Are you ready to publish your mandatory Climate Change Mitigation and Adaptation Plan (CCMAP) for NSW sites with Environment Protection Licences?

Published: May 25, 2026.

Are you ready to publish your mandatory Climate Change Mitigation and Adaptation Plan (CCMAP) for NSW sites with Environment Protection Licences?

A CCMAP is a Climate Change Mitigation and Adaptation Plan. Under new NSW regulation, holders of Environment Protection Licences (EPLs) must publish a CCMAP for any site that has exceeded 25,000 tonnes CO2e of Scope 1 and 2 emissions in the last three years. The plan sets goals for the site's Scope 1 and 2 emissions and outlines how the site will meet them through identified mitigation measures over the next five years, though the regulation does not yet cover adaptation elements.

Key points

  • The first CCMAP is due 31 March 2027 for Safeguard Mechanism sites and coal mines, and 31 August 2027 for all other sites.
  • A 5 year emissions mitigation plan needs to be published on your website and needs forward planning now.

The Requirements

The new regulation requires holders of NSW Environment Protection Licences (EPLs) to publish three things for any site that has exceeded 25kt CO2e of scope 1 and 2 emissions in the last 3 years:

  • An annual emissions report - the most recent NGER report, plus scope 1 livestock and land use emissions for agricultural sites. First report due 31 March 2027.
  • A 5 year forward estimate of scope 1 and 2 emissions that reflects planned production changes and reduction measures. Due 31 March 2027, updated every 3 years.
  • A Climate Change Mitigation and Adaptation Plan (CCMAP) - note the regulation does not yet cover adaptation. The plan sets the goals for the site scope 1 and 2 emissions and outlines how it will meet them. The EPA expects goals to be broadly consistent with NSW's targets:
  • a 50% reduction on 2005 levels by 2030,
  • 70% by 2035, and
  • net zero by 2050.

The plan must also list the mitigation measures the site will implement over the next 5 years, with timeframes and the contribution each makes to the emissions goals. Updates every 3 years.

Further reading Climate change requirements for licensees | EPA

How can Northmore Gordon help?

Public emissions commitments need confidence in your forecasts and in the savings each project will deliver. We build that confidence through emissions forecasting.

For site managers, the cheapest path to lower emissions usually combines well-chosen projects with grants and environmental certificate revenue. Identifying and sizing those projects, and securing external funding, is our strong point. As an accredited certificate provider, we also handle the certificate creation work for you.

Setting credible emissions goals means understanding current and emerging technologies, the energy transition, and the energy and certificate markets. We can guide you through these and build your team's knowledge as we go.

If you already have a plan, we can strengthen it with feasibility studies and funding support. If you don't, we can help you build one.

Talk to Angela Clarke today and learn more about mandatory reporting.

Reporting and compliance context

Confirm the reporting entity and period, current thresholds, regulator guidance, evidence boundary and assurance obligations before applying the dated discussion to a live report.

What is a CCMAP and what does it require NSW Environment Protection Licence holders to do?

A CCMAP is a Climate Change Mitigation and Adaptation Plan. Under new NSW regulation, holders of Environment Protection Licences (EPLs) must publish a CCMAP for any site that has exceeded 25,000 tonnes CO2e of Scope 1 and 2 emissions in the last three years. The plan sets goals for the site's Scope 1 and 2 emissions and outlines how the site will meet them through identified mitigation measures over the next five years, though the regulation does not yet cover adaptation elements.

When are the first emissions reports and CCMAPs due for NSW licensed premises?

First emissions reports are due 31 March 2027. CCMAP publication dates depend on licensee type: 31 March 2027 for Safeguard Mechanism sites and coal mines, and 31 August 2027 for all other licensed premises. Both the five-year forward emissions estimate and the CCMAP must be updated every three years thereafter.

What three deliverables must be published under the new NSW EPL regulation?

For sites exceeding 25,000 tonnes CO2e of Scope 1 and 2 emissions in the previous three years, holders must publish: (1) an annual emissions report based on the most recent NGER report plus Scope 1 livestock and land-use emissions for agricultural sites, due 31 March 2027; (2) a five-year forward estimate of Scope 1 and 2 emissions reflecting planned production changes and reduction measures; and (3) a Climate Change Mitigation and Adaptation Plan (CCMAP) listing mitigation measures with timeframes and their contribution to emissions goals.

What emissions reduction targets should CCMAP goals align with?

The NSW EPA expects CCMAP goals to be broadly consistent with NSW's long-term targets: a 50 per cent reduction on 2005 levels by 2030, 70 per cent by 2035, and net zero by 2050. These targets provide the regulatory framework for setting credible site-level goals, though individual site circumstances, technology options and cost-effectiveness will determine the practical pathway for each licensed premises.

How does Northmore Gordon help organizations establish credible CCMAP emissions goals and reduction projects?

We build confidence in emissions forecasts and project savings through emissions forecasting, opportunity assessment and transition planning. They help identify and size cost-effective emissions reduction projects, secure grants and environmental certificate revenue as an accredited certificate provider, and guide teams on current and emerging technologies, the energy transition and energy/certificate markets. This support connects technical assessment with commercial viability to establish achievable emissions goals backed by verified project pipelines.

What evidence must be assembled before preparing a CCMAP?

Start by checking the licensed premises and applicable requirements, then assemble emissions evidence for the relevant years and document the applicability assessment. Map existing inventories, site plans and transition documents to required outputs; identify missing evidence. Prepare licence details, site boundaries, available energy and emissions records, existing targets, planned projects and governance responsibilities. Distinguish measured, estimated and unavailable information. Keep premises-level evidence even where a portfolio document is being considered, as this supports both the emissions report and the forward estimate.

Can an existing net-zero strategy or sustainability plan be used as the basis for a CCMAP?

An existing net-zero strategy can provide useful material for CCMAP development, but it should be mapped against current regulatory requirements rather than assumed to be sufficient. Voluntary strategies may not align with NSW EPA criteria, emissions thresholds, reporting deadlines or the specific mitigation measures and timescales required under the new regulation. A dedicated CCMAP assessment and planning process is recommended to ensure compliance and credibility.

What is the role of an opportunity register in CCMAP preparation?

An opportunity register is a practical planning document that identifies emissions reduction and climate adaptation opportunities, assigns ownership to responsible parties, tracks implementation dependencies, provides indicative timing for each measure, and monitors progress toward CCMAP goals. It bridges the five-year emissions forecast and the stated CCMAP measures by documenting each project's boundary, estimated energy and emissions effect, assumptions, evidence quality and next decision point, enabling both strategic planning and operational accountability.

Does the NSW CCMAP regulation require adaptation planning in addition to mitigation?

Although the plan is called a Climate Change Mitigation and Adaptation Plan (CCMAP), the current NSW EPA regulation focuses on mitigation and does not yet establish immediate regulatory requirements for adaptation elements. The initial CCMAP focus is on reducing greenhouse gas emissions. However, adaptation considerations may be included voluntarily, and organizations should monitor regulatory guidance as the framework evolves.

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