EPBC Act Reforms Part 1 - New Emissions Modelling Requirements • earthtrade

The EPBC reform Bills, passed on 28 November 2025, include a new statutory requirement to supply greenhouse‑gas emissions information for projects that proceed to EPBC assessment. In practice, proponents must estimate and report Scope 1 and Scope 2 emissions and include information on measures to reduce and manage those emissions. Some details (formats, thresholds, and timing) will be set in regulations and guidance as the reforms phase in.

What changed?

Historically, project‑level emissions modelling at the federal level was inconsistent and often driven by other frameworks—e.g., the Safeguard Mechanism for large emitters and state/territory requirements (such as under Queensland’s Environmental Protection Act 1994). Under the EPBC reforms, projects that are assessed (controlled actions) must now provide Scope 1 and Scope 2 information as part of the assessment package (Scope 3 excluded).

Scope 1 and Scope 2—refresher

Scope 1 (direct): onsite fuel combustion, explosives, process emissions, methane leakage (e.g., coal mining), or diesel for construction plant.
Scope 2 (purchased energy): electricity (and, where relevant, purchased steam/heat). If a site is off‑grid and generates on‑site, those emissions are generally Scope 1.
Note: the Safeguard Mechanism regulates Scope 1 and does not cover Scope 2.

Where this lands you

If you are already captured by the Safeguard Mechanism or state regimes, you likely already prepare Scope 1 (and often Scope 2) modelling. EPBC now adds an assessment‑stage disclosure obligation and asks you to set out how you’ll manage/reduce those emissions.
For everyone else, factor this into timelines and budgets. While the law doesn’t literally say “life‑of‑project,” agencies and commentators expect modelling and management measures to cover construction and operations over the project life.

The good thing – this doesn’t have to be time consuming or cost intensive. earthtrade, with our partner ARTEH, can enable and undertake this process cost effectively and quickly (as fast as 48hrs!!).