Navigating Human Induced Regeneration Gateway Audits: A Summary for GreenCollar Project Partners


The Clean Energy Regulator (CER) has recently updated its guidelines which impacts Human Induced Regeneration (HIR) projects under the Australian Carbon Credit Unit (ACCU) Scheme. As project partners, understanding these updates help ensures continued compliance and progress towards forest cover milestones.

What is a Gateway Audit, and Why is it Needed?

A Gateway Audit is an essential part of the regulatory framework for HIR projects.  It serves to verify that projects are meeting the specific regeneration and forest cover milestones required under the Method, CFI Legislation and supporting Guidelines. These audits are designed to support the integrity and credibility of the ACCU Scheme, ensuring that the environmental outcomes being credited  are being achieved.

The Purpose of Gateway Audits

Gateway Audits are necessary to:

  1. Verify Progress: Ensure that HIR projects are on track to meet the designated milestones for forest cover.
  2. Maintain Scheme Integrity: Confirm that projects are contributing genuine carbon sequestration as per the ACCU Scheme’s requirements.
  3. Systematic Monitoring: Provide a structured approach to monitor and assess the progress of HIR projects over time.

Introduction of the Section 215 Gateway Audit

On 3 May, 2023, the CER announced an expanded audit program under section 215 of the Carbon Credits (Carbon Farming Initiative) Act 2011 (CFI Act). As of May 6, 2023, HIR projects must undergo an additional audit known as the Section 215 Gateway Audit. This audit is triggered when an offsets report containing a Gateway Check is submitted, ensuring alignment with all legislative requirements.

What Does the Section 215 Gateway Audit Involve?

The Section 215 Gateway Audit includes a comprehensive review of the stratification and technical data provided during the Gateway Check, as well as a review of the project eligibility (baseline suppression)and the evidence and implementation of HIR activities. This process involves both documentation review and may include an onsite inspection. GreenCollar will accompany auditors to project areas at times convenient for land managers to facilitate this process.

Consistent Requirements for Achieving Forest Cover

The requirements for HIR projects to achieve forest cover have not changed. The main objective remains to implement land management practices that reduce the suppression of native vegetation, enabling the regeneration of vegetation to reach forest cover.

Regeneration Assessment at 5 yearly Intervals

In 2019, the  CER established specific milestones for assessing regeneration, as a measure to ensure that HIR projects progress appropriately. These Regeneration Checks are required every 5 years until the project reaches it’s forest cover attainment date. At each gateway, regeneration needs to be assessed at a relevant scale. For example

  • First Check: Projects at year 6 for example, must demonstrate at least 7.5% canopy cover of vegetation that is 2 meters or taller, assessed over a 100-hectare scale.
  • Second Regeneration Check: Canopy cover should increase to at least 10%, with the same height requirement, assessed over a 10-hectare scale.
  • Attainment of Forest Cover: Ultimately, 90% of 0.2-hectare portions must achieve forest cover, confirming successful attainment of forest cover. This must be maintained until the end of the projects’ permanence period.

These benchmarks are designed to demonstrate that HIR projects remain eligible under the established methodologies and continue contributing to carbon sequestration goals.

Efforts to Help Expedite the Audit Process

Recognising that the audit process can be slow, with the potential to impact the timing of ACCU issuance and subsequent payments, GreenCollar is actively working with the CER and auditors to help streamline this process. While standard audits typically take around eight weeks, the Section 215 Gateway Audit could extend this timeline to 6-8 months. Our collaborative efforts aim to reduce these delays while maintaining the thoroughness required for assessment.

Integration of New Technologies

To expedite the audit and assessment processes, GreenCollar is leveraging new technologies and methodologies for data collection and analysis. These technological advancements enhance accuracy and efficiency, ultimately speeding up the entire process. 

Addressing Areas of Non-Compliance

It’s important to address any project areas that do not meet the required forest cover milestones. Areas that are not regenerating as planned must be removed from the project area or placed on a growth pause, ensuring that only compliant areas contribute to the project’s overall abatement profile. These areas can be re-evaluated and potentially re-included once they meet the necessary requirements.

Next Steps for Project Partners

Over the coming months GreenCollar will be working with our Project Partners to help ensure that evidence of the implementation of HIR management activities is of sufficient quality and quantity with an aim of improving audit timelines and project outcomes. We are constantly improving our processes to help ensure that projects remain compliant and can satisfy the requirements and increased scheme scrutiny.

GreenCollar will keep you informed about the progress of report submissions and subsequent Section 215 Gateway Audits. Please stay updated on these developments to ensure continuous alignment and project success.

For more detailed information on HIR Gateway Checks, please refer to the resources provided by the CER.

In summary, while the additional audit requirements may introduce some delays, GreenCollar is committed to working with all stakeholders to support a smooth and efficient process. Your continued support and collaboration are appreciated as we strive towards achieving our collective goal of contributing towards sustainable land management and carbon sequestration.