Commonwealth Climate Disclosure Pilot

The Pilot gives practical effect to the first phase of the Commonwealth Climate Disclosure Reform that was agreed by Government and publicly released on 28 November 2023.

Detail on the policy architecture is detailed on the Commonwealth Climate Disclosure Policy section of the website.

The Commonwealth Climate Disclosure Reform is being rolled out over four years.

The Commonwealth Climate Disclosure Policy section of our website outlines the categorisation criteria for each tranche. If you are still unsure when disclosure commences for your entity, feel free to email us at climateaction@finance.gov.au for assistance.

Your entity may also choose to opt-in to the CCD Pilot.

Please review the Pilot Guidance and supporting documentation and email climateaction@finance.gov.au to schedule a meeting to discuss. Participation in the Pilot will need to be confirmed in writing.

The Pilot provides an opportunity for entities to build their climate disclosure capability and prepare for the full CCD Requirements as they are brought into effect from FY2024-25.

The Pilot draws upon related polices and work underway across government to build more climate resilient and sustainable Commonwealth entities and Commonwealth companies. This includes the Net Zero in Government Operations Strategy, APS Net Zero Emissions Reporting Framework, Climate Risk and Opportunity Management Program and Commonwealth Risk Management Policy. Familiarising yourself with these relevant policies and frameworks will assist you in understanding the Commonwealth Climate Disclosure Reform.

We have a range of resources that have been developed to support you in preparing your Pilot disclosure, including:

• a Pilot Metrics and Targets Factsheet that outlines the whole-of-Australian-Government approach and methodology for emissions reporting under the APS Net Zero Emissions Reporting Framework, as well as information about the APS Net Zero by 2030 target.
• an illustrative example of a limited climate disclosure indicative of the standard required to satisfy the Pilot criteria.
• a GovTEAMS community that provides a collaborative group learning environment for departments and other entities participating in Commonwealth Climate Disclosure and other Climate Action in Government Operations activities more broadly. To join, email climateaction@finance.gov.au.

In addition to the above, the Climate Action in Government Operations Unit can perform thematic reviews of entities’ climate disclosures made as part of the Pilot, prior to publication in annual reports. Contact climateaction@finance.gov.au for further information.

The Department of Climate Change, Energy, the Environment and Water (DCCEEW) has also developed a range of tools and guidance to support entities to identify, assess, prioritise and manage their climate-related risks and opportunities, as part of its Climate Risk and Opportunity Management Program. These include (but are not limited to):

• Climate Risk and Opportunity learning and development modules on APS Academy
• Climate Risk Management Guides, including the Organisation Application Guide.

You do not need to have a Chief Sustainability Officer (CSO), however you are encouraged to consider appointing a CSO as per the Net Zero in Government Operations Strategy. The role of the CSO is to champion initiatives that support climate action in government operations, such as emissions reporting, APS Net Zero (including implementation of emissions reduction actions), climate risk management and disclosure. The CSO responsibilities could be augmented to an existing role or it could be a standalone role, depending on your entities’ circumstances. We are in the process of setting up a CSO network to support senior officials in this role, including championing climate-related risks and opportunities across the organisation.

The Pilot has been designed to allow entities to focus on developing the foundations and capability needed to build comprehensive climate disclosures over time. The Pilot does this by focusing in on certain climate-related governance, risk management, and metrics and targets criteria that will enable and prepare entities to better respond to strategy criteria in future reporting years of the Commonwealth Climate Disclosure Reform.

Entities should be aware that from the 2024-25 reporting period, the more fulsome CCD Requirements will be phased in for all in-scope entities. The Requirements will include expanded criteria in relation to governance, risk management, metrics and targets, as well as additional strategy criteria.

The CCD Requirements are expected to be finalised in mid-2024.

Entities are expected to outline the progress in completing your climate risk and opportunity assessment in accordance with the Climate Risk Management Organisation Application Guide. For example, if an entity had completed three out of the six steps, that level of progress would be disclosed. There is no requirement for an entity to have completed their assessment for the Pilot, or to report the outcomes of their climate risk assessment if completed.

We have developed a Pilot Metrics and Targets Factsheet to assist departments to address the Pilot metrics and targets criteria. The Factsheet has been specifically written for departments in the Pilot. However, it can also be used by entities voluntarily opting into the Pilot (see below for consideration).

The Factsheet supplements the APS Net Zero Emissions Reporting Framework, which all Commonwealth entities and Commonwealth companies must follow when reporting their greenhouse gas emissions. It also reflects the APS Net Zero in Government Operations Strategy, which describes the approach to implementing the APS Net Zero by 2030 target. The APS Net Zero by 2030 target includes non-corporate Commonwealth entities, with corporate Commonwealth entities and Commonwealth companies having the option to declare participation. The Factsheet aligns the details of the APS Net Zero Emissions Reporting Framework and the APS Net Zero by 2030 target with the criteria required to be disclosed in the Commonwealth Climate Disclosure Pilot.

In the case where an entity has voluntarily opted-into the Pilot but is not part of the APS Net Zero by 2030 target, the entity needs to be aware that the ‘Target’ part of the Factsheet is not applicable and will have to disclose its own information based on its emissions reduction target. This resource aims to reduce the reporting burden for departments by consolidating the APS-wide approach to metrics and targets which can be referred to, rather than replicated, within the departments’ Pilot climate disclosure. Refer to the Example Disclosure to see how this resource can be used within a Pilot disclosure by a fictional Department of State.

No, the Pilot will not be subject to a specific climate disclosure audit and assurance regime. We will be conducting an evaluation of the Pilot in late 2024. Evaluation outcomes will be used to inform the implementation of the Commonwealth Climate Disclosure Requirements in FY2024-25.

The Climate Action in Government Operations Unit is designing an audit and assurance regime in consultation with the Australian National Audit Office (ANAO) and affected entities that will come into effect in future reporting years of the Commonwealth Climate Disclosure Reform.

You are welcome to email us via climateaction@finance.gov.au. We will also be approaching entities involved in the Pilot directly for additional feedback to inform our evaluation process.