GrainGrowers welcomes the opportunity to comment on the Improving the efficiency of climate-related financial disclosures consultation paper.
GrainGrowers is a national organisation, driven by its vision: “Thriving Australian growers in vibrant communities.” Australian growers are at the heart of all that GrainGrowers does. Guided by grower insights and on-farm experience, GrainGrowers is delivering best practice, future-focused advocacy and development initiatives for the benefit of the grain industry and regional communities.
While most grain growers are not directly captured by mandatory climate-related financial disclosure requirements, many participate in the value chains of reporting entities and may increasingly be asked to provide climate-related information.
Accordingly, GrainGrowers has a strong interest in ensuring that Australia's climate-related financial disclosure framework remains practical, proportionate and efficient, while avoiding unintended administrative burdens on agricultural businesses that are not reporting entities themselves. The efficiency of the framework will ultimately depend on maintaining an appropriate balance between the information needs of reporting entities and the practical constraints faced by supply-chain participants, such as growers.
GrainGrowers supports reforms that improve implementation certainty, reduce duplication and make greater use of credible secondary data sources. The framework should ensure that reporting obligations remain with reporting entities and do not result in disproportionate compliance costs or administrative burden being transferred to growers through increased requests for Scope 3 emissions information.
GrainGrowers key positions outlined in this submission include:
- Support for maintaining limited assurance requirements to ensure climate-related financial disclosures remain proportionate, practical and aligned with the current maturity of reporting systems, methodologies and assurance markets.
- Support for clear guidance on reasonable value-chain information requests and stronger safeguards to ensure reporting obligations remain with reporting entities and are not transferred to growers through supply-chain data requests.
- Support for continued use of credible secondary data sources and greater investment in Australian-specific emissions factors and centralised datasets to improve reporting quality while reducing administrative burden.
- Opposition to regulatory settings that result in disproportionate compliance costs, reporting obligations or assurance requirements being shifted onto growers.
GrainGrowers looks forward to working with the Treasury on this topic.