Market requirements
Sustainability requirements of Australia's major data centre customers
What each major operator building in Australia expects from its electrical and data contractors, plus the NSW fast-tracking framework and what it means for Prime.
Operator-by-operator requirements
AirTrunk
Hyperscale campuses in Sydney, Melbourne, Canberra, Perth (plus APJ)Net Zero emissions by 2030 covering Scope 1 and Scope 2, announced October 2022.
Commits that 100% of electricity consumed at its data centres is covered by a net zero target, held either by AirTrunk or its customers. Monitors, measures and reports Scope 3 and is developing a roadmap to manage it — which flows directly onto contractors as requests for measured Scope 1 and 2 data and equipment embodied carbon.
What it means for Prime: Highest-pressure customer for Prime. Expect mandatory annual Scope 1 and 2 disclosure plus activity data to support AirTrunk's Category 1 and 2 reporting.
Source: airtrunk.com — Net Zero CommitmentCDC Data Centres
Canberra, Sydney, Melbourne, AucklandTargeting Net Zero emissions by 2030. New Zealand data centres Toitū net carbonzero certified since their first year of operation.
Certification-based approach means auditable supply chain data. Toitū certification requires verified emissions boundaries, which pushes measurement and evidence requirements down to trade contractors.
What it means for Prime: Certification audits mean Prime's data must be documented and traceable to source documents, not estimated.
Source: cdc.com — For a Stable PlanetNEXTDC
National — every mainland capitalCarbon-neutral certified data centres; offers customers net-zero emissions for IT housed in its facilities.
Carbon neutral certification of the facility depends on a complete and defensible inventory, including construction and fitout activity. Contractors are asked for project-level energy, fuel and waste data.
What it means for Prime: Prime should expect project-level monthly reporting obligations written into contract, not just a prequalification questionnaire.
Source: nextdc.com — Carbon NeutralVantage Data Centers
Melbourne (Tullamarine), SydneyGlobal sustainability programme with science-based emissions targets and supplier engagement on embodied carbon.
Sustainability weighted within tender evaluation; requires contractor emissions data, waste diversion rates and embodied carbon information for major electrical equipment.
What it means for Prime: Prime already delivers the Tullamarine 64MW fitout — the incumbent relationship makes data readiness a retention issue, not just a bid issue.
Source: Prime project record (Vantage Data Centre – Tullamarine) and Vantage sustainability disclosuresAWS (via Lendlease delivery)
Sydney and Melbourne regionsAmazon targets net-zero carbon by 2040 and 100% renewable electricity; Lendlease targets absolute zero carbon by 2040 with Scope 3 included.
Prime contracts through Lendlease, whose Scope 3 target explicitly covers its supply chain. Lendlease requires subcontractor emissions data, embodied carbon reporting on materials and waste diversion evidence.
What it means for Prime: Prime's data flows into two stacked Scope 3 inventories (Lendlease then AWS) — the most demanding evidence chain of any customer.
Source: Prime project records (AWS 063/064 for Lendlease) plus Lendlease and Amazon public climate targetsMicrosoft Azure (Australia East/Central)
Sydney, Melbourne, CanberraCarbon negative by 2030; requires suppliers to report emissions and use carbon-free electricity.
Microsoft's Supplier Code of Conduct requires suppliers to disclose emissions data through CDP-style reporting and progressively decarbonise. Embodied carbon in construction materials is a named focus area.
What it means for Prime: Formal supplier code compliance would be required — currently Prime has no policy set to point to.
Source: Microsoft public sustainability commitments and Supplier Code of ConductLatest announcement
NSW will fast-track data centres that meet world-class environmental and efficiency standards
On 23 March 2026 the Australian Government published its Expectations of Data Centres and AI Infrastructure Developers, setting five national expectations that will shape Commonwealth regulatory priorities. NSW moved immediately to align through its NSW Data Centre Consultation Paper, proposing five planning principles to be embedded into the assessment framework for state significant development applications. At the same time, NSW announced that 15 data centre development applications with a combined value of $51.9 billion have been endorsed by the Investment Delivery Authority for fast-tracked assessment — on top of approximately 90 data centres already operating in the state. In short: proposals that demonstrate genuine energy and water efficiency and transparent data get accelerated; those that cannot, do not.
The five NSW planning principles
- Data centre investment should enable a wider technology ecosystem that drives job creation and economic growth.
- Developers and operators must fund their own infrastructure requirements, beyond what is already planned and funded, to avoid increasing household prices.
- Data centres must be efficient and make sustainable use of energy, water systems and the environment.
- Approval and compliance must be based on reliable and transparent data.
- Regulatory and planning settings must account for differences in data centre size, location and community needs.
What NSW fast-tracking means for Prime
"Reliable and transparent data" becomes a contract requirement
Principle 4 makes data quality a planning condition, not a marketing preference. Operators pushing to be fast-tracked must be able to evidence energy, water, embodied carbon and e-waste performance — and they can only do that if their electrical contractor supplies auditable data. Prime's measured Scope 1 and 2 inventory becomes a commercial asset.
Embodied carbon and e-waste move into scope
Assessment focus areas now explicitly include embodied carbon and e-waste management alongside energy and water demand. For Prime that means Environmental Product Declarations for switchgear, cable, containment and transformers become tender attachments, and cable and equipment offcut recovery rates get scrutinised.
Air quality from backup generation is under assessment
Backup generation air quality impacts are a named assessment focus. Prime specifies and commissions standby diesel gensets — HVO-capable specification and reduced-runtime commissioning protocols become differentiators Prime can offer proponents.
A $51.9 billion pipeline is being fast-tracked
NSW announced 15 data centre development applications worth a combined $51.9 billion endorsed by the Investment Delivery Authority for fast-tracked assessment, on top of roughly 90 data centres already operating in the state. This is a large near-term volume of electrical and prefabrication work — accessible to contractors who can satisfy the environmental evidence conditions attached to fast-tracking.
It creates a reason for Prime to expand beyond Victoria
Prime's data centre delivery is currently Melbourne-centred. The NSW pipeline, combined with efficiency-linked fast-tracking, is the clearest growth case for a Sydney presence — but entry will require the sustainability credentials Prime does not yet hold (target, ISO 14001, renewable electricity).
Currency of this information
Operator commitments and the NSW framework were verified against public sources in August 2026. The NSW guidelines are still being developed following consultation (submissions closed 8 May 2026), so final requirements may tighten. Re-verify before quoting specific operator targets in a submitted tender response.