Australia’s sustainability reporting landscape shifted significantly in 2025 with the introduction of mandatory climate-related financial disclosures. For the first time, large Australian businesses are required to report on climate risks, emissions, and transition plans in a structured, auditable format. Understanding what changed and how it affects your organisation’s approach to IT equipment and e-waste is essential for compliance and strategic planning.

The Mandatory Climate Disclosure Regime

The Australian Government passed the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act, which introduced mandatory climate-related financial disclosures aligned with the International Sustainability Standards Board (ISSB) framework. The Australian Accounting Standards Board (AASB) then issued Australian Sustainability Reporting Standards (ASRS), starting with ASRS 1 (General Requirements) and ASRS 2 (Climate-related Disclosures).

The regime rolled out in phases. Group 1 entities, the largest reporters with over $500 million in revenue or $1 billion in assets, began reporting for financial years starting on or after 1 January 2025. Group 2 entities follow from 1 July 2026, and Group 3 from 1 July 2027. Even if your organisation does not yet fall within these thresholds, understanding the requirements early gives you time to build the data collection systems and processes you will need.

What This Means for IT and E-Waste

The new reporting requirements touch IT asset management and e-waste in several important ways. First, Scope 3 emissions reporting now requires organisations to account for emissions across their value chain, including the embodied carbon in purchased IT equipment and the emissions associated with its end-of-life processing. This means your IT procurement and disposition activities feed directly into your climate disclosures.

Second, transition planning requirements ask organisations to describe how they intend to move toward lower-carbon operations. For many businesses, extending the useful life of IT equipment through refurbishment and reuse is a tangible, measurable action that can be included in transition plans. Moving from a linear “buy, use, dispose” model to a circular approach where equipment is refurbished and remarketed demonstrably reduces your carbon footprint.

Third, physical and transition risk assessments may need to consider supply chain disruptions affecting IT equipment availability, the financial impact of changing regulations around e-waste disposal, and stranded asset risks if equipment cannot be disposed of compliantly.

Key takeaway: Even if your organisation is not yet required to report under the mandatory regime, your customers and partners who are in scope may start asking you about your own emissions data and sustainability practices as part of their Scope 3 reporting. Being prepared with accurate data positions you as a preferred supplier or partner.

Scope 3 and IT Equipment

For most office-based businesses, IT equipment represents a significant portion of Scope 3 emissions. The embodied carbon in manufacturing a single laptop can exceed 300 kg of CO2 equivalent, and for servers the figure can be several tonnes. When you multiply this across an organisation’s entire IT fleet, the numbers become material.

Under the new reporting requirements, organisations need to quantify these emissions. This means tracking what equipment you purchase (and its embodied carbon), how long you use it before retirement, what happens at end of life (recycling, refurbishment, or landfill), and the emissions associated with transportation and processing during disposition. Having a clear relationship with your ITAD provider who can supply accurate environmental data, including CO2e avoidance figures for refurbished and recycled assets, becomes a reporting necessity rather than a nice-to-have.

The TCFD Foundation

The Australian requirements are built on the Task Force on Climate-related Financial Disclosures (TCFD) framework, which organises disclosures around four pillars: governance, strategy, risk management, and metrics and targets. If your organisation has already been voluntarily reporting against TCFD, the transition to mandatory reporting is less dramatic, though the level of assurance and specificity required is higher.

For organisations new to this type of reporting, the four-pillar structure provides a useful framework for thinking about how IT asset management fits into your broader climate strategy. Who is responsible for overseeing IT sustainability (governance)? How does IT disposition fit into your climate transition plan (strategy)? What risks does improper IT disposal create (risk management)? And what metrics are you tracking to measure improvement (metrics and targets)?

Assurance Requirements

The mandatory regime introduces phased assurance requirements. Initially, limited assurance is required, moving to reasonable assurance over time. This means your ESG data, including data related to IT equipment and e-waste, needs to be audit-ready. Informal estimates and rough calculations will not meet the standard.

Organisations that have been relying on approximate e-waste figures or back-of-the-envelope carbon calculations will need to upgrade their data collection processes. This includes maintaining accurate IT asset registers with lifecycle data, obtaining verified emissions data from ITAD providers, documenting methodologies used to calculate IT-related emissions, and retaining supporting evidence for audit purposes.

Beyond Compliance

While the mandatory regime sets the floor for reporting, leading organisations are using it as an opportunity to differentiate themselves. Demonstrating strong e-waste management practices, transparent chain of custody, and measurable carbon reduction through IT asset reuse sends a positive signal to investors, customers, and employees.

Victoria’s e-waste landfill ban, in place since 1 July 2019, already puts Victorian businesses ahead of some other jurisdictions in terms of baseline compliance. Building on this foundation with robust ESG reporting around IT assets positions your organisation well as reporting requirements continue to expand.

For a deeper look at how to structure your ESG reporting around e-waste and IT equipment, see our comprehensive guide on ESG reporting and e-waste for Australian businesses. For specific guidance on measuring and reporting Scope 3 emissions from IT equipment, our Scope 3 emissions practical guide provides a step-by-step approach.

]]>