24 April 2025.
Introduction
AgForce Queensland Farmers Limited (AgForce) is a peak organisation representing Queensland’s cane, cattle, grain and sheep, wool & goat producers. The cane, beef, broadacre cropping and sheep, wool & goat industries in Queensland generated around $11.2 billion in on-farm value of production in 2022-23. AgForce is the leading voice for Queensland producers and strives to ensure the long-term growth, viability, competitiveness and profitability of these industries. Over 6,000 farmers, individuals and businesses provide support to AgForce through membership. Our members own and manage around 55 million hectares, or a third of the state’s land area. Queensland producers provide high-quality food and fibre to Australian and overseas consumers, contribute significantly to the social fabric of regional, rural and remote communities, as well as deliver stewardship of the state’s natural environment.
AgForce asserts that our producers have a strong track record of adaptation and resilience building to address the challenges of a variable climate. We are open to carefully considered opportunities, including reducing greenhouse gas emissions, when aligned with the needs of our members. However, we have significant concerns regarding the mandatory reporting of greenhouse gas emissions for the agricultural sector.
Position Statement
AgForce opposes the introduction of mandatory Scope 1, Scope 2, and Scope 3 emissions reporting for Queensland's agriculture industries until the appropriate supporting framework, tools and assistance are agreed upon and available throughout our supply chains. This position is based on the following key considerations:
1. Federal Government and Business Under Preparedness: For Group 3 (which start reporting 1 July 2027), the criteria for determining involvement in mandatory reporting is expected to exceed Treasury’s estimate of 1,800 firms. We are concerned the criteria based on meeting at least two of three criteria (1) consolidated revenue $50 million or more, 2) $25 million or more EOFY consolidated gross assets, and 3) 100 or more EOFY employees) will capture a large proportion of agricultural businesses and businesses in agricultural supply chains. Given the highly variable nature of farm income, these businesses may not generate enough profit to permit additional resourcing requirements for reporting. Moreover, larger companies that fall under Groups 1 and 2 must commence reporting from 1 Jan 2025 and 1 July 2026, respectively. To report their emissions, these larger companies will need to request emissions data from upstream actors in their value chains who are not ready to report. Pushing ahead now in the current state of unreadiness risks creating a destabilising influence on the agricultural sector and potentially beyond to impacting our competitive advantage on a global scale. Inaccurate or misleading reports can lead to loss of trust with trading partners and investors. Also, variations in reporting standards and concepts of climate best practice amongst countries could present non-tariff trade barriers – similar to concerns over European Union Deforestation Regulation (EUDR).
2. Inconsistency with the Agriculture and Land Sector Plan. On 23 May 2024, Minister Bowen and Minister Watt announced the government is investing $63.8 million in the Agriculture and Land Sector Plan. This plan recognises the importance of not imposing mandatory emissions reporting requirements for the agricultural sector. Instead, the plan supports voluntary emissions reduction efforts and aims to prepare the sector for future sustainability targets. This is at odds with mandatory scope reporting requirements imposed under the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024, which requires mandatory climate reporting for large businesses and financial institutions in Australia through amendments to the Corporations Act 2001 and the Australian Securities and Investments Commission Act 2001. This mandatory reporting will by extension place involuntary emission targets on agri-businesses of all sizes, to satisfy the requirements of large businesses and financial institutions who are captured by the mandatory reporting.
3. Complexity and Burden: Emissions reporting involves tracking and reporting emissions from direct operations (Scope 1), purchased electricity (Scope 2), and the supply chain (Scope 3). The reporting process is highly immature, leading to complexity and confusion that increases its resource intensity. For many farmers, especially small and medium-sized enterprises captured through the supply chain of larger businesses and financial institutions, these requirements would impose an undue burden, diverting resources away from essential farm and land activities. This situation also risks being anti-competitive, with larger businesses being better positioned due to having greater reporting capacity.
4. Data Accuracy, Availability and Security: Accurate data collection for all forms of scope emissions is currently an unmanageable challenge due to the diverse and dispersed nature of agricultural operations and supply chains. Current methodologies and tools are not yet sufficiently developed to ensure reliable and consistent reporting, and hence suppliers have no confidence in their ability to provide dependable data. Implementing mandatory reporting without robust tools will lead to inaccurate data and misinformed policy decisions. Further, there is a strong probability that dubious reporting will lead to claims and possibly litigation over greenwashing. There are additional concerns with how data could be used contrary to the wishes and best-interests of the data originator. This exacerbates the situation for SMEs who are at greater risk for data safety due to limited resources and less sophisticated defences.
5. Development and Testing of GAF Tools: The Greenhouse Accounting Framework (GAF) tools currently available have a long way to go before they are ready for widespread use. These tools need to be proven by multitudes of producers in real-world scenarios across diverse farming systems throughout Australia. This includes ensuring that producers understand and can effectively use the GAF tools, inputting data accurately to avoid erroneous calculations. Only through thorough testing and validation can these tools become reliable and practical for mandatory reporting. There are also concerns that punitive emission reduction approaches could be applied based upon calculators that were not designed with this end purpose in mind. Another issue is whether Australian GAF tools are consistent with international benchmarks.
6. Co-Development of Tools and Assistance: AgForce believes that the approach to emissions reporting has been rushed and implemented in a top-down manner. For emissions reporting to have meaning and value requires the co-development of frameworks, tools and assistance programs in collaboration with industries and businesses of all types and sizes across the supply chain. This collaborative approach will ensure that the tools are practical, user-friendly, and tailored to the specific needs of the agricultural sector. Only when these frameworks, tools and assistance programs are fit for purpose should mandatory emissions reporting even be considered.
7. Support and Training: Adequate support and training must be provided to farmers to help them understand and implement emissions reporting. This includes access to technical assistance, and educational resources to ease the strain and complexity associated with new processes of data collection and reporting.
8. Compensation for Costs: Farmers should be compensated for the costs associated with emissions reporting. This could be achieved through mechanisms such as tax rebates, higher farm gate prices (to reflect higher costs of reporting or emissions related practice change), or other agreed forms of reimbursement. Ensuring financial compensation will help mitigate the economic impact on farmers and support the sustainability of their operations. It is essential this does not rely on passing costs onto to consumers and increasing the cost of living.
Conclusion
AgForce is committed to working with government, industry stakeholders, and the broader community to develop practical and effective solutions for reporting greenhouse gas emissions in agriculture. We believe that mandatory Scope 1, Scope 2, and Scope 3 emissions reporting should not be introduced until the appropriate frameworks, tools and assistance are fit for purpose, having been co-developed and agreed upon by Queensland's broadacre agriculture industries and our supply chain partners. This approach will ensure that the reporting requirements are feasible, accurate, and meaningful in supporting sustainable farming practices.