For NFF, the shortcomings are particularly evident in its failure to adequately account for the consequential impacts of mandatory Scope 3 disclosures both on reporting entities and on businesses operating outside the Group category thresholds. The potential for these requirements to generate significant additional information requests and compliance costs throughout agricultural supply chains was foreseeable and repeatedly raised by NFF during the development of the framework. These concerns were not sufficiently addressed at the outset, and the early implementation of the regime has begun to demonstrate the very consequences we repeatedly warned of despite Scope 3 not formally kicking-in yet.
NFF has already identified instances where information requests and auditing practices have gone beyond the requirements enshrined in legislation, placing unnecessary (and potentially coercive pressure) on producers to collect and disclose information at their own cost, despite having no corresponding statutory reporting obligation to do so (Consultation Question 4). It is therefore both timely and prudent for the Commonwealth to examine opportunities to improve the regime’s efficiency and address the indirect compliance burden being imposed on agricultural producers and the broader supply chain.
NFF’s full submission can be found here.