PFAS Regulation in 2026: What’s Actually Moving Across ADWG, IChEMS and State Frameworks
- Emily Cox
- 1 day ago
- 7 min read
In the span of five months around mid-2025, every major layer of Australia’s PFAS regulatory framework moved—the compliance burden for utilities now more than ever is system mapping rather than addressing any one layer in isolation.
Consider a mid-sized regional utility that, in late 2024, identifies PFOS and PFHxS concentrations trending toward the incoming revised ADWG. It invests in GAC treatment, updates its DWQMP, and when the final values are published in June 2025, treated water sits comfortably below the new limits. The drinking-water compliance problem appears solved.
Twelve months later, the first media change cycle arrives. The used GAC exceeds the IChEMS Schedule 7 unintentional contamination threshold, meaning it can no longer be treated as conventional waste. At the same time, the utility’s biosolids program comes under review as state regulators tighten expectations following NEMP 3.0.
The utility remains complaint with drinking-water requirements throughout, yet new operational and disposal problems continue to emerge. That is because PFAS regulation in 2026 is not a single rule or number; it is a regulatory stack spanning nine separate jurisdictions (state, territory, Commonwealth) and many agencies, whereby compliance in one layer does not extinguish the problem in another.
The Water Quality Layer
Developed by the NHMRC, the Australian Drinking Water Guidelines (ADWG) are a set of national standards for microbiological, chemical, and aesthetic parameters, including risk management frameworks. While only guidelines rather than enforceable laws, ADWG acts as a scientific framework used by state and territory health departments, regulators, and water utilities for the purpose of drinking water management.
The implementation is done primarily through drinking water legislation. In Queensland, for instance, the Water Supply (Safety and Reliability) Act 2008 requires water service providers to prepare a Drinking Water Quality Management Plan (DWQMP), have it approved by the regulator, implement and review it, and report on it annually. NSW requires water utilities to have a Drinking Water Management System (DWMS) and report to NSW Health, who can issue improvement notices and orders.
Regardless of the state or territory, the plans used to ensure drinking water quality should be reviewed when there is a significant to the guidelines. The June 2025 ADWG revision is precisely that trigger.
PFAS first entered the ADWG in 2018. The table below compares the PFAS ADWG guidelines from 2018 and the updated July 2025 values. The final PFOS value differs from the October 2024 draft of 4 ng/L, following NHMRC’s adoption of the Gamma model over the US EPA dose-response model—utilities that reviewed governance against the draft should confirm their documentation reflects the final numbers.
PFAS | Previous ADWG Values (2018) | Updated ADWG Values (2025) |
PFOA | Based on human health considerations, the concentration of perfluorooctanoic acid (PFOA) in drinking water should not exceed 560 ng/L. | Based on human health considerations, the concentration of PFOA in drinking water should not exceed 200 ng/L. |
PFOS | Based on human health considerations, the sum of the concentrations of PFOS and perfluoro hexane sulfonate (PFHxS) in drinking water should not exceed 70 ng/L. | Based on human health considerations, the concentration of PFOS in drinking water should not exceed 8 ng/L. |
PFHxS | Based on human health considerations, the concentration of PFHxS in drinking water should not exceed 30 ng/L. | |
PFBS | No health-based guideline value. | Based on human health considerations, the concentration of PFBS (perfluorobutanesulfonic acid) in drinking water should not exceed 1000 ng/L. |
GenX Chemicals | No health-based guideline value. | No health-based guideline value can be derived at this time. |
The WSAA has noted that most utilities currently sit below the new guideline values, but the NHMRC has cautioned that, ‘the existence of other water supplies with higher PFAS levels cannot yet be ruled out’. Historically, PFAS was treated as an investigative contaminant only where a PFAS source was suspected. The Blue Mountains case—where PFAS contamination from legacy firefighting foam went undetected until 2024—illustrates why this approach is no longer defensible. While there is evidence that PFAS testing is frequently conducted in metropolitan water utilities, testing across all of Australia is more limited. Moreover, finding low results in a singular testing of PFAS was often used as justification for low PFAS risk and therefore little need to include PFAS in routine monitoring. With the 2025 update to the ADWG, in addition to the Executive Director of NHMRC Mr. Singh acknowledging addition PFAS may be reviewed in the future, the vocal criticisms of the ADWG PFAS guidelines being more lenient than in other countries such as the United States, along with community concerns, this explanation will become harder to justify.
Even so, WSAA has stated that, due to Australia’s high quality drinking water, ‘…most water utilities are unlikely to need treatment interventions at this point.’ Regardless, some utilities, particularly those in regional areas, will experience high costs as a result of needing to treat PFAS in drinking water. Even without the compliance costs of new infrastructure, the revised ADWG guidelines will still likely cause increased costs, as sensitive water testing and monitoring will be required. WSAA advised that testing costs using the more sensitive testing methods could increase costs by 30-100%.
Treatment options for PFAS in drinking water are all both complicated and costly. GAC and ion exchange resin are the most common, though spent media becomes PFAS-concentrated controlled waste. Nanofiltration and reverse osmosis are among the more effective options, the latter of which has demonstrated over 99% PFOS removal. Additionally, emerging approaches such as foam fractionation show significant potential. There is no one-size-fits-all solution, and effective treatment often requires integrating several technologies. Critically, all removal processes concentrate rather than destroy PFAS, which is why treatment decisions made to solve the drinking water problem inevitably create a residuals management problem downstream.
The Environmental Layer
The regulatory picture becomes more complex once utilities move beyond drinking water compliance into waste, biosolids, and residuals management.
The revised ADWG also has flow-on implications beyond drinking water. The guidelines are sometimes used as a reference point for recycled water approvals, and there are currently no national PFAS guidelines for recycled water; the Recycled Water Guidelines are being updated as a priority but the work is incomplete. Utilities operating recycled water schemes face genuine uncertainty about which standard applies and should be tracking the update process actively.
Unlike drinking water treatment, wastewater treatment has no equivalent PFAS removal capability. As such, ‘PFAS received at wastewater treatment plants end up in biosolids’. Some advanced technologies such as thermal treatment are being explored but remain extremely energy-intensive and expensive.
The PFAS National Environmental Management Plan (NEMP) was developed collaboratively by all state and territory EPAs through HEPA, and provides nationally consistent guidance on contaminated site assessment, landfill disposal, transport, storage, trade waste and—from NEMP 3.0, adopted in December 2024 and released in March 2025—risk-based criteria for biosolids reuse for the first time. The NEMP is not legislation. Its limits are advisory unless a jurisdiction has incorporated them into enforceable regulation, and the Department of Environment has confirmed there are no dedicated resources overseeing whether states are applying it. Queensland has had enforceable biosolids PFAS limits since 2020 (a PFOS trigger of 1 μg/kg under its End of Waste Code), predating the national criteria by four years. Other states are implementing NEMP 3.0 to varying degrees, but specific enforceable limits outside Queensland are not uniformly established.
IChEMS was administered by DCCEEW under the Industrial Chemicals Environmental Management (Register) Act 2021. Where the NEMP manages contamination already in the environment, IChEMS acts upstream to control chemicals in commerce. The Schedule 7 listing of PFOS, PFOA, and PFHxS came into force on 1 July 2025, meaning industrial uses of these chemicals are to be phased out. Schedule 7 also establishes an unintentional contamination threshold of 25 μg/kg, determining when waste materials containing these PFAS must be treated as controlled rather than conventional waste. Spent GAC from drinking water treatment will almost by definition exceed this threshold, meaning it is not conventional waste; landfill acceptance criteria, transport requirements, and contractor obligations all change accordingly. This cost arrives with the first media replacement cycle and is rarely captured in original capital estimates.
IChEMS does not cover all PFAS sources. The industrial chemical pathway is now prohibited, but the diffuse consumer product pathway, which contributes significantly to what utilities receive through household drainage, remaining largely unaddressed. The Waste Management and Resource Recovery Association have stated their dissatisfaction with the current listing, arguing it is ‘wholly insufficient’, and waste services are held to strict output thresholds for contamination arriving through input streams with still no equivalent controls.
Jurisdictional adoption of IChEMS is uneven. As of May 2026, only Queensland, NSW, and Victoria have fully adopted it; WA and NT have not. The register is also expanding, with twelve additional PFAS compounds expected to be scheduled in the 2025-2026 financial year. Utilities that have mapped their exposure only against the three currently schedule compounds are working with an incomplete picture. Looking further ahead, the Department of Environment has confirmed that all PFAS are expected to eventually be listed on the IChEMS Register, and the newly established Environment Protection Australia has been identified by the WSAA as the most promising vehicle for aligning NEMP and IChEMS processes and providing the national coordination that currently does not exist.
What utilities need to act on
The stack is now operative across all its layers simultaneously for the first time. Review the management systems against the June 2025 final values (not the October 2024 draft), rebuilding risk assessments, monitoring frequencies, and escalation triggers for the new threshold. Review spent GAC and ion exchange disposal arrangements against Schedule 7 classification requirements, not conventional waste rates. Assess biosolids concentrations against NEMP 3.0 criteria and the applicable state standard. Review industrial trade waste conditions against the Schedule 7 prohibition now in force. Map exposure against the twelve additional IChEMS compounds expected soon. Where you operate across jurisdictions, confirm the specific regulatory posture of each.
The utilities best placed to manage what is coming are not those asking only whether they are compliant. They are those asking whether they are managing PFAS coherently across its full lifecycle from source to disposal, and whether every layer of the stack is fully understood and accounted for.
References
NHMRC. (2026, April 22). Australian Drinking Water Guidelines. https://www.nhmrc.gov.au/about-us/publications/australian-drinking-water-guidelines
One Water. (2026, February 28). ADWG Explained: what the guidelines actually require. https://www.onewateraustralia.com.au/article/adwg-explained-what-guidelines-require
Department of Regional Development, Manufacturing and Water. (2022, October 1). Guideline for the preparation, review and audit of drinking water quality management plans. https://www.rdmw.qld.gov.au/__data/assets/pdf_file/0010/1655398/dwqmp-guideline-prep-review-audit.pdf
New South Wales Health. (2025, October 29). Water utilities. https://www.health.nsw.gov.au/environment/water/Pages/water-utilities.aspx
Parliament of Australia. (2025, November). PFAS in water supplies. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/PFAS_per_and_polyfluoroalkyl_substances_48P/PFAS48P/Final_report/Chapter_7_-_PFAS_in_water_supplies
Parliament of Australia. (2025, November). PFAS in waste streams and agricultural impacts. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/PFAS_per_and_polyfluoroalkyl_substances_48P/PFAS48P/Final_report/Chapter_9_-_PFAS_in_waste_streams_and_agricultural_impacts
Department of Climate Change, Energy, the Environment and Water. (2026). PFAS national environmental management plan 3.1. https://www.dcceew.gov.au/environment/protection/publications/pfas-nemp-3
Parliament of Australia. (2025, November). PFAS policy, regulation and coordination. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/PFAS_per_and_polyfluoroalkyl_substances_48P/PFAS48P/Final_report/Chapter_10_-_PFAS_policy_regulation_and_coordination
Business Queensland. (2025, March 21). Industrial chemicals environmental management standards (IChEMS). https://www.business.qld.gov.au/running-business/environment/ichems
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