Hypothetically? Not necessarily as an attacker can stage malware in places that will survive a factory reset. Eg: Malware can live in firmware; or recovery volume not wiped in Factory Reset. An extremely resourced attacker could write malicious microcode to your CPU. Can’t reset that.

Realistically? it means CoTS gov grade malware like gamma finfisher etc, which should die when all persistent flash or disk storage is reset.

Practically, I would guess that it’s whatever the capabilities of Australian malware vendors are shipping feature wise for the products you are trying to protect.

“It depends on your threat model”.