The Productivity Commission wants evidence on overlapping sustainability reporting costs

Treasury is already consulting on the shape of a reasonable value-chain ask. The Productivity Commission has opened a second, broader window.

On 9 September 2026 the Commission published its call for submissions on Business reporting requirements — an inquiry into the efficiency and value of non-financial business reporting. Initial submissions close Wednesday 30 September 2026. One of its three early focus areas is sustainability and environmental reporting: climate-related financial disclosures, emissions reporting, and pollution reporting — and how those packs stack when the same business (or the businesses that work with it) faces more than one.

That is not a new filing duty for mid-tier suppliers. It is a government ask for worked examples of cost, overlap, and data duplication while Australia’s climate-disclosure phase-in is still settling.

What Information request 2 actually asks

The paper notes that some large businesses must report on sustainability and environmental impacts under several schemes, that some of those schemes overlap, and that climate-related financial disclosures are still phasing in (Group 1 from 1 January 2025; further groups from 1 July 2026 and 1 July 2027). It notes the threshold increases announced in the 2026–27 Budget and points to the Treasury consultation on assurance, clearer guidance, and reducing the burden of information requests across supply chains.

Then Information request 2 asks participants:

• what the main compliance costs are — and whether overlaps make them worse
• what changes to requirements, processes or systems could cut costs and data duplication (examples given: reporting frequency; systems integration to reuse existing government data)
• to what extent reported information is actually used, and with what effect

Elsewhere the paper frames a second prong: map interactions across the reporting landscape and common barriers that stop regulators achieving a “tell us once” approach — identical or near-identical data sent to different bodies, inconsistent definitions or thresholds, misaligned periods. Opening pages are explicit that reporting costs can fall not only on the entity that lodges, but sometimes on businesses that work with them.

How this sits next to Treasury (and ASIC)

Do not conflate the two clocks.

The Australian Treasury’s Improving the efficiency of climate-related financial disclosures consultation (Proposal 3 on clearer boundaries for value-chain information requests) still closes Friday 2 October 2026. That paper is about the climate-disclosure regime’s own design. The Commission’s paper names that Treasury process and says it does not intend to create unnecessary uncertainty by duplicating or pre-empting concurrent reviews. Its interest, for this beat, is the cumulative load of sustainability and environmental reporting, and how the new climate packs fit with older emissions and pollution duties.

Separately, on 21 September 2026 the Australian Securities and Investments Commission (ASIC) published Report 839 on Group 1 sustainability reports for 31 December 2025 year-ends. In its sample (40 of the 312 reports lodged), 82.5% of entities relied on the one-year transitional relief from Scope 3 greenhouse gas emissions disclosure under Australian Accounting Standards Board Climate-related Disclosures (AASB S2). That relief is not available in the second year. ASIC also flags value-chain concentration of climate-related risks and opportunities, and expects practices to improve as more information becomes available across value chains — while pointing preparers to proportionality and estimation rather than absolute precision. That is a preparer surveillance signal, not a new supplier statute. It is useful context for why overlapping asks are already noisy in the field.

Who feels this — and who does not

If you are a mid-tier plant or a farm business outside the Corporations Act sustainability-report net, you are still not an AASB S2 filer. The Department of Agriculture, Fisheries and Forestry’s January 2026 farm fact sheet remains the plain line: reporting entities may use industry averages or secondary data; farm-level primary data is not mandatory for the climate-disclosure rules themselves; commercial programmes and contracts are a separate story.

The Commission is not proposing to enrol you as a filer. It is asking whether the stack — climate disclosure-driven Scope 3 packs, emissions schemes, pollution reporting, and the commercial templates that ride alongside — is creating duplication that a “tell us once” or reuse approach could shrink. If you have been asked for the same intensity, identity, and period data in three wrappers this year, that is the kind of worked example the paper invites.

What it does not settle

A call for submissions is not law. Nothing in this inquiry, by itself, voids a contractual data clause, a buyer programme, or a certification ask you already signed. The Commission’s interim report is flagged for November 2026; the final report goes to Government by February 2027. And because the paper deliberately steps around duplicating Treasury’s climate-efficiency work, do not read Information request 2 as a substitute for a Proposal 3 submission if that is the window you meant to use.

The practical supplier pattern hasn't changed: reuse intensity figures you already have, and share only the level of detail each commercial arrangement needs. The inquiry doesn't alter that either way.

Bottom line

The Productivity Commission has asked for evidence on overlapping sustainability and environmental reporting costs, with a hard close for initial submissions of Wednesday 30 September 2026. If the asks on your desk already stack — disclosure pack, emissions scheme, buyer portal — this is a second window to put that experience on the record, without pretending the inquiry has already rewritten the rules.