Three sets of rules can apply to the same emissions. The GHG Protocol Corporate Standard (2004) sets the method. AASB S2 requires that method for your climate disclosure, with some changes. The National Greenhouse and Energy Reporting (NGER) scheme is a separate law with its own boundary.
How do the three compare?
GHG Protocol Corporate Standard | AASB S2 | NGER | |
Reporting entity | The company decides | The entity that prepares the financial report | The controlling corporation: the top Australian company in the group |
Consolidation approach | Equity share, financial control or operational control | Your choice of the same three. Disclose which one | Operational control only |
Scopes | Scope 1 and 2 required. Scope 3 optional | Scope 1, 2 and 3. Scope 3 can be left out in the first year (C4(b)) | Scope 1 and 2, plus energy produced and consumed |
Geography | All operations, in every country | All operations of the reporting entity, in every country | Australian facilities only |
Period | The company decides | The same period as the financial statements | 1 July to 30 June |
Methods and factors | GHG Protocol methods. Factors are not prescribed | GHG Protocol Corporate Standard. NGER methods are allowed for the part of the entity NGER applies to (B24). Disclose the method and the reason (B28) | Methods and factors in the NGER Measurement Determination |
Global warming potential (GWP) | 100-year values from an IPCC assessment report | 100-year values from AR6, the IPCC Sixth Assessment Report (AusB22.1). Factors already in CO2e need not be recalculated (B22). NGER values for the NGER part only under AASB S2025-1 | The values set in the NGER legislation |
Why can your NGER group and your AASB S2 group differ?
There are four reasons.
A different reporting entity. NGER reports at the controlling corporation. AASB S2 reports at the entity that prepares the financial report. These can be different companies in the same group. Check the name on your NGER registration and the name on your annual report.
A different approach. NGER counts the facilities your group has operational control of. AASB S2 counts what your chosen consolidation approach counts.
A different geography. NGER covers Australian facilities only. AASB S2 covers your overseas operations too.
Different scopes and period. NGER has no Scope 3. The NGER year is always 1 July to 30 June.
What does the difference look like for one group?
Bluegum is not an NGER reporter. Suppose its group crossed an NGER threshold. These items would land in different places.
Item | NGER (operational control) | AASB S2 (Bluegum, financial control) |
Owned Dandenong distribution centre and 8 owned trucks | Scope 1 and 2 | Scope 1 and 2 |
12 utes on operating leases, which Bluegum drives and fuels | Scope 1 | Scope 3 Category 8 |
6 stores on operating leases, which Bluegum runs and holds the energy accounts for | Scope 2 | Scope 3 Category 8 |
Coastline Kayaks factory (50% joint venture under joint control, equity-accounted), if Bluegum staff ran it | 100% in Scope 1 and 2 | 50% in Scope 1 and 2, because Bluegum shares joint control |
Bluegum NZ Ltd, if it traded | Not covered, because NGER is Australian only | 100% in Scope 1 and 2 |
Purchased goods, freight, travel and other value chain emissions | Not covered | Scope 3, in the categories you find material |
When the two boundaries differ, you have a dual boundary. Keep both lists, and record why each item is in or out of each.
Can you reuse your NGER figures in your AASB S2 report?
Yes, for the part of your entity that NGER applies to. Which rules apply depends on your reporting period.
AASB S2025-1 (December 2025) lets you measure the part of your entity that NGER covers with NGER methods and NGER GWP values.
AASB S2025-1 applies to annual periods beginning on or after 1 January 2027. You can apply it earlier, but you must disclose that you have (C1B).
Before you apply AASB S2025-1, paragraph 29(a)(ii) and B24 already let you use a method that NGER requires for the part it covers. Use AR6 GWP values for that part (AusB22.1).
In your first AASB S2 year, C4(a) also lets you keep the method you used the year before.
Disclose the method you used and why you chose it (B28).
If you start to use the relief after an earlier AASB S2 year, adjust the comparative (C6).
Reuse changes your boundary. NGER uses operational control, so the part you reuse follows operational control. This applies whatever approach you chose for the rest of the group. In the Bluegum example, reused NGER figures put the utes and stores in Scope 1 and 2, not in Category 8.
The relief applies only inside your AASB S2 reporting entity. It is not settled whether it can bring in a facility that your group operates but does not consolidate. For such a facility, use your chosen approach and disclose the judgement. This is a judgement. Record it in your boundary document and discuss it with your auditor. In the Bluegum example, the Coastline Kayaks factory stays at 50% in Scope 1 and 2 under financial control.
If you reuse NGER figures:
State in your Basis of Preparation which part uses NGER figures, that it follows operational control, and why you chose this method (B28).
Count each facility once. A facility in your NGER figures must not also appear in Category 8 or Category 15.
Remove from your spend-based Scope 3 any contractor services whose fuel is already in an NGER facility total. Otherwise that fuel is counted in Scope 1 and again in Category 1.
Check that any NGER estimation shortcuts for small sources are also immaterial under AASB S2.
For how this affects your choice of approach, see Equity share, financial control and operational control compared.
What is the top-up?
The top-up is everything your AASB S2 report needs that your NGER report does not give you:
Scope 3. NGER does not cover it.
Operations outside the NGER report. These are overseas operations, entities in your AASB S2 group that are outside the NGER group, and facilities your approach counts but another company operates.
A different period. If your financial year does not run from 1 July to 30 June, re-cut the data to your financial year.
Scope 2 contract information. AASB S2 requires location-based Scope 2 and information about your contractual instruments, such as renewable electricity certificates.
For example: an NGER report shows 4,200 tCO2e. Add a New Zealand subsidiary at 300 tCO2e and a share of a joint operation, run by the partner, at 150 tCO2e. AASB S2 Scope 1 and 2 is 4,650 tCO2e, before Scope 3.
What this means in Avarni
Avarni has one assessment per financial year. If your financial year is not 1 July to 30 June, filter the Emissions Hub to 1 July to 30 June to get NGER-year figures. Then use Download as Excel.
To report the NGER part separately, create a custom field under Settings › Custom Fields, such as "NGER report" with the valid values Yes and No. Set it on each row. Then filter or group by it in the Emissions Hub.
Settings › Global Warming Potential holds one version for your whole organisation. It cannot apply NGER values to one part only. See Global warming potential: AR5, AR6 and NGER.
There is no operational control field in Avarni. Record the NGER and AASB S2 treatment of each facility in your boundary document. See What goes in your boundary document.