Scope 3 Emissions: Why This Is Now a Supply Chain and Procurement Problem for Australian Businesses

For most of the past decade, Scope 3 emissions have sat in the sustainability team's domain. They appeared in voluntary disclosures, were estimated using spend-based proxies, and were treated as a reporting exercise rather than an operational priority. Procurement teams were occasionally asked to include sustainability questions in tender documents. Supply chain leaders were sometimes consulted on transport emissions. But the overwhelming majority of Scope 3 activity was managed at arm's length from the functions that actually control the supply chain decisions driving those emissions.

That is changing, and it is changing fast. Australia's mandatory climate reporting regime, introduced under the Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Bill 2024 and governed by AASB S2, is phasing in requirements that make Scope 3 emissions disclosure a legal obligation for thousands of Australian businesses. Group 1 entities, those with over $500 million in revenue or $1 billion in assets, began reporting Scope 1 and 2 emissions from January 2025, with Scope 3 mandatory from their second reporting year. Group 2 entities follow from July 2026. Group 3 entities from July 2027. Within two years, virtually every large and mid-sized business in Australia will be required to measure, report, and subject to assurance their value chain emissions.

This is not a sustainability challenge that can be solved by the sustainability team alone. Scope 3 emissions, by definition, are generated across the supply chain. They sit in purchased goods and services, upstream and downstream transportation, waste generated in operations, business travel, use of sold products, and end-of-life treatment. For most organisations, Scope 3 represents somewhere between 70% and 90% of total greenhouse gas emissions. The decisions that drive those emissions are procurement decisions, logistics decisions, product design decisions, and supplier management decisions. Which means this is now, unavoidably, a supply chain and procurement problem.

What Scope 3 Actually Covers

The Greenhouse Gas Protocol defines 15 categories of Scope 3 emissions, split between upstream (supply side) and downstream (customer and end-of-life side). Not all categories are material for every organisation, and the reporting standards do not require equal depth of measurement across all 15. But understanding the categories is essential for determining where to focus.

On the upstream side, purchased goods and services is almost always the largest category. This covers the cradle-to-gate emissions embedded in everything an organisation buys, from raw materials and components to professional services and office supplies. For a retailer, this is the emissions profile of every product on the shelf. For a manufacturer, it includes every input material. For a services business, it includes everything from IT hardware to cleaning contracts. Capital goods, fuel and energy-related activities not included in Scope 1 or 2, upstream transportation and distribution, waste generated in operations, and business travel round out the upstream categories.

On the downstream side, the material categories depend heavily on the business model. For a manufacturer, use of sold products and end-of-life treatment of sold products can be enormous. For a property company, downstream leased assets may dominate. For a franchisor, franchisee emissions are the key category.

The practical implication is clear. Any organisation that wants to measure, let alone reduce, its Scope 3 emissions needs to engage deeply with its supply chain. There is no shortcut that avoids this. Spend-based estimates using industry-average emission factors will satisfy minimum reporting requirements in the short term, but they do not provide the granularity needed to identify reduction opportunities, set credible targets, or demonstrate progress over time.

Why This Hits Procurement First

Procurement is the function that selects suppliers, negotiates contracts, defines specifications, and manages the commercial relationships across the supply base. If Scope 3 emissions are driven by what an organisation buys, from whom, at what specification, and through what supply chain, then procurement is the primary lever for influencing those emissions.

This creates several practical requirements that most procurement functions have not yet absorbed.

Supplier emissions data collection becomes a procurement obligation. To report Scope 3 with any accuracy beyond spend-based estimates, organisations need primary emissions data from their suppliers. This means building data collection into supplier onboarding, contract requirements, and performance management. It means defining what data is needed, in what format, at what frequency, and with what level of verification. For many suppliers, particularly smaller businesses, this is new territory, and the requesting organisation may need to provide support, tools, or at minimum clear guidance on what is expected.

Evaluation criteria need to incorporate emissions. As Scope 3 reporting matures and assurance requirements tighten, the emissions profile of a supplier's product or service will need to be a genuine factor in procurement decisions, not just a line item in a sustainability questionnaire that nobody reads after the tender is awarded. This does not mean that emissions will or should override price, quality, or delivery in every procurement. It means that emissions need to be visible, measured, and considered as part of the total cost and total value assessment.

Category strategies need a carbon lens. The categories where an organisation's Scope 3 emissions are concentrated should be reflected in category management priorities. If 40% of your Scope 3 footprint sits in one or two procurement categories, those categories need dedicated attention, with targets, supplier engagement plans, and alternative sourcing strategies that address the emissions profile alongside cost, quality, and supply risk.

Contract terms need to evolve. Contracts with key suppliers will increasingly need to include emissions reporting obligations, performance expectations, and potentially reduction trajectories. This is not about imposing punitive requirements on small suppliers. It is about embedding emissions accountability into the commercial framework in the same way that quality, safety, and delivery performance are already embedded.

Why This Hits Supply Chain Operations Second

Beyond procurement, supply chain operations drive Scope 3 emissions through logistics, warehousing, waste, and the physical movement of goods through the value chain.

Transport and distribution emissions sit across both upstream (inbound logistics managed by suppliers) and downstream (outbound logistics to customers). The mode of transport, the distance travelled, vehicle utilisation, fuel type, and network design all influence the emissions profile. For organisations with significant freight activity, transport is one of the most actionable Scope 3 categories because the levers are relatively well understood: modal shift from road to rail or sea, route optimisation, fleet electrification or transition to lower-emission fuels, load consolidation, and network redesign to reduce total kilometres travelled.

Waste generated in operations is another category where supply chain decisions directly influence emissions. Packaging design, material selection, waste segregation infrastructure, and the availability of circular or recycling pathways all determine whether waste generates landfill methane or is diverted to lower-emission recovery processes. For organisations with significant packaging, construction waste, or food waste streams, this category can represent a material portion of Scope 3.

Warehousing and distribution centre operations contribute through energy consumption (which may fall under Scope 2 if the organisation operates its own facilities, or Scope 3 if outsourced to a 3PL). The energy efficiency of the facility, the source of electricity, refrigeration requirements, and material handling equipment all influence the emissions profile.

The Data Challenge

The single biggest barrier to meaningful Scope 3 management is data. Most organisations do not have supplier-level emissions data for the majority of their supply base. They rely on spend-based estimates, which apply a generic emissions factor per dollar of procurement spend in a given category. This approach produces a directional estimate of Scope 3 magnitude but is almost useless for identifying specific reduction opportunities, comparing suppliers, or tracking progress over time.

Moving from spend-based estimates to activity-based or supplier-specific data is a multi-year journey. It requires investment in data collection systems, supplier engagement, internal capability, and a realistic assessment of where to start.

The practical approach is to prioritise. Identify the procurement categories and suppliers that represent the largest portion of your Scope 3 footprint, typically the top 20 to 30 suppliers will account for 60% to 80% of supply chain emissions, and focus data collection efforts there first. Engage those suppliers directly, explain what data is needed and why, and work with them to establish reporting mechanisms. For the long tail of smaller suppliers, spend-based estimates will remain the default for some time, and that is acceptable under the reporting standards provided the methodology is disclosed and consistent.

The technology landscape for Scope 3 data management is maturing but still fragmented. There are platform-based solutions that aggregate supplier data, calculate emissions using multiple methodologies, and integrate with procurement and ERP systems. There are also industry-specific initiatives developing sector emission factors and data-sharing protocols. The right approach depends on the organisation's scale, complexity, existing systems, and the maturity of its supplier base.

What Boards and CFOs Need to Understand

Scope 3 is not a sustainability team deliverable. It is a cross-functional programme that requires investment, governance, and executive sponsorship. Boards and CFOs need to understand several things.

The reporting obligation is real and enforceable. Mandatory climate reporting under AASB S2 carries compliance obligations equivalent to financial reporting. Non-compliance penalties mirror those under the Corporations Act. Disclosures will be subject to assurance, progressing from limited to reasonable assurance over a phased timeline. This is not a voluntary reporting exercise.

The data will be imperfect for some time, and that is expected. The standards acknowledge that Scope 3 measurement is inherently more complex and less precise than Scope 1 and 2. There is a three-year protection from litigation specifically related to Scope 3 disclosures, recognising the immaturity of data and methodologies. The obligation is to make reasonable efforts, disclose the methodology used, and improve data quality over time.

Scope 3 creates strategic risk and opportunity simultaneously. Organisations that understand their value chain emissions can identify transition risks (exposure to future carbon pricing, regulatory tightening, or customer requirements), manage those risks proactively, and capture the efficiency gains that often accompany decarbonisation. Organisations that treat Scope 3 purely as a compliance burden will do the minimum, spend the money, and miss the strategic value.

The investment required is not trivial. Building the supplier data collection capability, the internal analytical capacity, the governance framework, and the cross-functional coordination to manage Scope 3 effectively requires dedicated resources. For large, complex organisations, this is a programme of work that takes two to three years to reach maturity, and it needs to start now if it has not already.

What Good Looks Like

Organisations that are managing Scope 3 well share several characteristics.

They have governance that connects sustainability, procurement, and supply chain. Scope 3 is not siloed in a sustainability function. There is a cross-functional steering group or working group that includes procurement, supply chain, finance, and sustainability, with clear accountability and reporting lines to the executive team.

They have prioritised based on materiality. They have completed a Scope 3 screening using spend-based estimates to identify the largest categories and the suppliers that contribute most to the footprint. Detailed data collection and reduction planning is concentrated on these material categories first, not spread thinly across the entire supply base.

They are engaging suppliers as partners, not policing them. The most effective organisations are working with their key suppliers to build capability, share tools, and develop joint reduction plans. They recognise that many suppliers, particularly mid-market and SME suppliers, do not yet have the systems or expertise to measure and report their own emissions, and they are providing practical support to bridge that gap.

They are embedding emissions into procurement decisions, not bolting them on. Emissions data is visible alongside cost, quality, and delivery data in category reviews and sourcing decisions. It is weighted appropriately in tender evaluations, and it is referenced in contract negotiations. This does not mean every procurement decision is optimised for emissions. It means emissions are a factor that is considered, not ignored.

They are setting realistic targets. Rather than headline commitments that are disconnected from operational reality, they are setting Scope 3 reduction targets that are grounded in the actual levers available: supplier switching, specification changes, logistics optimisation, packaging redesign, and energy transition across the supply base.

How Trace Consultants Can Help

Trace works with Australian organisations to connect Scope 3 obligations to supply chain and procurement strategy, ensuring that emissions management is embedded in the functions that actually control the levers.

Scope 3 materiality assessment and supply chain mapping. We conduct structured assessments to identify where Scope 3 emissions concentrate across your supply chain, which categories and suppliers are material, and where the data gaps are. This provides the foundation for a targeted programme of work rather than an unfocused compliance exercise.

Procurement strategy and category management. We integrate emissions considerations into procurement strategy, category plans, and sourcing processes, ensuring that Scope 3 is a genuine input to supplier selection, contract design, and performance management without derailing commercial outcomes.

Supply chain optimisation for emissions reduction. We identify and quantify the operational levers available across logistics, warehousing, packaging, and waste, where supply chain design and operational decisions directly influence Scope 3 performance.

Supplier engagement programme design. We design supplier engagement frameworks that are practical, proportionate, and aligned to your data maturity, helping you collect the right data from the right suppliers without creating an administrative burden that neither party can sustain.

Explore our Supply Chain Sustainability services →Explore our Procurement services →Speak to an expert at Trace →

Getting Started

The starting point is a Scope 3 screening. If you have not already estimated your Scope 3 footprint at a category level, that is the first step. It does not need to be precise. It needs to be directional enough to tell you where the material emissions sit and where to focus your effort.

From there, the work is about building the systems, processes, and supplier relationships that allow you to move from estimates to actual data, and from reporting to reduction. The organisations that start this work now will be better positioned when assurance requirements tighten, when customers and investors start benchmarking Scope 3 performance, and when the competitive landscape shifts to reward supply chains that can demonstrate genuine decarbonisation progress.

The regulatory mandate is clear. The commercial logic is sound. And the supply chain is where the work needs to happen.

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There's a moment in every fleet transition where the conversation shifts. It starts with the vehicle — what can we buy, what does it cost, does it pass the performance tests? And then, fairly quickly, the harder questions land. Where do we charge it? How do we keep it on the road? What happens to our depots? What about regional stations? Who maintains the thing? And what does this mean for how we roster, deploy and sustain an operational fleet that can't afford a single shift of downtime?

That's where Australian police forces are right now.

NSW Police has been running exhaustive trials at the Police Driver Training Centre in Goulburn, testing electric vehicles from multiple manufacturers through braking, cornering and pursuit-readiness assessments. Queensland Police took delivery of a Kia EV6 GT Line as their first fully electric highway patrol car. Victoria Police has tested Teslas. Western Australia recently rolled out Volkswagen Touareg R plug-in hybrids for highway patrol. And the BMW 530d — the workhorse of highway patrol in NSW and Victoria — is itself transitioning, with hybrid successors already entering fleets.

The direction of travel is clear: Australia's police highway patrol fleets will increasingly electrify over the coming decade. The operational performance of modern EVs — acceleration, handling, braking — is more than adequate for patrol work. In many cases it's superior. The economics of electric drivetrains, over a total cost of ownership lifecycle, are increasingly favourable. And the policy settings — federal and state emissions reduction targets, government fleet electrification mandates, sustainability reporting requirements — are creating momentum that isn't going to reverse.

But here's the thing that most of the public conversation misses: the vehicle is the easy part.

The genuinely complex challenge — the one that will determine whether this transition succeeds or stumbles — is the supply chain. Not in the narrow sense of "where do we buy the cars," but in the full operational sense: how do you redesign the infrastructure, logistics, maintenance, parts management, workforce capability and deployment models that sit behind a 24/7, mission-critical fleet?

That's a supply chain problem. And it deserves supply chain thinking.

Why this isn't just a procurement exercise

When police forces replaced Holden Commodores with BMWs, or transitioned from Ford Falcons to Kia Stingers, the underlying operating model didn't fundamentally change. You still refuelled at a petrol station. You still sent the car to a workshop with the same tools and the same technicians. The depot layout, the shift patterns, the parts supply chain — all broadly stayed the same.

Electric vehicles break that continuity.

The energy source changes entirely — from a liquid fuel that's dispensed in minutes at ubiquitous locations to an electrical charge that takes time, requires fixed infrastructure, draws significant power, and creates entirely new planning constraints. The maintenance profile changes — fewer moving parts, less frequent servicing, but different failure modes, different diagnostic tools, different technician skills, and a different parts supply chain. The depot and station infrastructure changes — electrical capacity, charging equipment, spatial layout, safety systems, and the relationship between the fleet and the built environment all need rethinking.

These aren't minor adjustments. They're structural changes to the operating model of a fleet that must be available around the clock, in all conditions, across vast geographies — with zero tolerance for capability gaps.

For government and defence agencies, where fleet availability is directly linked to public safety and operational readiness, the stakes are as high as they get.

The charging infrastructure challenge

Charging is where the supply chain complexity hits hardest. A highway patrol vehicle isn't a commuter car that drives 40 kilometres to an office and sits in a car park for eight hours. It's a high-utilisation asset that may cover hundreds of kilometres in a shift, across unpredictable routes, with no guaranteed return to base during operational hours.

That creates a set of infrastructure requirements that are fundamentally different from typical fleet electrification.

Depot charging is necessary but not sufficient. Every police station and highway patrol base will need charging infrastructure — that much is straightforward. But the electrical capacity of most existing stations was never designed for this. A single Level 2 (AC) charger draws around 7–22 kilowatts. A DC fast charger can draw 50–350 kilowatts. Multiply that across a fleet of patrol vehicles that all return to base within a similar window, and you quickly hit the limits of the site's electrical supply. Substation upgrades, switchboard replacements, cable runs, load management systems — these are capital works that require planning, approvals and lead times measured in months, not weeks.

Regional and remote stations face acute constraints. Highway patrol doesn't just operate out of metropolitan depots. It operates from stations in regional towns where grid capacity is limited, where the nearest fast charger might be an hour away, and where a vehicle being out of service for extended charging isn't operationally acceptable. Solving for regional deployment requires a different approach — potentially including on-site battery storage, solar generation, or strategic placement of dedicated police charging infrastructure along key patrol corridors.

En-route charging needs to be reliable and fast. Australia's public fast-charging network has grown significantly — reaching over 1,270 fast-charging sites by mid-2025 — but it wasn't designed for emergency services. Charger reliability, access priority, and coverage gaps on key highway corridors all create operational risk. Police forces will likely need either dedicated charging infrastructure or guaranteed-access arrangements at commercial sites to ensure vehicles can be recharged during shifts without compromising response capability.

Load management becomes an operational planning problem. When you have a depot with 15 patrol vehicles and 10 charging points, deciding which vehicles charge first, at what rate, and in what sequence is no longer a facilities management question — it's a fleet operations question. Smart charging systems that integrate with roster and dispatch data can optimise this, but they need to be designed, procured, installed and governed as part of the operating model, not bolted on afterwards.

This is where strategy and network design disciplines become critical. The charging network for a police fleet isn't just a facilities project — it's a supply chain network that needs to be designed around operational demand, geographic coverage, and reliability requirements.

Rethinking depot and station design

Charging infrastructure is one dimension. But the physical layout of police stations, depots and workshops also needs to change — and this is often underestimated.

Traditional police vehicle bays are designed for internal combustion engine (ICE) vehicles: fuel storage, exhaust extraction, oil and fluid management, and workshop layouts optimised for mechanical servicing. Electric vehicles introduce different spatial requirements. Charging bays need dedicated electrical infrastructure, cable management and potentially ventilation for thermal management. Workshop areas need to accommodate high-voltage battery safety protocols, including isolation procedures and specialist equipment. Storage for EV-specific parts and consumables — which differ materially from ICE parts — needs to be incorporated into existing stores.

For agencies managing hundreds of stations across a state, retrofitting these facilities is a substantial capital and logistics program. It requires site-by-site assessment, electrical engineering design, construction coordination, and a sequencing plan that doesn't compromise operational capability during the transition.

This connects directly to back-of-house logistics and warehousing and distribution thinking. How do you design physical infrastructure to support a changing fleet without disrupting current operations? How do you stage the rollout so that early sites become proof points, not bottlenecks? And how do you manage the parallel running of ICE and EV infrastructure during what will inevitably be a multi-year transition?

The maintenance and parts supply chain

The maintenance profile of electric vehicles is genuinely different from ICE vehicles — and for police highway patrol, those differences have operational consequences.

On the positive side, EVs have fewer moving parts, require less frequent routine servicing, and eliminate entire maintenance categories (oil changes, transmission servicing, exhaust system repairs). Over the vehicle lifecycle, this should reduce total maintenance cost and, critically, reduce unplanned downtime from mechanical failures.

On the other hand, the maintenance that EVs do require is different. Battery health management, high-voltage electrical systems, thermal management systems, regenerative braking calibration, and software updates all demand specialist tools, diagnostic equipment and technician training that most police fleet workshops don't currently possess.

The parts supply chain also shifts. The traditional police fleet MRO catalogue — filters, belts, brake components, fluids, mechanical wear parts — is largely replaced by a different set of items: battery modules, electric motor components, power electronics, charging connectors, and software-driven control units. Many of these are sourced through OEM-controlled supply chains with longer lead times and less aftermarket competition than traditional parts.

For agencies that manage fleet maintenance in-house, this means a significant capability uplift: training programs for existing technicians, recruitment of high-voltage specialists, investment in diagnostic and safety equipment, and a wholesale review of the parts catalogue, stocking policy and supplier base.

For agencies that outsource fleet maintenance, it means renegotiating service contracts, redefining performance requirements, and ensuring that service providers have the capability and capacity to support an electric fleet at the required service levels.

Either way, the procurement strategy for fleet maintenance and parts needs to be redesigned — not just tweaked. Category strategies, supplier agreements, inventory policies and performance frameworks all need to reflect the new operating reality.

Workforce capability and change management

Every transition of this nature has a people dimension, and this one is no exception.

Police fleet managers, workshop technicians, station managers, highway patrol officers, procurement teams and rostering staff are all affected. Each group needs to understand what's changing, why, and what it means for how they do their jobs.

Workshop technicians need structured training pathways to develop competence with high-voltage systems — including safety protocols that are materially different from ICE vehicle maintenance. Fleet managers need new planning tools and data to manage charging schedules, vehicle availability and lifecycle costs. Procurement teams need to understand new supplier markets, OEM relationships and total cost of ownership models. And frontline officers need confidence that the vehicles they're driving will perform when it matters and be available when they need them.

This isn't a memo and a half-day workshop. It's a sustained change management program that needs to be designed with the same rigour as the technical transition.

The agencies that handle this well will engage their workforce early, provide clear information about sequencing and support, build internal champions who can demonstrate the benefits from firsthand experience, and create feedback loops that allow the transition plan to adapt based on real operational experience.

Planning the transition: sequencing matters

One of the most consequential decisions in this transition is sequencing — the order in which vehicle types, station locations and capability investments are rolled out.

A common approach is to start with administrative and community engagement vehicles (lower risk, lower utilisation) before progressing to general duties and eventually highway patrol (higher risk, higher utilisation, higher performance requirements). This is the pattern most Australian police forces have followed so far, and it's sensible — it allows the organisation to build experience, test infrastructure, and develop maintenance capability before committing to the most demanding use cases.

Within the highway patrol transition specifically, sequencing decisions include which geographic areas to electrify first (metropolitan before regional, due to charging infrastructure density), which vehicle roles to prioritise (single-officer patrol versus pursuit-rated, for example), and how to manage the transition period where ICE and EV vehicles operate in parallel — requiring dual infrastructure, dual parts catalogues, and dual maintenance capabilities.

The transition period is often the most expensive and complex phase. Running two parallel fleet ecosystems simultaneously creates redundancy costs, training burdens and operational complexity that need to be carefully managed. A well-designed sequencing plan minimises the duration and cost of this parallel period while maintaining operational capability throughout.

This is fundamentally a planning and operations challenge. It requires demand modelling (how many vehicles, where, when), capacity planning (charging infrastructure, workshop capability, parts availability), scenario analysis (what if charging demand exceeds supply? what if a vehicle model is discontinued?), and a governance framework that allows the plan to adapt as real-world data becomes available.

Total cost of ownership: a different equation

Police fleet procurement has traditionally been driven by purchase price, performance specification and whole-of-life cost. Electric vehicles change the equation in several ways.

The upfront purchase price of EVs is currently higher than equivalent ICE vehicles for most segments relevant to highway patrol — though the gap is narrowing as battery costs decline and new models enter the market. However, the total cost of ownership (TCO) calculation is more favourable than the sticker price suggests when you factor in lower energy costs per kilometre (electricity versus fuel), reduced routine maintenance requirements, potential government incentives and fleet discounts, and residual value dynamics (which are still evolving for police-spec EVs).

On the other side of the ledger, the infrastructure investment required — charging equipment, electrical upgrades, depot modifications, workshop retooling — represents a significant capital commitment that doesn't apply to ICE fleet replacements. These costs need to be planned, funded and staged across the transition timeline.

The agencies that make the best decisions will be those that model TCO rigorously, across the full vehicle lifecycle, including infrastructure costs — and use that analysis to inform both procurement timing and budget allocation.

The supply chain resilience dimension

Police highway patrol fleets are, by definition, critical infrastructure. Any disruption to fleet availability has direct public safety consequences. That means the supply chain supporting these fleets needs to be designed with resilience as a primary consideration.

For electric fleets, resilience means ensuring that charging infrastructure has redundancy and backup power, that critical spare parts (particularly battery components and high-voltage systems) are held at appropriate service levels, that multiple supply pathways exist for key components to avoid single-source dependency, that maintenance capability is distributed geographically (not concentrated in a single workshop that becomes a single point of failure), and that the fleet management system can dynamically reallocate vehicles based on charge state, location and operational priority.

These are the same principles that apply to any mission-critical supply chain — but applied to a fleet context where the "customer" is public safety and the "service level" is uninterrupted operational capability.

Lessons from other fleet transitions

Australian police forces aren't the first organisations to navigate this transition. Commercial fleets, public transport operators, logistics companies and military organisations globally are all at various stages of electrification — and their experiences offer useful lessons.

Common themes include the importance of starting infrastructure planning well before vehicle procurement (charging infrastructure typically has longer lead times than vehicle delivery), investing in data and monitoring systems from day one rather than retrofitting them later (real-time charging data, vehicle health data and usage patterns are essential for optimising fleet operations), engaging with energy utilities early to understand grid capacity constraints and connection timelines, and not underestimating the change management requirement — the human dimension of the transition consistently takes longer than the technical one.

The organisations that succeed treat electrification not as a vehicle replacement program but as an operating model transformation — and plan accordingly.

How Trace Consultants can help

At Trace Consultants, we help government agencies and large fleet operators design and implement supply chain strategies for complex transitions — including fleet electrification.

We don't sell vehicles or charging equipment. We bring independent, supply-chain-focused thinking to the decisions that sit around the vehicle: the infrastructure, logistics, procurement, maintenance, workforce and operational planning that determine whether an electric fleet transition actually works in practice.

Fleet supply chain strategy and network design. We help agencies design the physical infrastructure network — depot charging, en-route charging, workshop locations, parts distribution — that supports an electric fleet across diverse geographies. This includes demand modelling, location analysis, capacity planning and sequencing strategy. Our strategy and network design approach ensures decisions are evidence-based and operationally grounded.

Procurement strategy for fleet transition. Electrification changes the procurement landscape — new vehicle categories, new OEM relationships, new maintenance service models, new parts supply chains. We help agencies develop procurement strategies that optimise total cost of ownership, build supply chain resilience and maintain competitive tension.

Maintenance and MRO supply chain design. We redesign the parts catalogue, stocking policies, supplier agreements and workshop capability models for an electric fleet — ensuring that maintenance supply chains support availability targets without over-investing in inventory. Our experience in MRO supply chains across government, defence and asset-intensive industries translates directly to fleet contexts.

Depot and station infrastructure planning. We support agencies with the back-of-house logistics and warehousing design work required to retrofit stations and depots for electric fleet operations — including spatial planning, electrical capacity assessment coordination, and construction sequencing that minimises operational disruption.

Workforce planning and change management. Transitioning to an electric fleet changes how people work — from technicians to fleet managers to frontline officers. Our workforce planning and change management teams help agencies design training programs, stakeholder engagement strategies and transition plans that bring people along rather than leaving them behind.

Resilience and risk management. For mission-critical fleets, we design supply chain resilience frameworks that identify vulnerabilities, build redundancy and ensure operational continuity through the transition and beyond.

Technology enablement. From fleet management systems to charging optimisation platforms to performance dashboards, we help agencies select and implement technology that supports evidence-based fleet management — without over-engineering or creating dependency on tools that don't integrate with existing systems.

The road ahead

The electrification of police highway patrol fleets in Australia is not a question of if, but when and how. The vehicle technology is ready. The policy direction is set. The economic case will strengthen as battery costs fall and charging infrastructure matures.

The agencies that get ahead of this transition — that start planning the supply chain, infrastructure and workforce dimensions now, rather than waiting until the first vehicles arrive — will find the process smoother, cheaper and less disruptive than those that treat it as a straightforward fleet replacement.

Because this isn't just about swapping what's under the bonnet. It's about redesigning the operating model that keeps patrol vehicles on the road, officers in the field, and communities safe. That's a supply chain challenge. And it deserves the same rigour, planning and investment that any critical infrastructure transition demands.

If your agency is planning or evaluating a fleet electrification pathway, we'd welcome the conversation.

Scope 3 Emissions Reporting Guide for Australian Businesses

Written by Caroline Chen, Consultant, co authored by Emma Woodberry, Senior Manager and Sustainability Lead.

Scope 3 comes into the spotlight

Most businesses are familiar with their Scope 1 (direct) and Scope 2 (indirect from purchased energy) emissions. Scope 3 emissions, however, are often less understood – despite typically making up the largest share of an organisation’s total carbon footprint.  

Scope 3 emissions capture greenhouse gases that occur indirectly across an organisation’s entire value chain, both upstream and downstream. This includes emissions from purchased goods and services, transportation, waste, business travel, product use and end-of-life treatment.

Historically, Scope 3 reporting in Australia has been voluntary, meaning these emissions often flew under the radar when assessing sustainability performance. That has changed now with Australia’s Climate-related Financial Disclosure (CRFD) regime, which came into effect on 1 January 2025, requiring entities who meet the threshold to include climate-related disclosures in their annual financial reports lodged with ASIC – and this includes Scope 3 emissions.

Australia’s phased Scope 3 reporting schedule for AASB S2 Climate-Related Disclosures

Why Scope 3 is different – and why preparation and action matters

Scope 3 emissions are widely recognised as the most complex to measure. Challenges include:

• Reliance on data from suppliers and customers across complex value chains

• Use of estimates, proxies, and industry averages rather than direct measurement

• Coordination across procurement, finance, operations, and sustainability teams

• Resource and capability constraints, particularly in early years

Hence, preparation is pivotal for accurate reporting. Although early Scope 3 disclosures may require only limited assurance, reasonable assurance will be expected in later phases. Methodologies, assumptions, and governance decisions made now will form the baseline auditors rely on in future years. Reporting should therefore be viewed as a long-term capability, not a one-off exercise.

Investing early in repeatable, finance-grade processes enables traceable, defensible, and scalable systems. This sets the foundation for long-term success by:

• Reducing compliance and assurance costs

• Avoiding reputational and regulatory consequences

• Strengthening supplier relationships

• Building credible, investor-ready disclosures

• Turning sustainability into a strategic advantage

Smaller businesses who sit outside ASIC reporting thresholds will be affected, as they often form part of the supply chains of large reporting entities. Scope 3 data requests should be expected, making early engagement essential regardless of size.

How businesses can prepare for Scope 3 reporting

Regulators recognise that early reporting will rely on estimates and industry averages. Establishing robust methodologies now ensures these estimates are defensible and improvable over time. A practical preparation approach can be broken into five phases:

Phase 1: Regulatory exposure and reporting boundaries

Clarity before data

• What parts of our organisation and group entities are required to be included in reporting?

• What consolidation approach applies (equity share, control, financial consolidation)?

• Which Scope 3 categories are material for us and therefore in scope?

• What assumptions, exclusions and methodological choices are we making, and are they documented?

Phase 2: Governance and accountability

Who owns Scope 3, and how is it controlled?

• Who is accountable at executive and board level for Scope 3 reporting?

• Who owns the data for each major emissions source (procurement, logistics, travel, etc.)?

• How do finance and sustainability teams work together to reconcile emissions to spend and activity data?

• What internal controls exist for review, approval and change management?

Phase 3: Data foundation and methodologies

Is our data defensible, traceable and repeatable?

• What data do we already have, and where does it live?

• Where can we use activity-based data versus spend-based estimates?

• Which emission factors are we using, and are they credible, current and documented?

• How confident is our data, and can we demonstrate year-on-year improvement?

• Can every number be traced back to a source system or assumption?

Phase 4: Value chain coverage and supplier engagement

Are we focusing effort where it matters most?

• What does our upstream and downstream value chain look like?

• Which suppliers and activities drive the majority of Scope 3 emissions?

• How are we engaging priority suppliers to collect data in a consistent way?

• How are emissions expectations reflected in procurement processes and contracts?

• What is our plan to improve supplier data quality over time?

Phase 5: Assurance readiness and strategic integration

Is Scope 3 embedded, not bolted on?

• Are we ready for internal review or external assurance of Scope 3 data?

• How are Scope 3 risks reflected in enterprise risk management and climate scenarios?

• How do emissions insights influence strategy, capital allocation and supplier decisions?

• Do we have an established reporting rhythm and improvement roadmap, rather than an annual exercise?

Turning Scope 3 Preparedness into Strategic Value

Building robust Scope 3 tracking systems is not just about preparing for future reporting requirements – it is the critical first step to achieving real emissions reduction and business impact. By investing early in high-quality data, governance, and supplier engagement, organisations create the foundation needed to actively manage and reduce Scope 3 emissions, rather than simply report on them.

This groundwork unlocks far more than compliance. It enables meaningful emissions reduction through smarter supplier selection and contract optimisation, product and material redesign, logistics and transport efficiency, energy and electrification strategies, and more informed capital investment decisions.

In parallel, these capabilities drive wider strategic benefits. Improved visibility across procurement, logistics, and product design strengthens strategic decision-making, supporting smarter, lower-risk choices. Transparent, credible disclosures enhance reputation and competitiveness, building trust with investors, customers, and employees. At the same time, value-chain insight fuels efficiency and innovation, highlighting opportunities for cost reduction and operational improvement.

Organisations that prepare now can turn Scope 3 tracking into a powerful business capability – transforming emissions management into a lasting competitive advantage.

How Trace can help

Preparing for Scope 3 reporting requires more than spreadsheets and one-off calculations. It demands structured data, governance, and audit-ready processes that evolve over time.

Trace supports organisations by:

• Translating CRFD requirements into clear, practical actions

• Identifying material Scope 3 categories and defining defensible boundaries

• Establishing traceable calculation methodologies aligned to the GHG Protocol

• Integrating emissions data with procurement, finance and operational systems

• Supporting supplier engagement and data collection at scale

• Building documentation and controls that stand up to future assurance

• Turning emissions insights into strategic and cost-saving opportunities

• Supporting Sustainability Report development  

We understand complex supply chains, and our deep expertise in operational environments, data analysis, and sustainable solutions can help you on your sustainability journey.

By starting early with the right foundations, businesses can move confidently from compliance to capability – and from disclosure to long-term value creation. Organisations that prepare now will ultimately be more prepared to thrive in the advancing sustainable business area, leveraging this legislation shift as an opportunity.  

Preparing for Scope 3 reporting doesn't have to be overwhelming. Our team understands complex supply chains and can guide you through every phase—from defining boundaries to building assurance-ready systems. Let's talk about how we can support your sustainability goals, contact one of our experts today.