Driving strategic insights: Sector readiness for a NSW government regulator

 

Overview

The NSW Government has introduced new requirements for large supermarkets to record their food donations from 1 July 2026, as part of the Food Organics and Garden Organics (FOGO) Bill. The requirements are designed reduce food waste, stop food waste going to landfill and strengthen food rescue, creating environmental and social benefits across NSW.

To support the smooth implementation of these requirements, the NSW Environment Protection Authority (EPA) commissioned BDO to provide an independent assessment of sector readiness. Building on BDO’s 2023 baseline report, the 2025 engagement provided a readiness assessment of supermarkets, charities, and food rescue organisations. The work benchmarked sector progress, highlighted ongoing challenges, delivered strategic insights to inform the EPA’s approach as it prepares for the 2026 deadline.

Delivery

BDO combined proven methodology with deep sector knowledge to deliver a clear picture of sector preparedness. The engagement drew on:

• Readiness assessment: Using BDO’s readiness matrix tool, we assessed levels of awareness, understanding, readiness, and sentiment across the sectors.
• Stakeholder engagement: We consulted with supermarkets, charities and food rescue organisations to validate assumptions and understand operational realities and emerging needs.
• Comparative analysis: Findings were benchmarked against the 2023 baseline to highlight improvements, capability shifts, and areas where risks persist.
• Strategic insights: The analysis provided forward-looking guidance to inform the transition.

BDO delivered a structured, evidence-based view of sector maturity by combining research, consultation, and comparative analysis. This approach ensured that the EPA received both a reliable snapshot of current readiness and a strategic roadmap to inform the transition.

Outcome

The final report provided the EPA with an informed analysis to support the introduction of the supermarket recordkeeping requirements. Designed to balance regulatory objectives with operational practicality, the outcomes of the engagement included:

• Clarity and consistency: Recommendations to strengthen sector-wide understanding of the new requirements and encourage alignment across stakeholders.
• Staged implementation roadmap: A timeline of short, medium, and long-term actions that ensures early wins while allowing adequate time for more complex initiatives.
• Evidence-based insights: A measured view of sector progress and remaining gaps, enabling the EPA to allocate resources effectively and build confidence among stakeholders.

This work has provided the EPA with the tools it needs to refine its implementation strategy, strengthen food rescue outcomes, and build a more resilient donation ecosystem across NSW.

How BDO can help

Our sustainability and advisory teams bring deep expertise in environmental policy, regulatory reform, and sector transformation. We work with public sector agencies, industry bodies, and organisations to navigate complex change, design practical frameworks, and deliver outcomes that create lasting environmental and social value. By combining strategic insight with operational experience, we help clients anticipate challenges, prioritise actions, and implement initiatives that drive meaningful impact.

• Readiness and capability assessments

  BDO provides evidence-based assessments that evaluate awareness, preparedness, and organisational maturity. By identifying strengths, gaps, and potential risks, we give clients a clear foundation for strategic decision-making and targeted intervention.

• Stakeholder engagement and insight generation

  We design and deliver structured engagement programs that capture diverse perspectives, uncover operational realities, and inform policy or program design. This ensures strategies are grounded in stakeholder needs while supporting broader objectives.

• Comparative analysis and benchmarking

  Our team applies rigorous comparative approaches to track progress over time, measure outcomes against benchmarks, and identify trends. These insights enable organisations to make data-driven choices, prioritise resources effectively, and strengthen their change initiatives.

• Strategic planning and roadmaps

  BDO translates insights into actionable, phased strategies, aligning short-, medium-, and long-term initiatives with organisational priorities. By mapping dependencies, sequencing actions, and embedding measurable outcomes, we help clients achieve sustainable transformation.

Through this combination of strategic insight, structured analysis, and practical guidance, BDO helps clients across the public sector and ESG landscape navigate complexity, unlock opportunities, and achieve impactful, lasting change.

Contact us to find out how our strategy and transformation and sustainability services teams can assist your organisation.