The NSW Environment Protection Authority (EPA) is introducing new climate change requirements for certain holders of Environment Protection Licences (EPLs), with reporting obligations beginning in 2027.
Under these requirements, eligible facilities must report their greenhouse gas emissions and develop a publicly available Climate Change Mitigation and Adaptation Plan (CCMAP). The changes aim to improve emissions transparency, encourage on-site emissions reductions and support NSW’s target of achieving net zero emissions by 2050.
Here’s what you need to know to prepare.
What is a CCMAP?
A Climate Change Mitigation and Adaptation Plan (CCMAP) sets out how a facility will manage and reduce its greenhouse gas emissions and, as adaptation requirements are introduced, address climate-related environmental risks.
The initial requirements focus on emissions mitigation. A CCMAP must identify current emissions, establish emissions reduction goals and outline existing and planned mitigation measures, including how and when actions will be implemented.
Looking ahead, the NSW EPA will develop greenhouse gas mitigation guides for specific sectors. Once published, licensees will be required to benchmark the mitigation actions outlined in their CCMAP against the relevant sector guide.
Facilities should therefore consider how their planned emissions reduction measures align with emerging sector-specific guidance as it becomes available.
Who needs to comply?
The new requirements apply to NSW EPA-licensed premises emitting 25,000 tonnes or more of carbon dioxide equivalent (CO₂-e) annually across Scope 1 and Scope 2 emissions.
Affected facilities may include metal ore mines, coal mines, manufacturing operations, large intensive agricultural facilities such as feedlots and dairies, and large landfills.
If your company holds an EPL, it is worth assessing your facility’s emissions and confirming whether the new requirements apply.
Key CCMAP deadlines
The NSW EPA is phasing in the requirements, with deadlines depending on the type of facility.
31 March 2027: First CCMAPs are due for facilities covered by the Commonwealth Safeguard Mechanism and qualifying coal mines.
31 March 2027: First annual emissions reports are due, covering emissions and energy data from the previous financial year.
31 August 2027: First CCMAPs are due for other affected facilities.
31 March 2030: First CCMAP updates are due. Plans must subsequently be updated at least every three years.
CCMAPs must be published on the licensee’s website, making emissions reduction commitments and planned actions publicly accessible.
How should businesses prepare?
Preparing for CCMAP requirements involves more than compiling an emissions inventory. Companies should begin reviewing their existing data, reporting processes and emissions reduction strategies ahead of the deadlines.
Key steps include:
Review emissions data: Confirm Scope 1 and Scope 2 emissions are accurately quantified and supported by reliable records.
Identify reduction opportunities: Assess existing controls and potential mitigation measures, prioritising opportunities to avoid and reduce emissions before considering offsets.
Establish emissions goals: Develop realistic reduction targets and document the actions, responsibilities and timeframes needed to achieve them.
Leverage existing reporting: Review existing emissions reports, climate strategies and AASB S2 disclosures to identify information that can be reused for CCMAP preparation. Assess any gaps against the EPA’s requirements and document additional information where necessary.
Plan for ongoing reporting: Establish clear processes for collecting, validating and maintaining emissions data to support annual reporting and future CCMAP updates.
Early preparation can help companies reduce the risk of incomplete data, last-minute reporting pressure and gaps between emissions reporting and practical reduction planning.
How Greenbase Can Help
Navigating new environmental reporting requirements requires reliable data, a clear understanding of regulatory obligations and a practical approach to emissions management.
Greenbase supports Australian companies with AASB S2 readiness, greenhouse gas emissions reporting, regulatory compliance and sustainability reporting. Our team can help businesses review their reporting requirements, improve emissions data management and identify practical steps towards more effective emissions reporting and reduction planning.
For companies navigating both CCMAP and AASB S2, aligning these workstreams can help identify reporting gaps early, streamline preparation and make existing climate-related assessments and data work harder.
With the first CCMAP deadlines approaching in 2027, now is the time to assess your obligations and prepare your data and processes.
Need support with emissions reporting or climate-related requirements? Reach out to discuss how we can help your company prepare.
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