A new compliance clock is ticking across Australian boardrooms….
Australia’s Climate-Related Financial Disclosure (CRFD) regime commenced on 1 January 2025, establishing Australia as a global leader in mandatory climate reporting aligned to International Sustainability Standards Board standards. Compliance is being phased in from the largest companies first, with Scope 3 emissions — the full value chain — becoming mandatory from the second year of reporting.
For airlines and airports, this is not an abstract regulatory exercise. It is an existential data problem.
The Scope 3 Problem Nobody Wants to Name
Scope 1 and 2 emissions (what you burn directly and what your energy supplier burns) are hard but solvable. Scope 3 is something else entirely. As per Brisbane Airport Corporation’s own reporting, 99% of their overall emissions fall within Scope 3, owned by airport stakeholders with primary contributors including aviation fuel, ground servicing equipment, passenger transportation to and from the airport, and third-party electricity consumption.
Read that again. Ninety-nine percent.
This means airports cannot hit their climate targets without fundamentally changing how they influence, measure, and report on the behaviour of every party in their ecosystem airlines, ground handlers, tenants, rideshare operators, passengers.
What the Ecosystem Is Actually Doing
The moves being made are significant, but fragmented.
In May 2025, Sydney Airport earned Airport Carbon Accreditation Level 4, signed an MoU with Qantas to develop a domestic Sustainable Aviation Fuel (SAF) industry, and participated in the largest-ever commercial importation of SAF into Australia, nearly two million liters. Bold infrastructure moves. But SAF addresses Scope 1 aviation emissions. It does nothing for the passenger who drove a diesel SUV to the terminal.
Brisbane Airport became one of the first Australian airports to achieve net zero Scope 1 and 2 emissions in January 2025, reducing emissions by 97% through renewable electricity procurement and electrification of ground fleet vehicles. Again commendable, but Scope 1 and 2 is the easy part.
On the ground transport side, Uber for Business now gives companies the ability to track, report and act on ground transportation carbon emissions including total CO2 and the percentage of corporate rides taken with low-emission options. Trip-level data. Useful. But siloed.
And then there’s Qantas. After pioneering Green Tier in 2022 to reward members for sustainable choices, the airline is phasing out Green Tier from late 2026, while stating it will “consider new ways to reward members who make sustainable choices when they fly.” The sustainability intent remains. The mechanism is being rebuilt from scratch.
The Gap Nobody Is Filling
What you see across this landscape is effort without integration. Airports measuring their fence line. Airlines measuring their fuel. Rideshare operators measuring their fleet. Loyalty programs measuring individual acts.
Nobody is measuring the journey.
A traveller flies Sydney to Singapore. They took an Uber to the airport, parked for a week, bought a coffee from a non-certified supplier in the terminal, offset their flight at checkout, and stayed in a hotel with no energy rating. That is a Scope 3 emissions story and right now, no single actor in that chain can tell it end to end.
Under the CRFD regime, the obligation to tell it is coming. Entities must disclose Scope 3 emissions from the second year of reporting, using all reasonable and supportable information available including information provided by customers, suppliers, or otherwise publicly available.
“All reasonable and supportable information.” That phrase will define a new category of competitive advantage.
What Good Looks Like
The travel operators who will lead this decade are not those who reduce their own footprint most aggressively. They are those who build the data infrastructure to measure, attribute, and improve the footprint of every interaction in their ecosystem and who turn that infrastructure into a better experience for the traveler.
Loyalty is the most underutilised lever in this equation. Airlines and airports already have the identity layer, the transaction layer, and the engagement mechanism. The question is whether they will use it to make sustainable choices visible, rewarding, and habitual or whether they will wait for regulation to force their hand. The obligation is no longer invisible. The tools to meet it are emerging. The organisations that move now, before the reporting deadline arrives, will shape the standard. Those that wait will be shaped by it.
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