ACCC releases final guidance on emissions claims to consumers
Updated: 55 minutes ago
21 October 2026 | Corporate Performance & Accountability
BCSD Australia contributed to the consultation and is exploring how businesses can translate the guidance into effective management practice.
The Australian Competition and Consumer Commission (ACCC) has released its final Making emissions claims to consumers – A guide for business, providing guidance on how businesses can communicate their emissions performance and climate initiatives accurately, transparently and confidently.
Published on 20 October 2026, the guide supplements the ACCC’s existing environmental claims guidance and addresses the application of Australian Consumer Law to consumer-facing emissions claims. The guidance aims to support fair competition, informed consumer choices and greater confidence in claims about emissions reductions and climate-related activities.
What the guidance covers
The ACCC’s central principle is that businesses must consider the overall impression their emissions claims create for an ordinary and reasonable consumer. The guide includes a practical checklist, six prompts and examples addressing:
1. Emissions accounting and substantiation: the completeness, credibility and transparency of information supporting a claim.
2. Clarity and specificity: avoiding overly broad, selective or insufficiently qualified claims.
3. Carbon credits and certificates: communicating their use transparently and avoiding misleading representations about emissions reductions.
4. Double counting: ensuring emissions benefits and associated attributes are not claimed more than once.
5. Business action and legal obligations: distinguishing voluntary improvements from regulatory requirements and broader market changes.
6. Future emissions claims: ensuring commitments and projections are supported by reasonable grounds.
The guide also addresses how emissions-accounting information is communicated in consumer marketing, where technical disclosures or qualifications may not adequately convey the meaning of a claim.
BCSDA’s contribution to the consultation
BCSD Australia provided formal feedback to the ACCC in June 2026. BCSDA supported the overall direction of the proposed guidance and called for additional practical clarification to assist businesses in communicating genuine emissions progress while meeting their consumer-law obligations. Our submission focused on six areas:
1. Emissions boundaries and Scope 3: clearer treatment of material value-chain emissions, exclusions and accounting boundaries.
2. Renewable electricity and certificates: practical clarification of on-site generation, power purchase agreements, certificate ownership and double counting.
3. Emissions reductions, removals and avoided emissions: clearer distinctions between different forms of climate action and their treatment in consumer claims.
4. Practical examples: more examples illustrating how businesses can communicate substantiated emissions progress accurately.
5. Future commitments: clearer expectations concerning the evidence, governance, investment assumptions and milestones supporting future-oriented claims.
6. Implementation tools: a substantiation checklist and decision framework to support consistent decision-making across business functions.
From guidance to effective management practice
The publication of the final guide also raises a broader implementation question: how can businesses translate regulatory guidance into management practices that are effective, repeatable and capable of demonstrating results?
This goes beyond understanding the guidance itself. It involves integrating emissions substantiation and claims governance into existing business processes, defining responsibilities across functions, maintaining reliable evidence, and establishing ways to review and improve performance over time.
BCSDA is now exploring with its Members and through the World Business Council for Sustainable Development (WBCSD) Global Network Partner network how the ACCC’s guidance can be translated into effective practical business implementation approaches.
This exploratory work will consider opportunities to support businesses with the management systems, internal capabilities, accountability arrangements and practical tools needed to make credible emissions claims consistently.
The objective is to move beyond awareness of regulatory expectations towards embedding credible emissions communication in everyday business decision-making and management practice.
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