INVESTIGATION | 4 November 2026

A consultancy firm advised both government and the gas industry on the same gas policy - without declaring a conflict of interest.

A Climate Integrity investigation reveals that consultancy firm ACIL Allen advised  both the government and the gas industry on gas policy – including the influential Future Gas Strategy – without declaring a conflict of interest.

Drawing on documents obtained under Freedom of Information (FOI), “Working both sides of the fence” shows that throughout 2023 and 2024, ACIL Allen was commissioned by the gas industry and the federal government to deliver analysis to inform gas policy. 

At times, ACIL Allen was working for industry and government at the same time.

The report  also analyses  six of the reports produced by ACIL Allen for government and the gas industry - finding that the consultancy often adopted assumptions and methodologies that overstate the case for more gas and understate the benefits of a faster transition to renewables. 

This raises questions about the adequacy of conflict-of-interest safeguards governing government-commissioned advice and about the integrity of parts of the evidence base behind one of Australia's most consequential energy policies.

By Alexandra Blucher and Michael Mazengarb

Working both sides of the fence


In 2023 and 2024, consultancy ACIL Allen was paid by gas industry groups to produce reports that were then used to lobby on the Future Gas Strategy. Over the same period, it was paid by the federal government to deliver analysis to inform that same strategy.

ACIL Allen did not declare a conflict of interest to the government.

One of the policies that ACIL Allen worked on for both government and industry was the Future Gas Strategy (FGS). This is one of the most significant policy statements in Australia’s energy transition. It sets out the role of fossil gas in the economy through to 2050, and has faced criticism for backing new gas supply that’s inconsistent with a net zero pathway, and for underplaying the role of renewables and storage.

Key Findings

  • ACIL Allen held a conflict of interest during its $273,713 contract for the Department of Climate Change, Energy, the Environment and Water (DCCEEW) – work intended to inform the development of the Future Gas Strategy and broader gas policy – because it had recently completed work for gas and business lobby groups Gas Energy Australia and the Business Council of Australia, which was used in the organisations’ submissions to the Future Gas Strategy.

  • ACIL Allen failed to disclose a conflict of interest to DCCEEW, even though the Supplier Code of Conduct was in force when the reports related to the Future Gas Strategy were delivered.

  • In 2023, ACIL Allen was working for industry and government on gas policy at the same time.

  • Reports produced by ACIL Allen for both gas industry interests and the federal government adopt a consistent stance that gas should remain a feature of Australia’s energy system to 2050 and beyond, recommending that government support is provided to enable the development of new gas supplies.

  • ACIL Allen’s analysis consistently overstated the cost of zero emissions alternatives to gas, while also entirely omitting any assessments of the costs of developing new gas supplies through worsening climate harms.

DCCEEW told Climate Integrity that ACIL Allen did not declare any conflicts of interest related to the contracts identified in this report. ACIL Allen did not respond to questions asking whether it declared any conflicts to the government and how conflicts were managed, if at all.

What our FOIs uncovered 

Documents obtained by Climate Integrity through Freedom of Information (FOI), along with open source research, shows that over a nearly two year period ACIL Allen worked on:

  • Three reports for industry associations representing fossil fuel interests. Including Gas Energy Australia, the Business Council of Australia, the Australian Pipelines and Gas Association and Energy Networks Australia. These reports were used in submissions to the Future Gas Strategy and Electricity and Energy Sector Plan consultation processes. The report for Gas Energy Australia was quoted in the Future Gas Strategy report, with no reference to who commissioned the work. 

  • Two reports for the Department  of Climate Change, Energy, the Environment and Water (DCCEEW) One advised on east coast gas market reforms and another (delivered in two parts) was commissioned to inform the Future Gas Strategy and the Energy and Electricity Sector Plan.

Timeline of six ACIL Allen gas reports commissioned by the Australian Government and gas industry bodies between 2023 and 2024, shown against the development of the Future Gas Strategy. ACIL Allen’s gas advice to government and industry, 2023–24 Commissioned by Australian Government (DCCEEW) Commissioned by gas industry bodies Future Gas Strategy (DISR) Faded start = estimated commissioning date Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan 2023 2024 Future Gas Strategy announced — 3 Oct 2023 Future Gas Strategy published — 9 May 2024 Gas Energy Australia Report The economic contribution of the Australian gas economy in 2021–22 Commissioned by Gas Energy Australia Delivered 6 Aug 2023 DCCEEW Report 1 East coast gas market reliability and supply adequacy — Stage 2 reforms Commissioned by DCCEEW (Australian Government) Commissioned 7 Jul 2023 Delivered 30 Nov 2023 BCA Report The role of the gas sector in Australia’s transition to net zero emissions Commissioned by the Business Council of Australia Delivered 13 Nov 2023 Renewable Gas Report Renewable Gas Target Commissioned by APGA and Energy Networks Australia Commissioned April 2023 Delivered 16 Feb 2024 DCCEEW Report 2 Gas-powered generation and gas infrastructure modelling Commissioned by DCCEEW (Australian Government) Commissioned 15 Feb 2024 Delivered 5 Jul 2024 DCCEEW Report 2: Supplementary Draft supplementary report — seasonal demand flexibility Commissioned by DCCEEW (Australian Government) Commissioned 15 Feb 2024 Delivered 19 Dec 2024 Future Gas Strategy Australian Government strategy Department of Industry, Science and Resources Note: where commissioning dates are not on the public record, they are estimated at approximately 120 days before delivery and shown with a faded bar. Sources: ACIL Allen and client publications; DCCEEW; DISR.
Timeline of six ACIL Allen gas reports commissioned by the Australian Government and gas industry bodies between 2023 and 2024, shown against the development of the Future Gas Strategy. ACIL Allen’s gas advice to government and industry, 2023–24 Commissioned by Australian Government (DCCEEW) Commissioned by gas industry bodies Future Gas Strategy (DISR) Faded start = estimated commissioning date Apr Jun Aug Oct Dec Feb Apr Jun Aug Oct Dec 2023 2024 Gas Energy Australia Report The economic contribution of the Australian gas economy in 2021–22 Delivered 6 Aug 2023 DCCEEW Report 1 East coast gas market reliability and supply adequacy — Stage 2 reforms Commissioned 7 Jul 2023 · Delivered 30 Nov 2023 BCA Report The role of the gas sector in Australia’s transition to net zero emissions Delivered 13 Nov 2023 Renewable Gas Report Renewable Gas Target — for APGA and Energy Networks Australia Commissioned April 2023 · Delivered 16 Feb 2024 DCCEEW Report 2 Gas-powered generation and gas infrastructure modelling Commissioned 15 Feb 2024 · Delivered 5 Jul 2024 DCCEEW Report 2: Supplementary Draft supplementary report — seasonal demand flexibility Commissioned 15 Feb 2024 · Delivered 19 Dec 2024 Future Gas Strategy Australian Government strategy — Dept of Industry, Science and Resources Announced 3 Oct 2023 · Published 9 May 2024 Note: where commissioning dates are not on the public record, they are estimated at approximately 120 days before delivery and shown with a faded bar. Sources: ACIL Allen and client publications; DCCEEW; DISR.

Figure 1: Timeline of ACIL Allen’s engagement on gas policy analysis, for both government and industry clients, corresponding with the development of the Future Gas Strategy

ACIL Allen’s reports for Government:

Conflict of interest


By working on gas policy both for the government and for gas industry clients, ACIL Allen has a conflict of interest. Its clients’ in the gas industry have a direct financial interest in the outcomes of government policy, on which it is also advising. 

DCCEEW told Climate Integrity that ACIL Allen did not declare a conflict of interest related to the contracts identified in this report. 

Following the PwC tax leak scandal, the Commonwealth introduced a Supplier Code of Conduct, which took effect on 1 July 2024. Its very first expectation is that suppliers declare and manage conflicts of interest. Under the Code, failing to declare a conflict is considered a “severe” breach.

ACIL Allen delivered its main report to DCCEEW four days after the Code came into effect, and a supplementary report five months later. DCCEEW did not answer our question about whether it updated ACIL Allen’s contract to include the Code. ACIL Allen did not respond to our questions.

However, previous guidance that was in place when the two DCCEEW reports were commissioned said public servants involved in contract management should ensure any conflict of interest declarations were provided by suppliers when setting up the administration of a contract.

DCCEEW and DISR did not respond to Climate Integrity’s questions on how the reports have been used internally.

ACIL Allen did not respond to Climate Integrity’s detailed list of questions asking whether it declared a conflict, whether the same staff worked on reports for both government and industry, and how conflicts were managed, if at all.

Same story, whoever the client


Our review of ACIL Allen’s reports for both industry and government found assumptions and methods that consistently made gas look better than the alternatives.

Date Published
Commissioned by
Content
Download
Cover of ACIL Allen report: The economic contribution of the Australian gas economy in 2021-22The economic contribution of the Australian gas economy in 2021-22
6 August 2023
Gas Energy Australia
Input-output modelling of the direct and indirect contributions of the gas industry to GDP and employment.
Cover of ACIL Allen report: The role of the gas sector in Australia’s transition to net zero emissionsThe role of the gas sector in Australia’s transition to net zero emissions
13 November 2023
Business Council of Australia
An assessment of the future role of gas in Australia, finding that more gas was necessary to support Australia achieving a net zero target.
Cover of ACIL Allen report: East coast gas market reliability and supply adequacy Stage 2 reformsEast coast gas market reliability and supply adequacy Stage 2 reforms
30 November 2023
DCCEEW
Qualitative assessment of proposed reforms to Australia’s east coast gas market.
FOI Disclosure
(Document 6)
Cover of ACIL Allen report: Renewable Gas TargetRenewable Gas Target
16 February 2024
Australian Pipelines and Gas Association Ltd (APGA) and Energy Networks Australia (ENA)
Analysis supporting policy proposal for the introduction of a renewable gas target.
Cover of ACIL Allen report: Gas-powered generation and gas infrastructure modellingGas-powered generation and gas infrastructure modelling
5 July 2024
DCCEEW
Comparative assessment of different firming technologies, comparing gas fired generation against hydrogen generators and pumped hydro energy storage.
FOI Disclosure
(Document 1)

1. ACIL Allen’s analysis consistently over estimated the cost of zero-emissions alternatives to gas

ACIL Allen produced a modelling report for the Business Council of Australia, which formed part of the lobby group’s submission to the Future Gas Strategy consultation.

In this report, ACIL presents gas generation as a lower cost source of firmed electricity supply, compared to zero emissions alternatives - pumped hydro and battery storage. But the analysis primarily focuses on capital costs, largely excludes the higher operating and maintenance costs of gas generation, uses constrained and unrealistic energy market scenarios and ignores the climate costs of gas.

ACIL Allen prepared a very similar analysis in a modelling report for the federal government - reaching the same conclusions with similar methodological issues.

In this report, ACIL Allen compares the cost of the continued use of gas generation to firm Australia’s largest electricity grid to two narrowly constructed alternative scenarios where gas is replaced by zero emissions technologies: one scenario where gas generation firming is replaced only by pumped-hydro projects by 2050, and a second, where all gas firming is replaced by only hydrogen fuelled generators by 2050. In reality, Australia’s future firming needs will be met by a mix of optimised technologies (as reflected in the forecasting approach taken by AEMO).

In ACIL Allen’s full analysis, other zero emissions technologies were excluded as alternatives, including large-scale battery storage, the use of demand management technologies, or expanded investment in solar and wind capacity - or a mixture of renewable energy, storage and demand management technologies - in providing an alternative to gas firming.  

In its conclusions, it tells DCCEEW that “[gas powered generation] and supporting gas infrastructure is an economically feasible way to firm the NEM during its transition to net zero.”

Click to expand: Climate Integrity analysis of a graph which was displayed prominently within the Business Council of Australia’s submission to the Future Gas Strategy Consultation. Read more here.

What needs to happen


The Future Gas Strategy is described by DISR as “an evidence-based framework” but this report reveals flaws and conflicts of interests regarding research that was commissioned to inform the policy. Given the conflict of interest was not declared by ACIL Allen, DISR and DCCEEW should retrospectively manage this conflict of interest by disclosing how ACIL Allen’s work was used to inform the Future Gas Strategy, and other gas policy and decision making, and should review and update the policies using sound, independent evidence that is free from conflicts of interest to rebuild public trust in the policies’ credibility.

ACIL Allen, and consultancies more broadly, should assess the climate impacts of their work against stated commitments to climate targets or goals, including ensuring their work is consistent with its own climate commitments. This includes a calculation and disclosure of their ‘serviced or advised emissions’.

Consultancies must prepare and publish a statement of commitment to modelling and information integrity. Consultancies should include a plan for implementing its commitment to information integrity, including full disclosure of commissioning clients, assumptions, modelling methodologies and conflicts of interest. 

All government departments and agencies commissioning research and analysis from consultancies must seek guarantees that conflicts of interests will be declared and mitigated. This is particularly important when a consultancy’s clients have a particular interest in the government adopting particular policy positions.

Cite this report:

Climate Integrity (2026). Working Both Sides of the Fence: How ACIL Allen Advised Government and the Gas Industry on the Same Policy, Without Declaring the Conflict. Melbourne: Climate Integrity. Available at: http://climateintegrity.org.au/acil-allen-gas-conflicted

“If part of the evidence base for a major national policy can come from consultants with undeclared industry ties, how can the public trust the policy?

The Future Gas Strategy is set to shape Australia's energy future until at least 2050. It is informing policy making that will shape the energy transition for decades to come. Australians should be able to trust that crucial government decisions about energy are being made based on advice that is free from conflicts of interest.”

Claire Snyder
Executive Director, Climate Integrity

As part of our investigation, we posed the following questions to ACIL Allen, DCCEEW, DISR, the Business Council of Australia, Gas Energy Australia, Australian Pipelines and Gas Association Ltd and Energy Networks Australia.

Only DCCEEW provided a response.

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