By Wilson Fernández
Introduction
As the global climate crisis intensifies, regulators and standards bodies alike are embedding climate change considerations directly into business governance frameworks. For Australian organisations, particularly those in Victoria, climate change compliance is no longer optional. It is enforceable through legislation and reinforced through global management system standards. With the February 2024 amendment to ISO 9001:2015 and EPA Victoria’s updated regulatory intent, businesses must understand and integrate climate change responsibilities into their quality management systems (QMS), whether certified or not.
This article synthesises regulatory mandates, ISO 9001:2015 expectations, and practical business actions using Victoria as a model jurisdiction — while recognising that similar requirements apply across all Australian states and increasingly around the world.
1. The ISO 9001:2015 Amendment: Climate Change as a Business Imperative
In February 2024, ISO and the International Accreditation Forum (IAF) jointly published a Communiqué announcing a key amendment to ISO 9001:2015:
Key Changes:
- Clause 4.1 – Organisations shall determine whether climate change is a relevant issue.
- Clause 4.2 – Organisations shall consider whether climate change is relevant to interested parties’ expectations.
These changes formally embed climate change into ISO 9001:2015 certified QMS. While labelled a clarification, it effectively mandates organisations to treat climate change like any other strategic business issue — requiring risk assessment, process integration, and performance evaluation.
1A. Circular Economy and Its Link to Climate Change Obligations
As part of its climate action strategy, EPA Victoria identifies the circular economy as a vital approach for achieving emissions reduction and building environmental resilience. A circular economy shifts businesses away from the traditional linear model of take-make-dispose and toward practices that prioritise resource recovery, reuse, waste minimisation, and product life extension. For Victorian businesses, adopting circular economy principles supports compliance with the General Environmental Duty (GED) and helps reduce emissions associated with production, transportation, and landfill. Circular practices — such as product design for recyclability, waste-to-resource programs, sustainable procurement, and repair/reuse systems — align directly with EPA Victoria’s objectives and can also serve as key risk controls in ISO 9001:2015 management systems. For businesses serious about climate mitigation, integrating circular economy thinking is not just good environmental practice — it’s part of a compliant and future-ready operation.
“The circular economy is not just an environmental trend — it’s a compliance, risk, and quality consideration”
Why it matters:
- Directly reduces emissions (climate mitigation).
- Minimises environmental harm (GED compliance).
- Adds value through cost savings, innovation, and stakeholder confidence.
- Strengthens ISO 9001 system effectiveness.
2. Victoria’s Legal Requirements: A Model for National and Global Action
EPA Victoria’s Statement of Regulatory Intent on Climate Change (2025–2027) affirms that all businesses have legal responsibilities (certified and non-certified to ISO 9001:2015) under:
2.1 Environment Protection Act 2017 (General Environmental Duty – GED)
- Under Section 25 of the Environment Protection Act 2017, every person or business conducting activities that may pose a risk of harm to human health or the environment (including from greenhouse gas emissions or climate-related effects) must minimise those risks as far as reasonably practicable
- This applies universally — from small retailers to large manufacturers.
2.2 Climate Change Act 2017
- This Act integrates climate considerations into decision-making for all sectors.
- It requires public authorities and regulated entities to consider climate risks and emissions reduction in their operations, strategies, and procurement.
2.3 EPA Climate Change Regulatory Intent
a. EPA has clarified that all businesses are expected to consider climate change when:
- Assessing environmental risks
- Applying for or holding EPA permissions (licences, permits)
- Demonstrating conformance with GED
b. Businesses must be proactive in identifying how their activities may contribute to or be affected by climate change.
Legislated Target: As amended in 2024, the Climate Action Act 2017 (Vic) mandates that the State must achieve net zero greenhouse gas emissions by the year 2045.
“The long-term emissions reduction target for the State is an amount of net zero greenhouse gas emissions by the year 2045.” — Section 6(1), Climate Action Act 2017, as amended by Act No. 9/2024.
Key Expectations for All Victorian Businesses:
- Identify if and how your business contributes to climate change (e.g. GHG emissions)
- Identify how climate change may impact your business (e.g. floods, heatwaves, fires)
- Minimise harm and build climate resilience (as far as reasonably practicable)
- Demonstrate action, monitoring, and continual improvement
- Comply with EPA Victoria’s Regulatory Intent.
- Demonstrate duty of care under the GED — e.g. emissions, waste, fire/flood risk, heat impact on assets, or supply disruptions.
NOTE: These are not ISO 9001:2015 requirements, but a must statutory obligations. Businesses without ISO 9001:2015 certification are still legally bound by these rules.
3. Practical Application: Who Needs to Do What?
3A. Risk and Scale-Based Application of Climate Change Requirements
While all businesses must observe the General Environmental Duty (GED), the depth of action, documentation, and engagement with EPA Victoria varies based on the organisation’s scale, industry, and environmental risk profile:
This risk- and scale-based application ensures that businesses respond proportionately to their environmental and climate impacts, while still fulfilling their statutory duties.
Key EPA Obligations Across All Sectors:
- General Environmental Duty (GED): Every business, regardless of type, must take reasonably practicable steps to prevent harm.
- Climate Risk Assessment: Especially where physical risks (e.g. fire, flood) or emissions (GHGs, refrigerants, waste) are present.
- GHG Emission Control: Required or encouraged for moderate-to-high impact sectors.
- Permissions / Licences: Required for certain high-risk activities (e.g. waste handling, emissions, effluent discharge).
- Climate Adaptation & Mitigation Plans: Especially where assets, people, or supply chains are vulnerable.
4. Flowchart: Climate Change Compliance Framework (EPA + ISO 9001)
The following diagram visualises how Victorian businesses can integrate climate change obligations within ISO 9001 systems.
5. Essential Activities to Demonstrate Compliance
5A. Generic Activities for Climate Change Preparedness and Risk Mitigation
a. Climate Risk and Impact Assessments
- Identify how climate change events (e.g. heatwaves, storms, floods, bushfires) could affect your business operations, staff, assets, supply chain, and customers.
- Assess business continuity risks from severe weather or infrastructure failure.
b. Greenhouse Gas (GHG) Emissions Review
- Identify and quantify Scope 1 and Scope 2 emissions (e.g. fuel use, refrigerants, electricity).
- Where applicable, estimate Scope 3 emissions (e.g. supply chain, transport, product lifecycle).
- Implement strategies to reduce energy consumption and emissions.
c. Energy Efficiency Initiatives
- Upgrade to energy-efficient lighting, equipment, and appliances.
- Consider solar power or participation in renewable energy programs.
- Implement automated energy management systems in facilities.
d. Waste and Resource Management
- Implement the waste hierarchy: Avoid > Reduce > Reuse > Recycle > Dispose.
- Prevent emissions from landfilling organic materials or improperly managed waste.
- Set up recycling programs for packaging, e-waste, organics, etc.
e. Sustainable Transport and Logistics
- Encourage use of low-emission vehicles, carpooling, public transport, or cycling.
- Optimise delivery routes and consolidate loads to reduce fuel consumption.
- Transition fleet vehicles to EVs or hybrids where feasible.
f. Sustainable Procurement and Supply Chain Engagement
- Source from environmentally responsible suppliers.
- Include climate criteria in supplier selection and contracts.
- Monitor suppliers for compliance with climate-conscious practices.
g. Infrastructure Resilience and Adaptation
- Upgrade facilities to withstand climate extremes (e.g. flooding, bushfire risk).
- Ensure stormwater and drainage systems are functional and resilient.
- Develop site-specific climate adaptation plans.
h. Refrigerant Management
- Replace high-GWP refrigerants with low-GWP alternatives.
- Regularly service refrigeration and HVAC systems to prevent leakage.
- Comply with Ozone Protection and Synthetic Greenhouse Gas Regulations.
i. Monitoring, Reporting & Review
- Track and document climate-related risks, emissions, and mitigation actions.
- Set climate or sustainability targets (e.g. net zero by 2045).
- Include climate impacts in risk registers and management reviews.
j. Training and Awareness
- Train staff in energy conservation, emergency preparedness, and waste reduction.
- Raise awareness about EPA Victoria’s General Environmental Duty (GED).
- Encourage a culture of environmental responsibility.
6. Sector-Specific Considerations
7. National and Global Alignment
While Victoria leads with enforceable climate obligations, other states are following:
- VIC: Victoria’s Climate Change Strategy | Victoria’s Climate Change Strategy (Booklet)
- NSW: Climate Change Policy | NSW: Action Plan (licencing and adaptation expectations)
- QLD: Adaptation Strategy 2030 | QLD: environmental obligations and duties
- WA, SA, TAS, NT, ACT: Each has climate policies and regulations addressing emissions, adaptation, and business obligations
Apart from State-Based EPA Requirements – Federal Climate Change Framework
In addition to state-specific obligations such as those imposed by EPA Victoria, all Australian businesses are subject to overarching federal climate change legislation. The Climate Change Act 2022 enshrines Australia’s national commitment to reduce greenhouse gas emissions by 43% below 2005 levels by 2030 and to achieve net zero emissions by 2050. It requires the federal government to publish annual climate change statements and report on national progress, creating both policy direction and accountability. Complementing this, the National Greenhouse and Energy Reporting (NGER) Scheme mandates that corporations exceeding defined thresholds must report their GHG emissions, energy production, and energy consumption. These federal instruments provide the legislative backbone for Australia’s transition to a low-emissions economy and set the tone for regulatory and audit expectations at both national and state levels. More information is available through sources such as legislation.gov.au, iclg.com, aofm.gov.au, and arena.gov.au.
NOTE: Internationally, ISO standards are increasingly aligning with climate accountability. Businesses in any country with ISO 9001 certification must assess and document whether climate change is a relevant issue.
8. Auditor Responsibility in the Context of Climate Change
The alignment of EPA Victoria’s regulatory expectations with the amended ISO 9001:2015 standard has redefined the responsibilities of both internal and external auditors. Auditors are now expected to go beyond traditional quality checks to verify whether climate change has been properly considered as a relevant issue within the organisation’s context (Clause 4.1) and stakeholder expectations (Clause 4.2). This includes ensuring that organisations (certified or non-certified) have identified, assessed, and documented climate-related risks, integrated mitigation and adaptation actions, and are continually monitoring their performance. This shift requires a comprehensive understanding of both regulatory obligations and ISO 9001:2015 requirements, enabling auditors to assess conformance, statutory compliance, and system effectiveness with confidence.
a. Generic Climate Change Requirements for All Victorian Businesses
These requirements apply to all organisations operating in Victoria, regardless of size, sector, or ISO 9001:2015 certification status:
*Note: Guidance on Auditing Climate Change issues in ISO 9001 (Source: ISO 9001 APG)
b. Sector-Specific Verification Requirements
c. Audit Evidence to Look For
- Risk registers with climate-specific entries
- Training logs covering GED and EPA expectations
- Documented emissions inventory or estimation method
- Compliance register (including Climate Change Act, EPA licences)
- Emergency response plan with climate events covered
- Project plans reflecting flood/fire/heat resilience measures
- Supplier contracts with climate/sustainability clauses
9. Quick Reference Summary of Climate Change Responsibilities
Conclusion
Climate change is no longer a future challenge — it is a current business, legal, and ethical responsibility. Through the February 2024 ISO 9001:2015 amendment and EPA Victoria’s climate enforcement program, Australian businesses now have clear direction on how to act.
Certified or not, businesses must:
- Identify their climate risks and responsibilities
- Engage with regulatory expectations
- Integrate climate considerations into operational and strategic decisions
This proactive approach builds resilience, transparency, and long-term sustainability — essential qualities for organisations operating in an era of increasing climate disruption and public accountability.
“Failure to act may expose businesses to legal risk, reputational damage, and systemic failure in the face of increasing climate-related disruptions.”
Prepared using ISO 9001:2015 (Amended 2024)🔹ISO/IAF Joint Communiqué (Feb 2024)🔹EPA Victoria GED & Regulatory Intent🔹 Climate Action Act 2017 (Vic)🔹 Climate Change Act 2022 (Federal)🔹National Greenhouse and Energy Reporting (NGER) Scheme and National Climate Legislation references
Disclosure Statement
The information presented in this article is intended to raise awareness and provide general guidance on the intersection of climate change requirements, ISO 9001:2015 (as amended in 2024), and regulatory obligations under EPA Victoria and other applicable Australian legislation. While every effort has been made to ensure accuracy and relevance at the time of publication, this content does not constitute legal advice, compliance certification, or official regulatory interpretation.
Readers are encouraged to consult the Environment Protection Authority (EPA) Victoria, Standards Australia, ISO, and legal professionals for advice tailored to their specific context, industry, and jurisdiction. Regulatory obligations and standards are subject to change, and organisations must remain up to date with the latest legislative and ISO published MSS developments relevant to their operations.
About the author
Wilson Fernandez is an experienced Management Systems Leader, Auditor, and Quality & Safety Professional with a global career spanning across engineering, manufacturing, automotive, infrastructure, and service industries. With deep expertise in ISO-based and industry-specific standards, he has successfully led initiatives in Quality, Health & Safety, Environmental, and Risk Management systems. Wilson has conducted hundreds of audits worldwide, applying process-oriented approaches and driving continual improvement.
He is passionate about sharing practical insights, highlighting regulatory responsibilities, and simplifying complex systems for real-world application. Through his articles, Wilson aims to raise awareness, build robust systems, and foster a culture of responsibility, safety, and quality across businesses of all sizes.
This article first appeared on Wilson Fernández’s LinkedIn page and is published here with permission.