Treasury is consulting on what a reasonable supplier ask looks like

The Budget flag was one thing. The consultation paper is another.

In August 2026 the Australian Treasury published Improving the efficiency of climate-related financial disclosures. Submissions close Friday 2 October 2026. Proposal 3 is the bit mid-tier suppliers should actually read: setting clearer boundaries on value-chain information requests.

That is not a rewrite of who files. Treasury is explicit that this consultation is not seeking views on changing Scope 3 greenhouse gas emissions reporting requirements, or on who must report under the regime. Australian Accounting Standards Board Climate-related Disclosures (AASB S2) and the Corporations Act phase-in stay the backbone. What is on the table is how hard — and how vaguely — reporting entities may lean on people in their chain when they gather Scope 3 and related climate information.

What Proposal 3 actually floats

Treasury notes that Scope 3 disclosures have not yet commenced for reporting entities — they are required from the second reporting year — and that Scope 3 is limited to “reasonable and supportable information… available without undue cost or effort.” Overseas practice under similar regimes, it says, has shown the value of clearer boundaries on value-chain asks.

Two options are sketched:

Option 3a — guidance on a reasonable request. More practical guidance and examples from the regulator and standard setters on what may reasonably be sought from value-chain participants, how proportionality should work when collecting information, and how “without undue cost or effort” lands when the ask hits a resource-constrained small or medium business. Treasury’s rationale: improve consistency, cut unnecessary or duplicative requests, and still leave room for commercially negotiated data provision.

Option 3b — better domestic emissions factors. Increase publicly accessible Australian emissions factors so reporting entities have reliable secondary data and less need to issue complex primary-data requests into fragmented sectors — agriculture is named alongside road freight, specialised manufacturing and commercial construction. This would not stop industry from offering more granular tracing where that is a competitive advantage.

What Treasury considered and did not prefer: a single standardised form or template for what can be requested of supply-chain entities. The paper’s worry is that a fixed form would encourage requests even when AASB S2 already permits secondary estimates, and could push some suppliers to provide more than is necessary.

Question 14 in the paper is aimed squarely at people like you: entities in the supply chain of reporting entities — what have you been asked for, how often, and what was the administrative impact (including asks via third-party data collectors)?

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 and the Australian Securities and Investments Commission (ASIC) small-business page both say the same plain thing: reporting entities may use industry averages or secondary data; farm-level or supplier primary data is not mandatory for the climate-disclosure rules themselves; commercial programmes and contracts are a separate story.

Proposal 3 does not enrol you as a filer. It acknowledges the blast radius and asks whether clearer boundaries — and better secondary factors — would shrink the noise before Group 2 and later cohorts harden their Scope 3 habits.

What it does not settle

Consultation is not law. Nothing in this paper, by itself, voids a contractual data clause or a buyer programme you already signed. Secondary factors help a portfolio estimate; they do not turn an anonymised intensity into farm-level land-management evidence for a Science Based Targets initiative Forest, Land and Agriculture (SBTi FLAG) company target programme. And a future guidance note on “reasonable requests” will not invent a parallel filing duty the Corporations Act never wrote for the supplier.

The durable supplier pattern is unchanged: sit on intensity you already have, answer once, grant per buyer at the level of detail the commercial deal needs, revoke when you mean to. If clearer boundaries and better factors arrive, that pattern gets easier — not obsolete.

Bottom line

Treasury has opened the door on what a reasonable supplier ask looks like, with a hard close of 2 October 2026. If the asks on your desk are already noisy, fragmented, or routed through third-party collectors, this is the window to put that experience on the record — without pretending the consultation has already rewritten the rules.