Permanence Period & other key compliance concepts

Permanence Period is one of the key concepts that defines the timeline of a ACCU scheme project. It is the duration for which the sequestered carbon must be maintained and protected from reversal.

At registration, project proponents can choose a permanence period of either 25 or 100 years.

The permanence period begins when ACCUs are first issued to the project, not at project start or registration.

The permanence period extends beyond the crediting period. This means that even after a project can no longer earn new ACCUs, the proponent still has an ongoing obligation to maintain the sequestered carbon for the remainder of the permanence period.

There is other concepts that make up the 'compliance timeline' for an ACCU scheme project. This guide outlines the key periods, obligations, and milestones that govern the lifecycle of a project, from registration through to the end of the permanence period.  

Summary of Key Periods

Baseline Period

The baseline period establishes the conditions of the project area before any carbon abatement activities begin. This is the reference point against which future carbon sequestration outcomes are measured.

Crediting Period

The crediting period is the duration during which a project can generate and claim ACCUs. For Environmental Plantings (EP) projects, this period is 25 years.

At registration, you choose (or are assigned) a crediting period start date, which is normally within 18 months of your registration date. It is important to note that the crediting period is distinct from the permanence period:

• The crediting period governs when ACCUs can be earned
• The permanence period governs how long the sequestered carbon must be maintained.

Delivery Period

The delivery period is the duration of a Carbon Abatement Contract (CAC) - the offtake agreement offered by the Clean Energy Regulator - under which ACCUs are delivered to the CER. It starts on the date the contract commences and continues until it expires, with a maximum of seven or ten years depending on the project type.

When a project proponent enters into a CAC, the delivery period defines how long they are obligated to deliver ACCUs to the CER, and provides a fixed price for those units over that term. It is worth noting that the delivery period only applies if the project has secured a CAC. Projects can generate and sell ACCUs on the open market without one, in which case there is no formal delivery period, and units are sold on the proponent's own terms.

Reporting Period

A reporting period is a defined timeframe covered by an offsets report, which details the project's progress and carbon sequestration outcomes. For EP projects, reports must be submitted at least every 5 years, and each reporting period must be a minimum of 6 months.

Importantly, reporting obligations do not end with the crediting period. For EP projects, offsets reports must continue at least every 5 years until the end of the permanence period. Each offsets report is due within 6 months after the reporting period ends. The CER may take up to 90 days to assess an offsets report and process any crediting applications.

Audits

All ACCU Scheme projects are subject to auditing throughout the crediting period. As a minimum, projects must undergo 3 scheduled audits during the crediting period (an initial audit followed by subsequent audits). In addition to scheduled audits, the CER may also conduct triggered (unscheduled) audits at any time if there are concerns about project compliance.

Alternative assurance for low-risk projects: Environmental Plantings projects registered under FullCAM 2024 may be classified as “low-risk” and, under the alternative assurance pathway, may have zero scheduled audits. In these cases, the CER uses geospatial monitoring in place of traditional audits. However, unscheduled or triggered audits can still occur.

ACCU Issuance

During the crediting period, carbon abatement that is delivered and reported above the baseline level is incrementally credited as ACCUs. First issuance is based on the success of the tree plantings, specifically whether growth and survivability are detectable at the time of assessment.

If a project is well planned and monitored, ACCUs can theoretically begin to flow as early as year 3 of the project. It is worth noting that the timing of your first ACCU issuance also has a downstream effect: the sooner ACCUs are issued, the sooner your permanence period begins, and therefore the sooner your long-term obligation will be completed.