PFAS contamination has moved from a niche regulatory concern to a mainstream due diligence issue, and the rules governing it are getting stricter. Through 2025 and into 2026, the national framework for managing PFAS in soil and water has been substantially revised, and the guideline values that decide whether a site is ‘clean’ have come down. If you own, develop, or manage land in Queensland, that shift changes what a contaminated land assessment needs to look for, and what a site is worth.
Per- and poly-fluoroalkyl substances (PFAS) are a large family of manufactured chemicals used for decades in firefighting foams, industrial processes, and a range of consumer products because they resist heat, water, and grease. The same durability is the problem. PFAS do not readily break down, which is why they are often called ‘forever chemicals’. They accumulate in soil, migrate into groundwater and surface water, and persist for generations.
For landowners, the practical consequence is that PFAS can be present on a site with no visible sign at all. Former industrial premises, fire training grounds, airports, defence land, waste facilities, and properties downgradient of any of these can carry a legacy that only surfaces in a soil or groundwater sample.
The PFAS National Environmental Management Plan (NEMP) is Australia's national guide for managing PFAS contamination. It is developed jointly by the Commonwealth, state and territory, and New Zealand governments through the Heads of EPA Australia and New Zealand (HEPA), and it shapes how regulators and consultants assess contaminated sites across the country.
On 4 March 2025 the Commonwealth released PFAS NEMP 3.0, the most significant overhaul of the plan to date. It introduced revised health-based and ecological guideline values for soil, surface water, groundwater, and biota, and placed a stronger emphasis on the remediation hierarchy — prioritising treatment of PFAS over disposal to landfill. It also added guidance on how to demonstrate that remediation has actually worked, and how to manage long-term residual risk where contamination cannot be fully removed.
That work has continued into 2026. PFAS NEMP 3.1 incorporates updated guideline values for PFOS in fresh and marine water, following revised values released by the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZG) in March 2026. The direction of travel is clear: the thresholds are tightening, not loosening.
The pressure is not limited to the NEMP. In June 2025 the National Health and Medical Research Council (NHMRC) updated the PFAS values in the Australian Drinking Water Guidelines, lowering the figure for PFOS to 8 nanograms per litre, alongside values of 200 ng/L for PFOA, 30 ng/L for PFHxS, and 1000 ng/L for PFBS. Lower water thresholds matter for land because groundwater is often the pathway that connects a contaminated site to a receptor.
The list of regulated substances is also growing. A Commonwealth consultation on proposed environmental standards for additional PFAS chemicals — including PFHpS, PFNS, and PFBS — under the Industrial Chemicals Environmental Management Standard (IChEMS) closed on 24 April 2026, with outcomes expected before the end of June 2026. Substances that were not previously a focus of assessment may soon need to be.
Tighter guideline values have a direct commercial effect. A concentration that passed an assessment under earlier criteria may exceed the current values, which can change a site's classification, its permitted land use, and the cost of making it development-ready.
For anyone buying, selling, or developing land, the implications are practical:
In Queensland, assessment of site contamination is carried out under the national framework, and investigations should be designed and signed off by a suitably qualified person. PFAS adds a layer to that work: the sampling strategy, laboratory methods, and screening criteria all need to reflect the current NEMP and water guideline values rather than superseded ones.
The cheapest PFAS problem is the one you find early. A preliminary site investigation that reviews land history and identifies potential PFAS sources can tell you whether further sampling is warranted before you commit to a purchase or lock in an excavation method. Where contamination is confirmed, a clear assessment against current criteria gives you the evidence base to plan remediation, classify waste correctly, and satisfy regulators, lenders, and buyers.
The regulatory tightening through 2025 and 2026 is not a reason to panic. It is a reason to get ahead of the question on your sites, with assessment that reflects the rules as they stand now.
BBN Consulting provides contaminated land assessment and environmental due diligence across Queensland, designed around the current PFAS framework. If you have a transaction, development, or remediation project where PFAS could be in play, talk to BBN before ground is disturbed. Get in touch or call 0421 748 867.
