Are you ready to pass an NGERS/GHG Audit as required for Sustainability Reporting?
Australia’s mandatory climate disclosure framework (AASB S2) marks a structural shift in corporate accountability. Large entities and significant National Greenhouse and Energy Reporting Scheme (NGERS) reporters must now disclose Scope 1 and Scope 2 greenhouse gas (GHGGreenhouse gases trap heat in the atmosphere. They all have different global warming potentials (GWP) over different time frames, the higher the number, the worse the impact. For simplicity of accounting everything is referenced back to carbon dioxide which has a global warming potential of 1. There are over 200 GHGs listed in the IPCC fifth assessment report, a sample are below. Note that in current carbon accounting standards the 100 year GWP is used. Greenhouse gas 20 year GWP100 year GWPCarbon dioxide CO211Methane CH48428Hydrofluorocarbon HFC-134a37101300Chlorofluorocarbon CFC-1169004660Nitrous Oxide N2O264265Sulfur hexafluoride SF617,50023,500) emissions within their Sustainability Reports.
These disclosures are no longer simply a compliance exercise. Under ASSA 5010, reported emissions must be subject to:
• Limited assurance in the initial reporting years, and
• Reasonable assurance in subsequent years – a far more rigorous audit standard.
For many organisations, the real challenge is not disclosure. It is audit readiness.
The Hidden Risk: The 4-Month Reporting Window
Entities typically have only four months between the end of the reporting period and submission of the Sustainability Report. In practice, this window can narrow quickly due to:
• Delays in receiving final energy invoices
• Data validation and reconciliation processes
• Internal governance reviews
• Auditor queries and evidence requests
Without a well-designed GHG inventory framework already embedded, organisations risk significant pressure, remediation work, and potential reputational exposure.
What Auditors Will Expect
External assurance providers will not simply test your final emissions number. They will examine the integrity of your entire GHG management framework.
A defensible Basis of Preparation must clearly demonstrate:
• Defined operational boundaries
• Complete identification of all relevant emission sources
• Collection and retention of auditable raw data
• Accurate application of emissions factors and calculation methodologies
• Controlled data management and documentation practices
In addition, auditors will scrutinise complex or judgement-heavy areas such as:
• On-site waste treatment and waste-to-energy processes
• Small or irregular fuel use (equipment, fleet)
• Refrigerant and switchgear gas management
• Emissions generated by on-site contractors
• Scope 2 market-based accounting and contractual instruments
These are often the areas where assurance findings arise.
Northmore Gordon’s Role: Specialist GHG Advisors – Not Auditors
Northmore Gordon are not auditors, and we do not provide external assurance services.
Instead, we specialise in the development, technical review, and strengthening of GHG inventories and NGERS submissions. Our role is to ensure your emissions framework is robust, defensible, and audit-ready before it is examined by official assurance providers.
We work alongside sustainability, finance, and operational teams to:
• Review and refine your Basis of Preparation
• Stress-test boundary definitions and emission source completeness
• Identify data gaps and control weaknesses
• Validate emissions calculations and methodologies
• Strengthen documentation and audit trails
• Improve governance processes ahead of assurance engagement
By conducting a pre-assurance technical review of your most recent GHG inventory or NGERS submission, we provide practical, targeted recommendations, giving your organisation time to address issues before the formal audit process begins.
From Compliance to Confidence
As climate reporting matures, the market will distinguish between organisations that merely report emissions and those that demonstrate robust, auditable systems.
Audit readiness should not be an afterthought compressed into a four-month reporting window. It requires early preparation, technical rigour, and clear documentation.
Northmore Gordon helps organisations move from reactive compliance to confident, defensible disclosure, ensuring you are prepared when official auditors commence their assurance procedures.
To see if you’re audit ready, contact Senior Consultant Nina Wissenden
