Climate Active Certification: Is It Still Worth It Under ASRS?

A sustainability manager at a commercial property group asked us recently whether she should renew her Climate Active certification. She'd been paying roughly $35,000 a year — licence fees, consultant fees, offset purchases — and now that ASRS was forcing her to disclose emissions anyway, she wanted to know: what's this actually buying me?

We didn't have a clean answer. And honestly, we're not sure anyone does right now.

Climate Active — Australia's government-backed carbon neutral certification — is in a strange spot. The program had over 700 certifications in late 2023. As of March 2025, that number was down to 540. Telstra pulled out in June 2024, publicly stating it would stop using the term "carbon neutral" altogether and instead redirect its offset budget into actual emissions reduction — raising its Scope 1 and 2 target from 50% to 70% by 2030. Australia Post followed. So did PwC, NRMA, Afterpay, Jetstar, and the government's own Clean Energy Finance Corporation.

When the greenbank that finances renewable energy projects decides your carbon neutral certification isn't worth keeping, that should tell you something.

The Program the Government Can't Decide On

In October 2023, the Albanese government launched a review of Climate Active, proposing to ditch the "carbon neutral" label and tighten rules around which offsets qualify. An announcement was promised for late 2024. It never came. As of mid-2026, the government's official position is still that "a decision about the future direction of the Climate Active program is yet to be made."

That policy limbo matters if you're a sustainability manager trying to justify a five-figure annual spend to your CFO. You're paying for a certification that might be reformed, renamed, or quietly abandoned — and nobody will give you a straight answer about which one.

The underlying problem isn't just political indecision. It's structural. Climate Active certifies an organisation as "carbon neutral" if it measures its emissions, develops a reduction plan, and buys enough offsets to cover whatever's left. But here's the thing: you don't actually have to reduce anything. The standard says annual absolute emission reductions are "not mandatory." You can increase your emissions year on year and still carry the carbon neutral tick, as long as you buy more credits.

That's the feature Telstra walked away from. And it's the feature that makes ACCC greenwashing prosecutors nervous.

What Climate Active Requires vs What ASRS Requires

The data collection overlap between Climate Active and ASRS is bigger than most people realise. Both require Scope 1 and 2 emissions measurement. Both need activity data — your electricity bills, gas consumption, fuel use, refrigerant losses. Climate Active also requires applicable Scope 3 categories, and ASRS mandates Scope 3 from each entity's second reporting year.

But the similarities end at the data. What you do with the numbers is completely different.

ASRS (specifically AASB S2) requires you to disclose your actual emissions — gross, unvarnished, inside your annual financial report. Directors sign off under the same liability framework as your profit and loss. The numbers get assured. Scope 1 and 2 face full legal liability from day one — no safe harbour, no modified liability protection. Get them wrong and your exposure goes up to $15 million or 10% of annual turnover.

Climate Active requires you to offset those emissions and claim you're carbon neutral. It's a voluntary marketing credential. Nobody goes to jail for getting your Climate Active report wrong. (Though the ACCC might come knocking if you use the trademark while your data is rubbish — more on that shortly.)

The critical difference: ASRS is about disclosure. Climate Active is about a claim. Under ASRS, you report emissions of 12,000 tonnes and that's fine. Under Climate Active, you report 12,000 tonnes and then buy 12,000 tonnes of offsets to say you're net zero. The reporting is a compliance obligation. The certification is a brand exercise.

If you're already caught by ASRS Group 2 requirements, you're doing most of the data work Climate Active needs anyway. The question isn't whether you can afford to do both. It's whether the incremental cost of the Climate Active layer — the offsets, the licence, the consultant to manage the certification — delivers value that justifies itself.

The Real Cost of Climate Active in 2026

Climate Active's own licence fees are modest. Under 25,000 tonnes CO2-e, you're paying $1,100 per year. Up to 100,000 tonnes, it's $2,200. Over 100,000 tonnes, $3,300. Those fees increase by 2.5% each July.

The licence fees aren't what makes this expensive.

It's everything else. Third-party validation runs $2,000 to $5,000 every three years. Consultant fees to manage the emissions inventory, write the public disclosure statement, and handle the certification submission typically cost $8,000 to $15,000 per year for a mid-sized organisation. And then there's the big line item: offsets.

A mid-market company with, say, 5,000 tonnes CO2-e needs to buy 5,000 credits. ACCUs traded at roughly $35-37 per tonne through the first half of 2026, and at least 20% of your offsets must be ACCUs (for certifications over 1,000 tonnes). International credits can be cheaper — Gold Standard units sometimes go for $10-15 — but they come with their own integrity questions. For 5,000 tonnes, a conservative offset budget lands between $60,000 and $120,000. For a bigger emitter at 25,000 tonnes, you're looking at $300,000 to $600,000 just in credit purchases.

Add it up and a mid-market Climate Active certification costs somewhere between $20,000 and $50,000+ annually at the low end, ballooning well past $100,000 for companies with larger footprints. And that's recurring. Every year. Because the moment you stop buying offsets, the certification lapses.

Compare that to the marginal cost of adding Climate Active to an existing ASRS compliance program — you've already got the emissions data — and you're really paying for two things: the offsets and the right to use the trademark. Is that worth it?

The Carbon Neutral Claim Is Getting Riskier

Here's where it gets uncomfortable. The ACCC has made greenwashing an enforcement priority for 2025-26 and into 2026. They've imposed over $42 million in penalties across four major cases in twelve months. And they've specifically signalled that carbon neutral claims backed primarily by offsets are under scrutiny.

The AANA Environmental Claims Code — which replaced the 2018 version in March 2025 — now requires that vague environmental claims like "carbon neutral" meet a high standard of proof. Substantiation must exist at the time the claim is made. Future claims need verifiable plans and milestones.

Think about what Climate Active certification actually certifies. It says: this organisation has offset its measured emissions. But 89% of offsets used under Climate Active come from international sources, with over half being Certified Emissions Reductions from the Clean Development Mechanism — a system so plagued by quality concerns that the EU stopped accepting its credits years ago.

We're not saying every Climate Active member is greenwashing. But we are saying that a "carbon neutral" claim sitting on top of rising actual emissions, funded by international offsets of questionable additionality, is exactly the kind of claim the ACCC has been going after. The Clorox case ($8.25 million penalty) and the Australian Gas Networks case (ongoing, alleging unsubstantiated renewable gas claims) show that regulators aren't interested in your certification logo. They're interested in whether the underlying claim holds up.

If your actual emissions are going up while your marketing says "carbon neutral," that's a gap. And gaps like that attract attention.

When Climate Active Still Makes Sense

We've been hard on the program, so here's the honest counter-argument. For some organisations, Climate Active certification still delivers value — but the use case is narrower than it used to be.

B2C brands where consumers care. If you sell directly to environmentally conscious consumers — organic food, sustainable fashion, eco-tourism — the Climate Active tick still carries recognition. Research suggests 87% of consumers value carbon-neutral labelled products over unlabelled alternatives. That's real, even if it's eroding. But you need to be confident your offset portfolio can withstand ACCC scrutiny, not just Climate Active's own review.

Government procurement. Some state and federal procurement frameworks give preference to Climate Active certified suppliers. If you're tendering for government contracts where it's an evaluation criterion, the commercial case is clear. Check the specific tender requirements before assuming this.

Organisations not caught by ASRS. If you're below the ASRS Group 3 thresholds (less than $50M revenue, fewer than 100 employees), you don't have a mandatory disclosure obligation yet. Climate Active can serve as a structured framework for measuring and managing emissions voluntarily. It gives you rigour you might not have otherwise. But honestly, you can get the same rigour from proper carbon accounting software without the offset cost.

For everyone else — and particularly for ASRS-reporting entities — Climate Active is an optional overlay on a mandatory process. And optionality costs money.

What We'd Do Instead

If we were a sustainability manager at a mid-market company today, here's where we'd put the $30,000-$50,000 that Climate Active would cost.

First, we'd get the ASRS emissions data right. Not "good enough for certification" right, but "auditor-assured, board-signed, Corporations Act liability" right. That's the number that matters now. Scope 1 and 2 carry full legal exposure from day one with no safe harbour protection under AASB S2.

Second, we'd invest in actual reduction — not offsets. Telstra made this exact move. They redirected their offset budget into decarbonisation projects and raised their reduction target. The ACCC can't penalise you for publishing accurate emissions that are going down. That's the opposite of greenwashing.

Third, if we still wanted a voluntary credential, we'd look at science-based targets through SBTi instead. An SBTi target forces absolute reduction along a 1.5-degree pathway. It doesn't let you offset your way to a claim. That's harder to achieve, but it's also much harder to challenge.

We're not sure Climate Active survives in its current form. The program might be reformed, it might be renamed, or it might just quietly shrink until the remaining participants are mostly electricity retailers and events companies. But one thing is certain: ASRS is the compliance baseline now, and no voluntary certification substitutes for it.

If you're spending money on Climate Active, make sure you can answer this: does this certification tell my stakeholders something that my mandatory ASRS disclosure doesn't already say? If the answer is just "we buy offsets," that's not a differentiator. It's a line item.

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