From tractionfintech.com: Australian Carbon Credit Units (ACCUs) are classified as ‘financial products’ but are not subject to reporting under the ASIC Derivative Transaction Rules since they do not qualify as over-the-counter (OTC) derivatives.

While ACCUs themselves are not reportable, any derivatives that have ACCUs as an underlier may require reporting if they involve future settlement.

Only OTC derivatives with longer-dated emissions products as the underlying are reportable under the ASIC Rules, with ACCUs explicitly excluded from the definition of OTC derivatives.