Glossary›Regulation, capture and thresholds / Regulation, capture and timing›NGER reporter capture trigger
Glossary term
Cluster B · B17
Tier 1 · differentiator
NGER reporter capture trigger
Definition
Registration under the NGER Act is an independent trigger for mandatory climate reporting. A registered NGER corporation is captured regardless of its revenue, gross assets or employee numbers. Registered corporations above the publication threshold in section 13(1)(a) of the NGER Act fall into Group 1. All other registered NGER reporters fall into Group 2.
Corporations Act 2001 (Cth) s 292A
· emissions threshold limb, by reference to the National Greenhouse and Energy Reporting Act 2007 s 13(1)(a) ·
In force
On this page
In practice
This is the limb that catches entities nobody expects, and it is the single fastest way to be wrong about your own start date.
The size test does not apply on this limb. A registered NGER corporation is captured on the emissions limb alone. A modest-revenue business that happens to run energy-intensive operations (cold storage, transport, quarrying, manufacturing, waste) can sit well below every Group 3 size threshold and still be a Group 2 entity from financial years commencing on or after 1 July 2026, a full year ahead of the private companies it thinks of as its peers.
The Group 1 / Group 2 split turns on the section 13(1)(a) publication threshold. That is the 50,000 tonnes CO2-e corporate group threshold. A registered NGER corporation at or above it is a Group 1 entity, reporting for financial years commencing on or after 1 January 2025. A registered NGER corporation below it is a Group 2 entity.
The trigger is registration, not emissions. The test is whether the entity is a registered corporation under the NGER Act. An entity that has crossed a NGER threshold but has not registered has a NGER problem and a climate reporting problem at the same time, and the first produces the second.
The planning consequence is worth stating plainly for a private business. If your group is registered under NGER, your capture question is already answered and your only remaining question is which group. Do not run the two-of-three size test; it is not the operative test for you. The most common version of this error is a group that runs the size test, concludes it is Group 3 with a 1 July 2027 start, and discovers late that a subsidiary’s NGER registration made it Group 2 with a 1 July 2026 start: losing a year of preparation and a year of activity data it can no longer collect contemporaneously.
What the assurer does with it
The assurer checks NGER registration status as part of establishing the first reporting period, because a registration the entity did not weight correctly changes the group and therefore the assurance scope under ASSA 5010. They ask for the registration record and the most recent NGER report, and they check the reported corporate group emissions against the 50,000 tonne publication threshold to confirm the group determination. They reject a group determination based on the size test alone where the entity is a registered NGER corporation, and they will ask whether any controlled entity in the group is separately registered, because groups frequently do not know.
Commonly confused with
The NGER obligation itself, which is a reporting obligation to the Clean Energy Regulator and is not discharged by preparing a sustainability report. Also confused with the Safeguard Mechanism, which is a facility-level emissions limit and is not a capture trigger for climate disclosure, though a Safeguard facility’s controlling corporation will almost always be a registered NGER reporter and therefore captured anyway.
Timing and relief
Group 1 from financial years commencing on or after 1 January 2025 for registered NGER corporations above the section 13(1)(a) threshold; Group 2 from 1 July 2026 for all other registered NGER corporations. There is no relief on this limb for small size. An entity that deregisters from NGER after falling below the thresholds should confirm the effect on its capture position in writing rather than assume it drops out.
Sources
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2
National Greenhouse and Energy Reporting Act 2007 (Cth)
Federal Register of Legislation
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4
Review status
Review required
Last reviewed
15 September 2026
Editorial pass, unsigned
Reviewer required
NGER practitioner or registered company auditor
Next scheduled review
1 July 2027
Part of
Cluster B, Regulation, capture and thresholds / Regulation, capture and timing
26 terms on who has to report, when their first report is due, and what the regime is built on.
Related terms
The scheme registration under which triggers capture
Where a registered NGER corporation above the publication threshold lands
Where every other registered NGER corporation lands
Related questions
We report under NGER. Does that automatically capture us?
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It can. If you are a corporation registered under the NGER Act and your Scope 1 and Scope 2 emissions are at or above the 50,000 tonne CO2-e publication threshold, you are in Group 1. Every other registered NGER corporation sits in Group 2, regardless of size.
What are the thresholds for Group 1, Group 2 and Group 3?
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Group 1 is two of $500 million revenue, $1 billion gross assets and 500 employees. Group 2 is two of $200 million, $500 million and 250 employees, and Group 3 is two of $50 million, $25 million and 100 employees. All figures are consolidated and you test them every year.
Do we have to do mandatory climate reporting?
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You must prepare a sustainability report if you already lodge a financial report under Chapter 2M of the Corporations Act and you also meet one of the size, NGER or funds-under-management tests in section 292A. Both gates have to be passed: with no Chapter 2M obligation, section 292A never engages however large you are. Which of the three reporting groups you fall into decides which financial year is your first.
Other terms in this cluster
NGER reporter capture trigger