NFF does not support a policy architecture that increasingly relies on agriculture to supply lower-cost offsets for residual emissions generated elsewhere in the economy. Agriculture cannot be taken for granted to do the heavy lifting for other sectors that carry on as business-as-usual, particularly where those sectors have access to more established and mature opportunities to reduce emissions at-source. The availability of comparatively lower-cost land-sector abatement should not become a substitute for genuine industrial decarbonisation or entrench a compliance model in which residual emissions are routinely shifted onto agricultural landscapes. We understand that this Review has raised separate questions as to how Safeguard settings can further support and strengthen incentives for greater on-site abatement, and that is supported. For instance, there may be opportunities to pull complementary policy levers beyond the Safeguard itself to accelerate on-site decarbonisation as baseline requirements tighten, including through targeted co-investment or public-private partnerships to enable new infrastructure (as is the case internationally). However, the broader test must remain whether the transition is delivering genuinely just outcomes for regional communities, rather than allowing the residual emissions task of other sectors to be shifted onto agriculture and food and fibre production.
From that perspective, NFF supports strengthening targeted safeguards for large land-sector projects that may materially affect agricultural production or regional communities under the Carbon Credits (Carbon Farming Initiative) Rule 2015. This includes extending the existing 30% threshold for Ministerial consideration to environmental planting projects on agricultural land, provided it is applied flexibly and does not constrain landholder decision-making or property rights.
NFF also recommends that the Review consider an explicit mechanism to contain the extent to which Safeguard compliance is met through land-sector ACCUs over time. This approach is consistent with the proportionality principle Treasury has proposed in its parallel consultation on Climate-Related Financial Disclosure (CRFD), which similarly seeks to prevent large reporting entities from placing disproportionate and open-ended compliance burdens on smaller value-chain participants, including agricultural suppliers.[1]
The NFF’s full submission can be found here.
[1] August 2026, Australian Government, The Treasury: Improving the Efficiency of Climate-Related Financial Disclosures