Australian businesses must now disclose Scope 3 emissions under the CRFD regime. For airlines and airports, that means measuring what they've never had to own — the entire journey.
Brisbane Airport Corporation's own annual report reveals a striking number: 99% of the airport's total emissions sit in Scope 3 — generated not by the airport itself, but by every airline, ground handler, retailer, rideshare, and passenger moving through it. Sydney Airport, meanwhile, has committed to net zero Scope 1 and 2 by 2030 and earned Airport Carbon Accreditation Level 4 in May 2025. Commendable milestones. But Scope 1 and 2 is the easy part.
Under Australia's Climate-Related Financial Disclosure (CRFD) regime, Scope 3 reporting becomes mandatory from the second year of reporting — for Group 1 entities from 2026, Group 2 from 2027. Airlines and airports are squarely in scope. The question is no longer whether they must measure the full journey. It's whether they have the data infrastructure to do it.
Here is the underappreciated irony: airlines already own the most powerful tool in this equation. Loyalty programs give them the identity layer, the transaction layer, and the behavioural engagement mechanism to make sustainable choices visible and rewarding at scale.
Qantas recognised this early. Green Tier — launched in 2022 — offered members 50 status credits or 10,000 bonus points for completing five sustainable activities: offsetting flights, staying in eco-accredited hotels, switching to green energy. It was imperfect but directionally right. Now, Qantas is retiring Green Tier from late 2026, integrating sustainability as one of ten ground-earning categories in a redesigned program. The intent remains. The mechanism is being rebuilt.
The gap being left is significant. No single actor in the travel chain currently measures the full passenger journey — the rideshare to the terminal, the carbon offset at checkout, the hotel energy rating, the SAF percentage on the flight. Uber for Business now offers trip-level CO2 reporting for corporate travel. Sydney Airport is importing sustainable aviation fuel at scale. These are meaningful, siloed moves. Nobody is connecting them into a single emissions story attributed to a single traveller.
The CRFD deadline is not a future problem. Group 1 reporting has already commenced. The organisations building data partnerships, loyalty integrations, and passenger-level attribution frameworks today will define the standard. Those waiting for regulatory pressure to force the issue will be shaped by a standard someone else set.
The journey is the emissions story. It's time the travel industry started telling it.