28 February 2025
Farmers for Climate Action (FCA) welcomes the opportunity to provide a response to the Consultation on the Australian Agriculture Sustainability Framework (AASF).
Key Points
- The AASF must be independently governed, with legislative backing.
- No lobby group, including the National Farmers Federation, should retain custodianship of the AASF.
- The AASF must have compliance and enforcement capabilities.
- The future AASF entity must support farmers, not burden them.
- Trust in the AASF must be built through inclusive and transparent governance.
About Farmers for Climate Action
We represent farmers, agricultural leaders, and rural Australians who want to see Australia adopt strong climate policies to protect farmers and farming communities. Our members include more than 8,400 farmers across Australia and a further 80,000 community supporters committed to reducing emissions across the economy this decade.
Farmers for Climate Action commends the National Farmers Federation (NFF) for successfully securing $4 million to develop Stage 1 of the AASF between 2020-2022, and for securing an additional $5 million investment from the Australian Government for Stage 2 of development from 2023 until 2026. More investment will be required to transition the AASF into a robust, future-fit, and ongoing initiative. Farmers for Climate Action strongly requests continued transparency around the disbursement and efficient allocation of public funds to support this development.
For our sector, the AASF has the potential to be a visible demonstration to Australia’s 169 trading partners and our national and global value chain that Australian suppliers meet robust sustainability-related criteria required to safeguard market access. Australian farmers have been subjected to increasing sustainability-related trade barriers while the AASF has been under development. We note the urgency with which finalising and operationalising the AASF must occur. Every year that this important initiative remains a work-in-progress is a year that hurts the Australian farming sector. This framework is one key pathway to keep Australian farmers farming.
Our approach to this consultation is informed by one undeniable reality: for Australia to remain competitive in global markets, sustainability standards – particularly around emissions reduction and climate risk mitigation – must move towards mandatory compliance with enforceable consequences. As the consultation paper is written today, it is clear that the AASF is overdue to prioritise mandatory emissions reduction. The absence of mandatory emissions reduction in the AASF, despite significant investment by government over many years, reflects a lack of leadership and ambition to lead agriculture towards a sustainable and prosperous future in competitive global markets.
Farmers for Climate Action thanks the NFF for its dedication and leadership to shepherd the AASF to this point. Successfully transitioning the framework into an independent, effective, and trusted initiative that supports farmers will rest on the broad consultation undertaken to date. To further strengthen the initiative, we urge a closer consideration of the needs of farmers, alongside the entire value chain with a stake in the sustainability of the Australian farm sector. The overall credibility of the AASF will be fundamentally undermined if it remains industry-owned for the next phase of its development.
Farmers for Climate Action reiterates the importance of broad representation across the agricultural sector and value chain. Transparency is critical to building trust in the development process and ensuring the AASF meets the needs of farmers, industry, and key trading partners. We seek clarity on how this consultation has engaged all relevant agricultural sectors and supply chain partners, and the process by which submissions will be published to ensure transparency. Additionally, we request further detail on the expected timeframe for a collective summary of feedback, whether it will be made publicly available, and whether the names of participating organisations will be listed. Given the significance of the AASF in shaping the future of agriculture in Australia, an open and clearly communicated process will be essential in building trust and ensuring a framework that meets the needs of all stakeholders.
Please do not hesitate to contact me at the number below should you wish to further discuss this submission.
Yours sincerely,
Natalie Collard
CEO, Farmers for Climate Action
Email: info@farmersforclimateaction.org.au
Phone: 1800 491 633
Web: farmersforclimateaction.org.au
Post: FCA C/- Melbourne Connect Co-Working, Lvl 2 700 Swanston Street, Carlton VIC 3053
Consultation Question 1 – Based on the above options, what is your preferred option for the future entity and why?
The AASF must be independently governed, with legislative backing. The AASF will play a critical role shaping sustainable agriculture, market access, and emissions reduction pathways. It represents a meaningful opportunity to unite Australian agriculture and ensure that the sustainability initiatives across different sectors are mapped to and reflect the high standard of a strong national framework. To be effective, the AASF must be governed by a Commonwealth Corporate Entity with legislative authority. This ensures long-term stability, regulatory certainty, and independence from industry lobbying pressures. An independent entity is necessary to transition critical sustainability criteria – such as emissions reduction – from voluntary to mandatory, in line with evolving market and trade requirements.
As a Commonwealth Corporate Entity, the AASF body will have the necessary resources and capacity to monitor industry developments and guide the transition from voluntary to mandatory emissions reduction criteria. We note that this transition may need to take place over years and be supported by deep engagement with industry, extension, and investment. Where compliance is not observed, only a Commonwealth Corporate Entity with legislative authority will have recourse to measures allowing it to investigate and correct allegations of non-compliance. As a Commonwealth Corporate Entity, the AASF will be functionally and perceptually independent of industry and agricultural representative groups.
Consultation Question 2 – Based on the above options, are there any options listed that should definitely not be considered and why?
No lobby group, including the NFF, should retain custodianship of the AASF. Farmers for Climate Action, representing 8,400 farmers nationwide and over 80,000 supporters, has consistently heard from farmers that they want transparency, integrity, and clear regulatory oversight in sustainability reporting. The perception of industry self-regulation weakens the credibility of the AASF, both domestically and internationally. This view is supported by market expectations for robust and independent sustainability governance. International buyers, investors, and policymakers will not accept reporting and compliance mechanisms that are influenced by industry bodies with political or commercial priorities.
Of the options listed on page 10 of the consultation paper, Farmers for Climate Action is concerned that half of the suggested options would leave the AASF within the NFF. The NFF is an industry lobby group whose primary function is to represent the commercial interests of its members. While this role is important, and our membership of the NFF affirms this, it is fundamentally incompatible with overseeing a framework that must independently monitor and influence industry compliance. Allowing a lobby group to oversee a national compliance framework presents a clear conflict of interest – particularly when enforcing emissions reductions and sustainability commitments. As such, option A (an entity within the NFF) and option B (an entity with the NFF) must not be considered. The option of “business as usual” must also not be considered – it is worth noting the urgency with which the AASF must be strengthened, finalised, and operationalised. The “business as usual approach” has not significantly advanced the AASF, despite significant funding and in the face of rising trade barriers that have impacted Australian farmers.
Consultation Question 4 – What functions and services do you think would be critical for a national sustainability initiative that effectively meets your current and future needs?
The AASF must have compliance and enforcement capabilities. For Australia to remain competitive in global markets, sustainability standards – particularly relating to emissions reduction and climate risk mitigation – must evolve beyond voluntary compliance. They must produce real impact through mandatory compliance. As such, the AASF must be empowered to ensure that all industry sustainability initiatives align with its high standards. The national initiative should have oversight of all industry standards, and function to influence these standards in line with an AASF that is strengthened to transition critical sustainability criteria – such as emissions reduction – from voluntary to mandatory compliance, in line with evolving market and trade requirements. It should be able to audit, assess compliance, and take appropriate action through enforceable consequences if the application of sector sustainability standards is not producing the stated sustainability-related outcomes.
The future AASF entity must support farmers, not burden them. Farmers have clearly expressed that they do not want additional layers of sustainability reporting, especially when existing, commodity-specific frameworks already meet their needs. The work of commodity-specific research and development corporations in developing transparent, measurable and, in many cases, ambitious sustainability frameworks is to be applauded.
The AASF should not be responsible for servicing individual farmers – it must focus on aligning and integrating sustainability standards across sectors, rather than creating duplicative or conflicting requirements. The initiative should actively provide services that build the capacity of sector-specific initiatives, and in this manner collaboratively mitigate the exposure of our sector to sustainability-related market risk.
The delivery of these functions and services will be best supported by an independent governance structure. A well-structured, independent government entity will reduce administrative burdens on farmers while strengthening national sustainability credibility.
Consultation Question 5 – Please review the recommendations contained in Table 2 and provide your comments about the NFF initial response. Do you have any alternative views about whether recommendations should be adopted, adopted with amendments or rejected?
Farmers for Climate Action agrees with the proposed recommendation that P1 read, “net anthropogenic greenhouse gas emissions are limited to mitigate climate change” be the principle of this criteria. However, for Australia to remain competitive in global markets, sustainability standards related to emissions reduction must move towards mandatory compliance. As this principle is written today, the AASF remains overdue to prioritise mandatory emissions reduction.
Regarding P2, energy should be separated into a separate grouping of principles to differentiate between the unique properties of energy as opposed to air quality. The new ‘Energy’ principles should be grouped within the ‘Environmental Stewardship’ section of the AASF and afforded its own set of principles alongside ‘Greenhouse Gases & Air’, ‘Soil & Landscapes’, ‘Biodiversity’, et cetera. The new principle relating to energy should read that “energy is consumed efficiently and obtained from renewable sources”. To best represent the economic opportunities presented by renewable energy and electrification to reduce costs and increase productivity for farmers, ‘Energy’ should also be included under the ‘Economic Resilience’ grouping of principles.
Farmers for Climate Action agrees with the recommendation of a new principle under ‘Economic Resilience’ that reads “climate change adaptation and resilience is promoted”, but this principle must be strengthened. Strengthening this principle to read “climate change adaptation and resilience building is prioritised on farms and mandated across industry”, will ensure that farmers and farming communities are best equipped with the tools, information, and support needed to succeed as climate change continues to impact our sector.
Consultation Question 6 – What would ensure you can trust the processes by which the AASF register and catalogues are created and maintained? Who would need to be involved and/or represented on the governance group and associated expert groups?
Farmers for Climate Action strongly believes that trust in the AASF can only be established through independence, transparency, and robust governance. The AASF must not be functionally or perceptually influenced by industry groups with explicit commercial interests. Instead, it must function as an impartial entity with clear oversight mechanisms.
To ensure trust, the AASF must genuinely function as a value-adding service provider for a broad ecosystem of grassroots farmer-led initiatives, industry working groups, and commodity-specific sustainability standards. As a partner to these existing groups, farmers will retain ownership of their data, with industry groups administering their commodity-specific standards while the AASF entity manages and audits meta-data for accuracy and compliance. The independence of the AASF entity is fundamental – it cannot be influenced by industry and must be governed as a Commonwealth Corporate Entity with legislative authority and a ministerially appointed board to provide regulatory oversight. Without this separation, the credibility of the AASF will remain in question domestically and for key trading regimes and supply chain partners overseas.
The governance and expert groups overseeing the AASF must reinforce this independence while maintaining strong engagement with industry stakeholders. Farmers for Climate Action recommends a governance structure that includes:
- Independent experts in sustainability reporting, environmental science, and agricultural policy.
- Farmers as representatives from grassroots sustainability initiatives to ensure that the services of the entity meet their needs.
- Industry group and RDC representatives to support alignment with existing sector-specific sustainability standards and priorities.
- Regulatory and market experts to ensure that the AASF meets both national and international compliance expectations.
For the AASF to maintain trust and provide assurance of compliance to international markets, its governance must demonstrate independence from industry lobbying. The long-standing approach of industry-led self-regulation has not delivered the level of transparency or credibility required to safeguard market access for farmers in a rapidly evolving sustainability landscape. The AASF must be built on a foundation of accountability, ensuring that sustainability data is handled with integrity while strengthening the resilience and competitiveness of Australian agriculture.
Consultation Questions 10 to 13
Farmers for Climate Action acknowledges the extensive process undertaken to identify the indicators and measures within the AASF structure. This work reflects the significant efforts of grassroots farmer-led initiatives, industry-administered sustainability frameworks, and sector-specific standards that have informed the AASF’s development. These contributions are to be commended.
We note that the indicators themselves are not new – rather, they are the result of an ongoing industry consultation process that has documented and consolidated existing sustainability measures. While this process has been thorough, the real test of the AASF’s effectiveness lies in how these indicators are applied moving forward to result in the tangible sustainability-related outcomes demanded by key trading jurisdictions and supply chain actors.
The critical next step for the AASF is to move beyond voluntary commitments and toward enforceable sustainability standards. Emissions reduction, alongside other priority indicators, must transition from voluntary measurement and reporting to mandatory compliance. This shift is necessary to provide Australian farmers with a credible overarching framework to guarantee market access in a manner that aligns with evolving global trade requirements.
The success of the next phase of development for the AASF will ultimately depend on its ability to evolve from a reporting mechanism into a governance framework that drives meaningful impact and outcomes for farmers. Establishing an independent entity to oversee the AASF is essential to ensuring that sustainability indicators result in action that supports long-term economic resilience for Australian agriculture. Farmers for Climate Action urges the next phase of the AASF’s development to prioritise this transition – ensuring that sustainability outcomes are not only documented but embedded within the regulatory and market frameworks that shape the future of the sector.
