2026 ACCU Scheme Review Submission
Climate Integrity welcomes the opportunity to provide feedback on the Climate Change Authority’s 2026 ACCU Scheme review public consultation.
Submission Summary
Drawing on the best available climate science and a growing body of evidence on carbon market performance, this submission argues that the ACCU Scheme, in its current form, risks undermining Australia’s decarbonisation task by enabling over-reliance on carbon offsetting, particularly through land-based methodologies that lack durability, additionality and long-term environmental integrity.
At its core, this submission emphasises a well-established principle: carbon offsetting must remain a limited tool, reserved for genuinely residual emissions after all feasible emissions reductions have been achieved. Biological and land-use based carbon storage cannot compensate for the effectively permanent nature of fossil fuel CO₂ emissions, and large-scale reliance on such credits introduces significant risks of reversal, over-crediting and mitigation deterrence. Without reform, the ACCU Scheme and linked compliance frameworks – including the Safeguard Mechanism – risk diverting capital away from long-term emissions reductions, prolonging fossil fuel production, and enabling misleading environmental claims. The review therefore presents a critical opportunity to realign the ACCU Scheme with climate science, public trust, and Australia’s long-term emissions reduction objectives.
Recommendations:
The ACCU Scheme must be reformed with a view to phasing out methodologies that lack additionality, environmental integrity and are highly vulnerable to abatement reversals
Operation of the ACCU Scheme must recognise the inherent limits of carbon offsetting approaches and the trade-offs associated with land-use practices
The use of ACCUs must not detract from efforts to achieve long-term decarbonisation of emissions intensive industries
Greater clarification is needed regarding the environmental claims associated with the use of carbon offsets generally, including ACCUs
