve also prepared many greenhouse gas inventories using the Greenhouse Gas Protocol. For example, Kestrel Coal engaged me to identify mitigation options for its underground mine. The project involved developing a greenhouse gas inventory using the GHG Protocol and evaluating potential mitigation projects.
Other examples include greenhouse gas impact assessments. I’ve prepared more than 40 greenhouse gas and energy assessments for major projects. In all cases, the assessments have been completed using the Greenhouse Gas Protocol.
Q: And what does the climate change risk assessment involve?
The new sustainability report must include a climate change risk assessment. This means reporting organisations must disclose their physical and transition risks associated with climate change. Physical risks include events such as floods, sea level rise, heatwaves, droughts and cyclones. Transition risks arise from shifts in policy, law, technology, markets and reputation.
The risk assessment seeks to test the impact of climate risks on operations and financial value. It considers how physical and transition risks affect each element of a supply chain. The assessment must consider a limited-warming scenario and a high-warming scenario.
The limited-warming scenario is likely to generate lower physical risks but higher transition risks, as it requires significant global action. The high-warming scenario is the reverse, with higher physical risks and relatively lower transition risks.
The climate risk assessment should help investors understand the potential impacts of climate change on company value.
Q: What advice would you give a business preparing for its next sustainability report?
Start early. Understand the reporting requirements, identify the issues that are material to your business and establish what information you already have.
Then look at the gaps. Do you have reliable emissions data? Are responsibilities clear? Can you explain how climate-related risks are assessed and managed? Are the right people involved in reviewing and approving the information?
It’s also worth thinking about the report’s audience from the beginning. What do investors and other stakeholders need to understand about your business, its risks and its priorities?
Good sustainability reporting is the result of good preparation. The report itself is only one part of the process.
Q: Your experience also extends beyond compliance reporting. What other projects have you found particularly interesting?
I’ve done a lot of work in the voluntary carbon space. I worked with the City of Sydney to develop a carbon-neutral strategy. I helped the City measure its greenhouse gas emissions, evaluate mitigation options and develop a five-year strategy to manage the financial and environmental risks of achieving carbon neutrality.
I worked with the Local Government and Shires Association of NSW to develop a climate change training program to assist local governments in planning for climate change. The training program included step-by-step guides for assessing climate change risks and preparing greenhouse gas inventories. Much of the inventory guidance was based on the Greenhouse Gas Protocol. The workshop package was provided to more than 150 local councils in NSW.
I assisted the Office of Environment and Heritage in developing and delivering a greenhouse gas accounting and carbon management training program. Through the program, I helped businesses develop reporting boundaries, prepare greenhouse gas inventories and develop greenhouse gas management plans. I delivered carbon management training to businesses such as Buildcorp, the Sydney Markets, Rockdale Beef, Casella Wines, De Bortoli Wines, Geofabrics Australia, Murrumbidgee Irrigation, Luxottica and Compass Housing.
Q: With all this technical work, how important is the way a business communicates its sustainability performance?
It’s very important. The analysis needs to be technically sound, but the findings also need to be understood by the people making decisions and the stakeholders relying on that information.
A sustainability report should explain what matters to the business, how it is managing its opportunities and risks, and what progress it is making. Investors may be particularly interested in the implications for strategy, governance and long-term performance, while employees and other stakeholders may have different priorities.
The challenge is to make complex information accessible without oversimplifying it or making claims that the evidence doesn’t support.
That means connecting the data with the business strategy and being clear about both progress and the work still to be done.
Q: How does working with Ink complement your sustainability expertise?
My focus is on the technical and strategic side of sustainability: understanding emissions, assessing climate risks, developing frameworks and helping businesses make informed decisions.
Ink brings expertise in corporate communications, investor relations and reporting. That’s a valuable complement because the technical work needs to be translated into clear, credible information that makes sense to different audiences.
Whether it’s a sustainability report, an investor presentation or broader corporate communications, the aim is to ensure the information is accurate, the messaging is consistent and the company's story reflects the substance behind its sustainability work.
Q: Finally, what do you enjoy most about this work?
I enjoy solving problems and helping organisations make sense of complex issues. Sustainability can involve a lot of technical information, competing priorities and uncertainty.
Working through those challenges, identifying practical options and helping organisations make better-informed decisions is what makes the work rewarding.
Sustainability reporting is about getting the detail right — and communicating it well.
At Ink Communications, we bring together sustainability strategy, reporting and corporate communications to help businesses explain their priorities, risks and progress clearly and credibly. If your organisation is developing its sustainability framework or preparing its next report, coffee’s on us!
