Introduction

1.1 The Australian Government established the National Redress Scheme for Institutional Child Sexual Abuse (the Scheme) in response to the Royal Commission into Institutional Responses to Child Sexual Abuse (the Royal Commission).⁷ The Scheme started on 1 July 2018 and operates under the National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (the Act) with a legislated term of ten years.

1.2 The main objectives of the Act are to: ⁸

• to recognise and alleviate the impact of past institutional child sexual abuse and related abuse; and
• to provide justice for the survivors of that abuse.

1.3 The Act states that the objectives are achieved by providing redress to survivors and ‘enabling institutions responsible for abuse of survivors to participate in the Scheme to provide redress to those survivors.’⁹

1.4 Redress under the Scheme consists of:¹⁰

• a monetary payment to survivors as a tangible means of recognising the wrong survivors have suffered; and
• a counselling and psychological component which, depending on where the survivor lives, consists of access to counselling and psychological services or a monetary payment; and
• a direct personal response to survivors from the Participating Institutions and partly Participating Institutions.¹¹

1.5 An applicant is eligible to receive redress if they:

• are an Australian citizen or permanent resident¹²;
• were born before 30 June 2010; and
• experienced sexual abuse while under 18 years of age, in an Australian institution, on the premises of an institution or where activities of an institution took place, or by an official of an institution.

1.6 The Scheme ends on 30 June 2028.¹³ The Act allows for the National Redress Scheme for Institutional Child Sexual Abuse Rules 2018 (the Rules) to extend provisions of the Act, and transitional matters, beyond the Scheme’s end.¹⁴ As at July 2025 the Rules did not include matters beyond the Scheme’s end. The Department of Social Services (the department) received external advice in October 2024 that any such extensions ‘would only operate for one year after the sunset day, i.e. until 30 June 2029.’

1.7 In 2015 the Royal Commission estimated that there were 60,000 eligible survivors who would make a claim for payment under a redress scheme.¹⁵ As at 4 July 2025 the department reported on its website that there had been 63,995 applications under the Scheme, with:

• 22,721 advised a result, of which 19,008 had payments made totalling approximately $1.7 billion dollars;
• 2,979 withdrawn by the applicant; and
• 38,295 awaiting an outcome, with;
  • 25,602 actionable by the Scheme;
  • 6,144 unable to be actioned as either awaiting additional information or undergoing a special assessment; and¹⁶
  • 6,549 applications ‘on hold’.¹⁷

Overview of roles and responsibilities

1.8 Under section 9 of the Act the Scheme Operator is the Secretary of the Department of Social Services. The Scheme Operator was supported by a management structure outlined in Figure 1.1.¹⁸ The Redress Group (the Group) was established in 2019 and was led by a Group Manager (Senior Executive Service Band 2) who is the Redress Scheme Responsible Officer.¹⁹ As at 30 June 2025 there were 707 staff in the Redress Group.²⁰

Figure 1.1: The management structure for the Scheme as at June 2025

Source: ANAO analysis of annual organisational structures for the department.

1.9 The Scheme Operator has delegated the power to make determinations under the Act to Independent Decision Makers (IDMs).²¹ As at 30 June 2025 there were 65 IDMs engaged by the department.

1.10 At the start of the Scheme, the Department of Human Services (now Services Australia) provided services to the Scheme, including managing enquiries from survivors, assessing applications, notifying applicants of outcomes and delivering redress payments to applicants.

1.11 On 5 December 2019 the Prime Minister announced changes to the Social Services portfolio. This Machinery of Government moved Redress Scheme services in the Department of Human Services (now Services Australia) into the Department of Social Services’ Redress Group on 4 February 2020. From that date Services Australia’s role was to provide enabling services to the Scheme, such as ICT, identity management and delivering redress payments to applicants.

Application process

1.12 The Act (subsection 19(1)) specifies that ‘to obtain redress under the scheme, a person must make an application to the Operator.’ The department established an application process for the Scheme to enable the consideration of each application and reach a determination in line with the Act (section 29). Applications to the Scheme were processed using a model where tasks and responsibilities were organised by specific functions or activities. The model did not take an end-to-end case management approach.

1.13 The department’s application management process comprised of six processing stages, summarised in Table 1.1.

Table 1.1: Redress Scheme application stages

Note a: Validity against the criteria set out in subsection 19(2) of the Act.

Note b: See paragraphs 3.8 to 3.11.

Note c: See paragraphs 3.16 to 3.23.

Note d: See paragraphs 3.38 o 3.41.

Note e: The department calls the decision summary the ‘Statement of Reasons’.

Source: The Department of Social Service’s Redress Hub, Maps and Resources Suite (MaRS), accessed 30 January 2025.

1.14 Appendix 3 provides further details of the activities within each stage. Supplementary processes exist for non-standard applications such as:

• a special assessment process for applicants who are imprisoned for five years or more for unlawful killing, sexual offences, terrorism offences, or were a risk to the integrity of the Scheme;
• where an applicant is eligible for an advance payment; and/or referrals are required to assess and manage any risk to the applicant.

Participating Institutions

1.15 Institutions with a history of interacting with children are encouraged to join the Scheme and become Participating Institutions. This enables Participating Institutions determined to be responsible for abuse of survivors to provide redress to those survivors, in line with the Act.

1.16 All Australian Government institutions are Participating Institutions. State, Territory and non-government institutions are Participating Institutions if they agree to participate in the Scheme and the Minister for Social Services makes a declaration that they are a Participating Institution under section 115 of the Act.²²

1.17 The National Redress Scheme for Institutional Child Sexual Abuse Declaration 2018 is a list of all Participating Institutions and is updated when new institutions join, or the status of a Participating Institution changes. As at 30 June 2025 there were 911 Participating Institutions (government and non-government). This covered approximately 70,000 sites across Australia.

1.18 For a non-government institution to join the Scheme, the Minister must be satisfied that the institution is able to meet its obligations under the Scheme. Where an institution does not meet the requirements and is unable to join the Scheme, the department investigates an option of ‘partly participating’ status and Funder of Last Resort arrangements.²³

1.19 A participating government institution or the Australian, state or territory government can be determined as a Funder of Last Resort for another institution when:

• a government institution was equally responsible for the abuse; or
• a non or partly Participating Institution is primarily responsible for the abuse, and the abuse occurred within a jurisdiction that has agreed to be the funder of last resort.

1.20 An application for redress can proceed to an eligible determination if at least one institution identified in the application is declared to be a Participating Institution. If an application is made where an institution named is not participating in the Scheme, the applicant can either withdraw their application, wait until the institution is participating, or have their application proceed to determination.

Funding arrangements

1.21 The Australian Government covers the up-front costs of redress payments and counselling/psychological services, as well as any administrative costs born through case administration. The Australian Government funds the Scheme through the Department of Social Services’ redress appropriations as summarised below.²⁴

• The departmental appropriation is used to fund the administration of the Scheme.
• The annual administered appropriation is used to fund Redress Support Services.
• The special appropriation is used to make Redress payments to eligible applicants. As a special appropriation, the total amount available is not fixed and is adjusted to reflect updated modelling of Scheme demand and payments. Payments are offset by the estimated receipts from institutions and jurisdictions for their contribution to the Scheme.

1.22 The initial funding profile for the department over the life of the Scheme (from 2017–18²⁵ to 2027–28) was approximately $3 billion, inclusive of special appropriations. As at July 2025, the total estimated funding profile had increased to $5.7 billion (see Table 1.2).

Table 1.2: Department of Social Services appropriations for the National Redress Scheme

Note a: Forward estimate.

Note b: The Departmental Appropriation for the department is used to fund the administration of the Scheme. Government consideration of any additional departmental appropriation each year is informed by the Australian Government Actuaries’ projections of applications to be received by the Scheme.

Note c: The Annual Administered Appropriation for the department is used to fund Redress Support Services.

Note d: The Special Appropriation for the department is used to make Redress payments to eligible applicants. As a Special Appropriation, the total amount available is not fixed and is adjusted to reflect updated modelling of Scheme demand and payments. Payments are offset by the estimated receipts from institutions and jurisdictions for their contribution to the Scheme.

Source: Department of Social Services data.

1.23 The Act states that:²⁶

Participating institutions that are determined by the Operator to be responsible for the abuse of a person are liable for the costs of providing redress to the person. Those institutions are liable for contributing to the costs of the administration of the scheme.

1.24 The Operator is responsible for recovering those costs from Participating Institutions on a quarterly basis (see paragraphs 3.87 to 3.98).

Legislative framework

1.25 The National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (the Act) establishes the Scheme and sets out the principles under which the Scheme will operate, including:

• eligibility requirements for survivors and Participating Institutions, groups and jurisdictions;
• processes for application assessment, offer and acceptance;
• reviews of determination;
• provision of redress;
• liability for funding; and
• reviews of the Scheme.

1.26 The Act is supported by three legislative instruments and two sets of guidelines.

• National Redress Scheme for Institutional Child Sexual Abuse Rules 2018 (the Rules).
• National Redress Scheme for Institutional Child Sexual Abuse Assessment Framework 2018 (the Assessment Framework).
• National Redress Scheme for Institutional Child Sexual Abuse Assessment Framework Policy Guidelines (the Assessment Framework Policy Guidelines).
• National Redress Scheme for Institutional Child Sexual Abuse Declaration 2018.
• National Redress Scheme for Institutional Child Sexual Abuse Direct Personal Response Framework 2018.²⁷

1.27 The Rules are made by the Minister for Social Services under section 179 of the Act. They provide for matters including an institution, group or jurisdiction ceasing to participate in the Scheme, and overriding any provisions of settlement agreements or deeds that relate to confidentiality or would inhibit access to, or the operation of, the Scheme.

1.28 The Assessment Framework was established by Ministerial declaration on 29 June 2018 under section 32 of the Act. The Assessment Framework sets out the method of working out the amount of a redress payment and the counselling component of redress.

1.29 The Assessment Framework Policy Guidelines were established by the Minister for Social Services on 22 October 2019 under section 33 of the Act. The Assessment Framework Policy Guidelines are to assist decision makers in applying the Framework and are not a legislative instrument.

1.30 The Act was amended in 2021 to:

• add the option of advance payments, at the discretion of the Scheme Operator;
• modify the method of indexation of relevant prior payments;
• extend review and acceptance periods;
• remove the statutory declaration requirement for applications;
• enable payment by instalments;
• clarify the arrangements for funders of last resort; and
• enable the Operator to publicly disclose that an institution is not participating in the Scheme.

1.31 The Act was further amended in 2024 to:

• enable reviews of determinations to consider additional information;
• remove the restriction on people making an application for redress from gaol;
• change the process for people with serious criminal convictions applying for redress;
• provide additional authorisations for the disclosure of protected information;
• align funder of last resort rounding provisions; and
• allow finalised applications for redress to be reassessed where an institution identified in the application has subsequently joined the Scheme or been listed under funder of last resort arrangements.

1.32 The Act states that the total amount of a redress payment may not be greater than $150,000 ‘regardless of the number of responsible institutions’ and that costs of counselling and psychological services provided must not be more than $5,000. Section 30 of the Act provides instructions for the Independent Decision Maker (IDM) in determining how much to award an applicant deemed eligible for redress; section 31 does the same for counselling and psychological services.

Rationale for undertaking the audit

1.33 The National Redress Scheme is intended to ensure that, where there is a ‘reasonable likelihood’ that a person is eligible for redress, they receive an offer of redress.²⁸ As at the 4 July 2025, there had been 63,995 applications and approximately $1.7 billion dollars had been paid to applicants. The estimated funding profile for the life of the Scheme was $5.7 billion as at July 2025, including special appropriations.

1.34 There has been public and parliamentary interest in the implementation of the Scheme, and the Scheme has been subject to Parliamentary inquiries and external reviews. Joint parliamentary committees on the National Redress Scheme have released four reports containing 93 recommendations.²⁹ This performance audit was conducted to provide assurance to Parliament that the Scheme is being administered effectively.

Audit approach

Audit objective, criteria and scope

1.35 The objective of the audit was to assess the effectiveness of the Department of Social Services’ (the department) administration of the National Redress Scheme (the Scheme).

1.36 To form a conclusion against this objective, the following high-level criteria were adopted.

• Has the department established effective governance arrangements for the Scheme?
• Does the department have effective processes to administer the Scheme?
• Has the department established appropriate arrangements to monitor and report on the Scheme?

1.37 The ANAO focused on the department’s management of the Scheme in 2023–24 and 2024–25. The audit did not:

• test the content or consistency of communications with potential applicants or potential institutions;
• test or re-perform determinations made by Independent Decisions Makers;
• test the implementation status of review or enquiry recommendations about the Scheme;
• examine the actions of any committee reporting to the Minister of Social Services;
• examine the processes associated with Redress Support Services, Direct Personal Responses or counselling support for applicants; or
• examine the ICT systems.

Audit methodology

1.38 The audit methodology included:

• review of department data, documentation, procedures and training materials;
• walkthroughs of department systems and processes;
• a site visit to the department’s offices where the Scheme is managed, in Tuggeranong, ACT;
• review of 25 contributions from the public, made to the audit via email or post; and
• meetings with departmental staff.

1.39 The audit was conducted in accordance with ANAO Auditing Standards at a cost to the ANAO of approximately $873,656.

1.40 The team members for this audit were Margaret Murphy, Kim Murray, Jillian Hutchinson, James Carrington, Scott Lang, Jonathan Dong, Li Lin, Dale Todd, Qing Xue, Danielle Page, Joanna Giang, Saxon Dettmann, Alexandra Collins and Corinne Horton.

2.1 The objective of the National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (the Act) is to provide redress to survivors and enable institutions responsible for abuse of survivors to participate in providing redress to those survivors (see paragraph 1.2). The Act establishes a ten-year window for this to occur (1 July 2018 to 30 June 2028).

2.2 Under sections 15 and 16 of the Public Governance, Performance and Accountability Act 2013 (PGPA Act), the accountable authority of an entity has a duty to establish and maintain an appropriate system of internal controls for the entity, including the oversight and management of risk.

2.3 The Secretary, as the accountable authority for the department and the Scheme Operator, is required to comply with the Scheme’s enabling legislation (the Act), and its legislative instruments. The implementation and operation of the Scheme requires appropriate governance arrangements, including frameworks for managing oversight, risk and engagement with potential stakeholders.

Does the department have fit for purpose oversight arrangements for the Scheme?

Delegations

2.4 The Act establishes the decision-making authority of the Minister for Social Services and Scheme Operator, which are delegated through legislative instruments. Both sets of delegations detail the Scheme power or function being delegated and to which position(s).

2.5 The Minister for Social Services delegated powers and functions under the Act to the Scheme Operator or a Senior Executive Service (SES) Band 3 position in the department. This included power to declare institutional status in relation to the Scheme, and to revoke declarations where required. The Minister’s delegations under the Act commenced on 29 June 2018 and were last updated in 2023.

2.6 The Scheme Operator delegated powers and functions under the Act to a range of roles within the department, including the power to make determinations on applications for redress to Independent Decision Makers (IDMs)³⁰. The Operator’s delegations under the Act commenced on 29 June 2018 and were last updated in 2025.

2.7 The delegations for the Scheme are available to department staff on the department’s staff intranet. Staff are advised by email when delegations change.

Oversight committees

2.8 Since the start of the Scheme in 2018 the department had a series of committees with responsibility to oversee the implementation and operation of the Scheme.

2.9 In February 2024 the department initiated an internal governance reform project to consider the impact of the sustained increase in the number of applications received and the implementation of recommendations from the Second Year Review.³¹ The project explored matters such as meeting cycles with sufficient opportunity for consultation on impact and risk, ensuring a common understanding about the purpose and accountability of each governance body, and greater focus on data to inform strategic decisions. The project resulted in the closure of some existing oversight committees and established two new oversight committees.

2.10 Figure 2.1 summarises the Scheme’s governance and management structure as at May 2025, and Table 2.1 outlines the oversight role and membership of each of these governance committees.

Figure 2.1: Scheme governance and management structure as at May 2025^a

Key: Dotted connector = advisory or consultative committee.
Solid connector = decision-making committee.

Note a: The graphic does not include sub-committees, networks or other management groups.

Source: ANAO analysis.

Table 2.1: Scheme governance committees as at May 2025

Note a: The Intergovernmental Agreement on the National Redress Scheme for Institutional Child Sexual Abuse is an agreement between the Australian Government and each of the states and territories, signed in 2018 and updated in 2023.

Source: ANAO analysis of terms of reference from the department.

2.11 All the committees as at May 2025 were working to their terms of reference. Each terms of reference detailed the committees’ roles in Scheme oversight including functions such as business continuity and improvement planning, performance monitoring, compliance and risk management, and policy development. For example, the Redress Performance Committee discussed performance data, change planning, and identification of risks to program delivery, and the Strategic Planning and Risk Committee discussed the overall strategic direction, business continuity planning and compliance with risk management for the Scheme.

Service arrangements

2.12 As discussed in paragraph 1.10, the Department of Human Services (now Services Australia) provided a range of services to the Scheme from the start of the Scheme in 2018, including the processing of applications. In April 2018 the accountable authorities of the department and Services Australia signed a Statement of Intent, which replaced the 2014 Bilateral Management Arrangement (BMA) head agreement. At the time of signing, planning was underway for the involvement of Services Australia in the delivery of the Scheme. The Statement of Intent did not include the National Redress Scheme and was not updated when the Scheme commenced in July 2018.

2.13 Machinery of Government changes announced on 5 December 2019³² moved the processing of redress applications from Services Australia into the Department of Social Services on 4 February 2020 (see paragraphs 1.10 and 1.11). A Letter of Exchange concerning the transitional arrangements was signed by the Deputy Secretary of the department on the 16 October 2020.

2.14 The first National Redress Scheme Service Arrangement under the BMA was signed on 24 June 2021, three years after the start of the Scheme.³³ The arrangement refers to an Operational Committee that facilitates assessment, review and problem resolution of matters relating to the agreement. The department advised ANAO in January 2025 that the committee ‘was later suggested to be unnecessary and so was never formally established. Instead managing issues relied on officer level relationships, and escalation to Branch Manager level where necessary.’

2.15 In April 2023 the accountable authorities signed a new BMA head agreement, which superseded the 2014 BMA head agreement and 2018 Statement of Intent.³⁴

2.16 On 28 June 2024 a Program Delivery Services Schedule was established for the Scheme under the 2023 BMA head agreement. The schedule specifies a range of services to enable delivery of the Scheme such as information and communication technology services and processing of payments to applicants. The schedule established processes to monitor progress annually and manage issues as they arise (see paragraphs 2.44 to 2.47).

2.17 The schedule states that governance of the services schedule will be conducted through the National Redress Scheme Services Schedule Contact Officer and the Services Schedule Relationship Manager, who ‘will facilitate assessment, review and resolution of any matters relating to this Services Schedule.’ See paragraphs 4.15 to 4.25 for more information about performance reporting between Services Australia and the department.

Business planning

2.18 The department’s business planning process requires the development of group business plans to provide a ‘clear view of our operational landscape, key risks, priorities, outcomes and relevant performance measures.’³⁵ They are to be updated and provided to the department’s Executive Management Group annually.

2.19 With the establishment of the Redress Group in 2019 a group business plan was developed and updated each year. As required by the department, it documented the operational landscape, key priorities and risks, outcomes and performance measures for the Scheme, as well as the Scheme’s governance arrangements and workforce considerations. Since 2023–24 the plan has consisted of a single page, providing a concise representation of the key components of the business plan.

2.20 The Redress Group Business Plan was not presented to the department’s Executive Management Group until January 2023, when the 2022–23 plan was noted. From 2023 onwards the Redress Group Business Plan was summarised, along with others in the Families and Communities Stream, and noted by the Executive Management Group.

End of Scheme planning

2.21 The Act (subsection 192(3)) requires the Minister to conduct a review of the operation of the Scheme as soon as possible after the eighth anniversary of the Scheme start date (1 July 2026). The review must consider the same matters from the second year review, and ‘the results of any other review or evaluation conducted in relation to the operation of the scheme.’³⁶ The department advised the ANAO in July 2025 that ‘the review is anticipated to consider matters relating to the end of the scheme.’

2.22 The department established a steering committee to plan for the eight anniversary review, consisting of departmental, State and Territory officials. It had its first meeting on 17 March 2025.³⁷ In that meeting the members discussed the development of a topic register to set out key issues that need to be considered in the lead up to the formal review commencing. These issues were classified into three categories:

• how effective has the Scheme been for survivors and what can [the department] improve before Scheme end;
• when and how could the department end the Scheme; and
• beyond the end of the Scheme.

2.23 In February 2025, the department advised the Minister for Social Services that the department had commenced a functional review of the Scheme in January 2025, to further consider a recommendation from a 2024 Independent Review to clarify roles, responsibilities, and accountabilities between the Redress Group and the whole-of-department functions. As a result of the functional review the department implemented a new Group structure on 21 July 2025. The new structure included a new area called ‘end of scheme planning’. The department advised the ANAO in July 2025 that this area was created to coordinate end of Scheme planning across the Scheme.

Is there an appropriate risk management framework for the Scheme?

Departmental risk management

2.24 Expectations for managing risk are set out in the Secretary’s Instructions for the Department of Social Services (July 2023) (Secretary’s Instructions).³⁸ Consistent with the requirements of the Commonwealth Risk Management Policy, the Secretary’s Instructions require the department to have a risk management framework.

2.25 As at January 2025, the department’s risk management framework comprised a departmental Risk Management Policy, Risk Management Procedure and an Issues Management Procedure (all published April 2023).³⁹ The framework outlined the department’s approach to managing risk, its strategic risks, roles and responsibilities for managing risk, and its risk management process.⁴⁰

2.26 Under the department’s Risk Management Policy ‘Senior Executives’ are responsible for identifying, reviewing, monitoring and managing risks within their respective business units. The Redress Group Manager is the Senior Executive responsible for risk management for the Scheme. Table 2.2 sets out the department’s risk escalation process and accountabilities for considering and accepting risks, in line with the department’s Risk Management Procedure.

Table 2.2: Department of Social Services’ risk escalation process accountabilities

Source: ANAO analysis of the department’s Risk Management Procedure.

2.27 The department updated its Risk Management Policy and Procedure, along with the Issues Management Procedure, on 23 June 2025.

Redress Group risk management

2.28 The department had Redress Group risk management plans for each year of the Scheme to May 2025. The department’s 2024–25 Redress Group Risk Management Plan (the Plan)

• documented the identified risks to the Redress Group’s activities,
• listed the controls in to manage each risk,
• assessed the effectiveness of those controls,
• assigned a risk rating to each risk, and
• identified proposed treatments for each risk necessary to achieve a target risk rating.

2.29 The 2024–25 Plan was last updated 13 February 2025. The department advised the ANAO in February 2025 that this plan is the primary document used to document and assess risks to the National Redress Scheme.

2.30 The Plan identifies:

• ten ‘standard’⁴¹ risks to the Group’s operations;
• three risks specific to the Scheme and
• seven fraud and corruption risks relevant to the Group’s activities.

2.31 The three risks specific to the Scheme are summarised in Table 2.3.

Table 2.3: Scheme specific risks in the 2024–25 Redress Group Risk Management Plan dated 13 February 2025

Note a: This risk acceptance authority is consistent with the requirement of the department’s Risk Management Procedure that a risk rating of ‘medium’ requires acceptance by the relevant Group Manager (SES Band 2) and a risk rating of ‘high’ requires acceptance by the Deputy Secretary (SES Band 3).

Source: ANAO analysis.

2.32 The department’s Risk Management Procedure requires the responsible Deputy Secretary to advise the Secretary of any risk with a current risk rating of ‘high’. The Secretary was not informed about the high risk identified in the Plan (Table 2.3). In February 2025, the department advised the ANAO that it had ‘initiated a monthly [report] to the Deputy Secretary providing updates on the High Risks’ and that the Deputy Secretary’s office would provide a copy of the report to the Secretary for noting.

2.33 For the risk of failing to finalise redress applications before the end of the Scheme the department identified seven ‘effective controls’ and seven treatments in the Plan to reduce the risk level rating from high to low. (see Table 2.4) The treatment due dates in the plan have been revised over time, as summarised in Table 2.4. As at July 2025, six of the seven treatments had been completed, and treatment implementation had not been reviewed for impact on the risk.

Table 2.4: Controls and treatments for the risk of failing to finalise redress applications before the end of the Scheme

Note a: The due date for the Redress System Improvement Taskforce was extended to 30 May 2025 by the Strategy Planning and Risk Committee (SPaRC) on the 30 April 2025.

Note b: The treatment was closed at the SPaRC meeting on the 22 January 2025, staff training on how to use the resource continued.

Source: ANAO analysis of Redress Group Risk Management Plan 2024–25 (dated 13 February 2025) and Strategic Planning and Risk Committee minutes.

2.34 The Plan identified seven fraud and corruption risks relevant to the Redress Group’s activities, each with a risk rating of ‘medium’:

• corruption;
• unauthorised access or disclosure of information⁴²;
• false and misleading information or documentation;
• identity;
• misuse of assets;
• misuse of departmental funding; and
• misuse of administered funding.

2.35 Each of the seven fraud and corruption risks listed in the Plan included the same proposed treatment — the development of an updated Redress Scheme Fraud and Corruption Risk Assessment (discussed in paragraphs 2.37 to 2.43). The Plan notes that this treatment is not likely to reduce the assessed risk levels for any of the seven risks from their medium risk rating.

2.36 The Redress Strategic Planning and Risk Committee (SPaRC) is responsible for overseeing the Scheme’s compliance with the department’s risk management requirements.⁴³ The SPaRC meets monthly and ‘risk update’ is a standing item on the committee’s agenda. In the minutes from the committee’s meetings to January 2025, the committee had considered the 2024–25 Redress Group Risk Management Plan and received quarterly reports on the Group’s risk management activities including risk controls testing.⁴⁴

Fraud risk assessment

2.37 The department’s fraud and corruption control framework (discussed further in paragraphs 3.50 to 3.58) includes the requirement for ‘targeted fraud and corruption risk assessments’ for schemes that have a higher level of complexity, and fraud and corruption exposure. In June 2023 the department documented a National Redress Scheme Fraud Risk Assessment.⁴⁵

2.38 The 2023 National Redress Scheme Fraud Risk Assessment (fraud risk assessment) identified four categories of fraud risks to the Scheme and assessed the risk level based on controls identified as being in place at the time.

• ‘False Statements — obtaining a benefit (or causing a loss) through providing false or misleading information.’ The department assessed this risk as ‘extreme’.
• ‘Identity — obtaining a benefit (or causing a loss) through use of a false, manipulated or stolen identity.’ The department assessed this risk as ‘high’.
• ‘Hijacking of Application or Payment — obtaining a benefit through interception of payment or take-over of application.’ The department assessed this risk as ‘high’.
• ‘Insider Threat — staff members use their access, knowledge or authority obtain a benefit for themselves or others’ (staff includes APS, contractor and IDM personnel, in both the department and Services Australia). The department assessed this risk as ‘medium’.

2.39 The 2023 fraud risk assessment identified proposed treatments which, if implemented and effective, were anticipated to reduce the fraud and corruption risks to ‘high’ (False Statements), ‘medium’ (Identity and Hijacking of Application or Payment), and ‘low’ (Insider Threat). The fraud risk assessment did not identify planned dates for implementation of the proposed treatments. Contributions to the audit raised concerns about fraud prevention and risk management. The fraud risk assessment was updated 25 July 2025 to include treatment due dates.

2.40 The 2023 fraud risk assessment was approved by the acting Branch Manager, Redress Enabling Services on 28 June 2023. The Secretary was briefed about the current and emerging fraud risks in the Scheme on 13 October 2023 (discussed further in paragraphs 3.50 to 3.58).

2.41 There was a misalignment between the risk level ratings for fraud related risks to the Scheme identified in the 2024–25 Redress Group Risk Management Plan and the 2023 National Redress Scheme Fraud Risk Assessment. The Redress Group Risk Management Plan 2024–25 assessed ‘false and misleading information or documentation risk’ and ‘identity risk’ as medium, while the risk assessment rated them as extreme and high respectively. The updated 2025 fraud risk assessment addressed the misalignment for the ‘false and misleading information or documentation risk’, not for the ‘identity risk’. Both the 2023 and 2025 fraud risk assessments contained additional risks not included in the risk management plan such as ‘hijacking of application or payment’, and ‘insider threat’.

2.42 Executive oversight of the Scheme’s fraud and corruption risks are conducted through the department’s Fraud and Serious Non-Compliance Committee, which is chaired by the Chief Operating Officer. For matters concerning the Scheme, membership includes the Deputy Secretary, Families and Communities, the Group Manager Redress and relevant Branch Managers and Directors.

Shared risks with Services Australia

2.44 The Commonwealth Risk Management Policy requires entities to collaborate in managing shared risks. The department’s Risk Management Policy (April 2023) requires, among other things, a joint risk management assessment that determines the governance arrangements in overseeing, managing and escalating shared program delivery risks. This has been a requirement of the department’s documented risk management framework since the Scheme commenced in 2018.

2.45 The department and Services Australia agreed to the first Redress Shared Risk Management Plan on 4 November 2024, six years after the start of the Scheme. The plan identifies the following four risks to the Scheme that are shared by the two entities, with each risk assessment based on existing controls.

• Identity fraud — rated as medium.
• Provision of quality service to applicants — rated as low.
• Protection of staff — rated as medium.
• Collection, access to, use and disclosure of Scheme information — rated as medium.

2.46 The shared risk management plan was approved by the department’s Branch Manager, Enabling Services on 4 November 2024. The department advised the ANAO on 30 May 2025 that the shared risks rated as ‘medium’ were accepted by the Group Manager on 7 April 2025. The first quarterly review of the plan that updated the shared risks was approved by the relevant Senior Executive Service Band 1 in February 2025.

2.47 The Shared Risk Management Protocol between the department and Services Australia, established in March 2024, and revised in March 2025, specifies that shared risks will be reported through the governance arrangements specified in the BMA Head Agreement. As noted in paragraph 2.17, the Scheme’s governance arrangements under the Head Agreement are through the National Redress Scheme Services Schedule Contact Officer in the department and the Services Schedule Relationship Manager in Services Australia.

Does the department have an appropriate framework for engaging with stakeholders?

2.48 To achieve the Act’s objective to provide redress to survivors, and to enable institutions to participate in the Scheme, requires clarity, consistency and alignment of communications with stakeholders. This would assist in fostering trust and reducing misunderstandings, ultimately leading to better outcomes for applicants and institutions.

2.49 In 2018 the department established a Communications Strategy for the Scheme that outlined the approach to communications about the launch and initial operations of the Scheme for survivors and ‘intermediaries’.⁴⁶ The Communication Strategy outlined the aim and objectives of the communication activities, key messages to be given and the approach to different types of communication activities, including a timeline of activities to the end of 2018. The Communication Strategy was last updated on the 6 February 2018.

2.50 A communications framework was established on 14 August 2024 to outline the Scheme’s communication requirements, expectations and standard procedures through to 2028, to ‘ensure all communications are effective, comprehensive and timely.’ The framework addresses stakeholders such as people who experienced institutional child sexual abuse and can apply for redress, members of the public, Group staff, IDMs, institutions, and jurisdictions. The department advised ANAO in May 2025 that the communications framework, together with the Redress Service Charter, the Redress Trauma-Informed Framework and the department’s guidelines to manage external communications, form the current communication strategy.

2.51 Contributions to the audit noted the communication challenges experienced by survivors including the timeliness, consistency and accessibility of communications.

Engaging with potential applicants

2.52 In addition to the 2018 Communications Strategy and 2024 Communications Framework, 15 individual strategies and plans were developed. The strategies and frameworks were for specific potential applicant groups such as people with a disability, culturally and linguistically diverse stakeholders and Indigenous stakeholders, between 2018 and 2024. These are not mentioned in either the 2018 Communications Strategy or 2024 Communications Framework.

2.53 All of the 15 strategies and plans outlined the communications approach and activities to be delivered, the target audiences, key messages, and timelines. Eight of the documents were written by external agencies with communications expertise specific to the focus of the document. The documents do not refer to each other or specify if they have superseded previous documents on the same topic or stakeholder group.

Trauma-informed communications

2.54 A trauma-informed approach is one in which the core philosophy of an activity, program, or campaign is centred on empowerment and support of individuals who have experienced abuse.⁴⁷ This aligns with some of the general principles established in the Act, including that redress under the Scheme should be survivor-focused and should be assessed, offered and provided to avoid, as far as possible, further harming or traumatising the survivor.

2.55 In December 2017 WhereTo Research⁴⁸ conducted developmental research prior to the production of Scheme promotional materials. They advised the department that every aspect of the Scheme must take a trauma-informed approach to allow the Scheme to avoid activities that may risk re-traumatising survivors.

2.56 The 2018 Communications Strategy states that:

all communication materials will be reviewed by a trauma-informed psychologist to ensure they are, as much as possible, non-triggering for survivors. In accordance with research recommendations, an advisory group will be formed to provide advice on communication materials, especially those produced for Indigenous and CALD [Culturally and Linguistically Diverse] audiences. CALD and Indigenous agencies will informally test material with community leaders before translation, to ensure they are appropriate and useable.

2.57 An advisory group to advise on communication materials was not established, and all communication materials were not reviewed by a trauma-informed psychologist.

2.58 The department established a Clinical Advisor role in 2021 (renamed Trauma-Informed Advisor in 2023). The 2024 Communications Framework notes the role of the Trauma-Informed Advisor in reviewing internal and external communication prior to final version approval. They do this ‘through a trauma- informed lens, where advice on trauma-informed language is required, to assist in identifying and modifying language or content that might unintentionally trigger or distress survivors.’ The Advisor’s review of communications activities focuses on those activities expected to have the most significant impact, such as website content. The advisor can also be requested by the service delivery team to provide advice on communications directly with an applicant.

2.59 Four of the 15 communication strategies and plans referred to taking a trauma-informed approach. Communication materials were also reviewed from a trauma-informed perspective in 2018 and 2023.

• In May 2018 the department invited (through a direct approach to market) the Blue Knot Foundation to review its promotional materials from a trauma-informed perspective. Blue Knot signed a 12-month contract with the department in June 2018.⁴⁹
• In March 2023 the department commissioned concept testing from WhereTo Research⁵⁰ in which it received advice about trauma-informed content.

2.60 In May 2023 the department developed a trauma-informed framework (the Framework) to provide guidance to staff on how they could help make the Scheme trauma-informed. The department also established a Trauma-informed Embedment Strategy (the Embedment Strategy) in 2023 to support staff in applying the Framework in their work. The Embedment Strategy outlined the communications to staff, resources provided for staff and a series of mandatory monthly activities for staff to undertake. The department advised the ANAO in July 2025 that participation in the mandatory training is monitored. The Framework and Embedment Strategy are not referred to by subsequent communication plans or strategies.

Evaluation of communication plans and strategies

2.61 Five of the 15 communication strategies and plans detailed how the effectiveness of the activities would be assessed (Table 2.5), one of which (the Northern Australian Indigenous Communication and Engagement Strategy) underwent the expected evaluation.

Table 2.5: Communication plans and strategies with evaluation plans

Source: ANAO analysis.

2.62 In addition to the above strategies there was one report that evaluated the media performance of the Scheme in 2023–24. It was an evaluation of a Google AdWords campaign by UM Australia.⁵¹ The campaign was to raise awareness of the Scheme and drive traffic to the website. The evaluation found the campaign was an example of best practice for government search campaigns, optimising the click through rate from 17.34 per cent in 2020 to 28.2 per cent in 2024, and the cost per click decreased.

Engaging with non-Participating Institutions

2.63 An application for redress can proceed to an eligible determination if at least one institution identified in the application has joined the Scheme. One of the Act’s objectives is to enable institutions to participate. Institutions that have joined the Scheme are called Participating Institutions (see paragraphs 1.15 to 1.20).

2.64 At the start of the Scheme the department approached institutions who were identified by the Royal Commission, and State or Territory governments, about joining the Scheme. As applications were received the department prioritised approaching any institutions named in an application that had not joined the Scheme (non-Participating Institutions). Non-Participating Institutions could also approach the Scheme directly to join. The department advised the ANAO on the 22 July 2025 that such unsolicited approaches from non-Participating Institutions happened ‘organically’ and were not planned by the department.

2.65 As at March 2025 the department had guidance material for staff that outlined the process to identify and approach non-Participating Institutions. The material outlined the process for researching an institution’s legal status, documentation, and history. The process is described as an important step to ensure that:

• the Scheme is engaging with the correct institution;
• the institution is capable of participating in the Scheme; and
• there is appropriate responsibility for the institution’s operational history.

2.66 There has not been a review of the effectiveness of the onboarding process for institutions. Contributions to the audit indicated mixed experiences with the clarity of information received in joining the Scheme, particularly in relation to the burden of proof for institutions.

2.67 If a non-Participating Institution declines to participate in the Scheme, subsection95A(1) of the Act⁵² provides authorisation for the Scheme Operator to publicly disclose that the institution is not a Participating Institution, if either or both of the following applies:

• a person has applied for redress under the Scheme and the application identifies the institution as being involved in the abuse of the person; and/or
• the Operator has reasonable grounds to believe that the institution may be connected with abuse of a person that is within the scope of the Scheme.

2.68 The department advised the ANAO in March 2025 that all State and Territory government institutions were onboarded to the Scheme by January 2019. Since 2018 the department has a record of engaging with 1265 non-government institutions about joining the Scheme, of which three per cent declined (see Table 2.6 ).

Table 2.6: Summary of key outcomes from department engagement with non-government institutions from 1 July 2018 to 30 June 2025

Note a: Consistent data on the department’s engagement with non-government institutions about joining the Scheme was available from January 2020. Data prior to January 2020 was added where it became available but is not complete.

Note b: Includes non-government Institutions that have declined, or are in the process of being publicly named as declined.

Note c: Includes unable to progress, application progressed without the institution, employment based organisation, IDM determined not responsible, institution ineligible, misidentified and out of scope.

Source: Department data.

2.69 The department further advised the ANAO in July 2025 that of the 848 non-government institutions that the department approached directly to join the Scheme, 407 had not joined for the reasons recorded as per Table 2.7. Of the 12 per cent found not suitable, this was the result of actions such as the redress application being withdrawn, or the institution being found not responsible or misidentified prior to completing the joining process.

Table 2.7: Reasons non-government institutions approached by the department didn’t join the Scheme as at 30 June 2025

Source: Department analysis.

2.70 The department took an average of 12.3 months⁵³ to declare a non-government institution. The average time taken peaked in 2019 and was approaching that peak again as at 30 June 2025 (see Table 2.8).

Table 2.8: Average number of days taken from a non-government institution’s first contact to being declared as at 30 June 2025.

Source: Department analysis.

2.71 To ensure effective and coordinated communication with potential institutions and applicants, existing frameworks, strategies and plans should be evaluated to inform continuous improvement and planning for the conclusion of the Scheme (see recommendation 1).

Communicating the end of the Scheme

2.72 With the Scheme legislated to end on 30 June 2028, the department’s website stated (as at 23 July 2025) that it will cease to accept applications on 30 June 2027. There is a risk in the Group’s risk management plan with a high risk rating that the department fails to finalise redress applications before the end of the Scheme. The communications framework was one of the controls identified. The risk management plan did not include a treatment for communications, and it did not specify related communication risks such as:

• potential applicants miss the opportunity for redress due to lack of awareness of the deadline; and
• those with applications awaiting an outcome are confused and or traumatised by a lack of understanding about what the end of the Scheme means for their application.

2.73 The 2024 Communications framework states it ‘is implemented until 2028’. It does not reference planning or implementing communications to stakeholders about the end of the Scheme. It states that for ‘operational changes, such as … key messages … the [External Engagement and Communications Branch] will undertake the communication directly with their audiences.’

2.74 Two of the 15 communication strategies and plans for applicants referenced the end of the Scheme. No detailed planning is specified.

• The National Redress Scheme Disability Engagement Strategy (20 March 2025) was established to engage with people with disabilities about the Scheme and guide engagement and community activity until June 2025. The strategy notes that ‘it is important that we let people know about the Scheme before applications close on 30 June 2027.’
• The National Redress Scheme First Nations Engagement Plan Yarning Circle Design and Radio Strategy (November 2024) was established to develop, execute and report on First Nations engagements to raise awareness of the Scheme. The strategy notes a key message is the application closure date of 30 June 2027.

3.1 The objective of the National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (the Act) is to ‘recognise and alleviate the impact of past institutional child sexual abuse for survivors and provide justice for the survivors of that abuse.’ The Scheme is designed to be survivor focused and trauma-informed by ‘maintaining the principles that the Scheme be a low threshold and non-legalistic process for survivors.’⁵⁴ The ANAO examined if the department had fit for purpose arrangements for processing applications from survivors, and making decisions in line with the Act.

3.2 Participating Institutions which are determined by the Operator to be responsible for the abuse of a person, are liable for the costs of providing redress to the person and for contributing to the costs of the administration of the scheme. The Operator is responsible for recovering those liabilities from Participating Institutions. The ANAO examined if the department had fit-for-purpose arrangements for this debt recovery.

Does the department have fit-for-purpose arrangements for processing Scheme applications?

Application management

3.3 The Act (subsection 29(1)) requires the Scheme Operator (Operator) to ‘make a determination to approve, or not approve, an application for redress as soon as practicable.’ To do this the department engages with applicants and institutions to ensure the application contains all the information necessary to reach a decision in accordance with the Act, and to manage the outcome as required.

3.4 The redress application management process starts with the department receiving an application for redress and consists of six main stages. (Figure 3.1) A summary of the application process can be found in paragraphs 1.12 to 1.14, Table 1.1 and in Appendix 3.

Figure 3.1: Redress Scheme application process flow

Source: The department’s Resources Hub, Maps and Resources Suite (MaRS), accessed 30 January 2025.

3.5 As at February 2025 the department did not have a single process for tracking and allocating applications to staff for processing at each stage. The Redress Group’s intranet site states:

Sections within the Service Delivery Branch have their own specific ways of tracking and allocating applications sitting within their remit that require the actioning of a task. The medium used for application tracking varies dependent on the nature of the work involved and the complexity of information around that work needing to be captured.

3.6 Modelling commissioned by the department in 2017 anticipated that there would be 60,000 eligible applicants, with the highest number of eligible applications received in the first three years of the Scheme, declining in years four to nine, and increasing in the final year. Subsequent modelling in 2020, 2021, 2022, 2023, 2024 and 2025 have provided estimates varying between 40,000 and 59,000 eligible participants. All modelling highlighted the uncertainty of the figures due to the uncertain levels of child sexual abuse in institutions. Modelling done in April 2025 estimated that the volume of eligible applications lodged will start to decline over 2025–26, with a final increase in 2027 before the Scheme closes to applications on the 30 June 2027.

3.7 Between 1 July 2018 and 30 June 2025 there were 63,738 applications submitted to the Scheme of which 33 per cent (20,896) were complete as at 30 June 2025. There was a 373 per cent increase in applications received from 2018–19 to 2024–25. The largest single year growth was 2022–23 at 79 per cent (Table 3.1).

Table 3.1: Application growth rate^a

Note a: ANAO conducted analysis by examining the department’s data between 1 July 2018 and 30 June 2025. The reporting of ANAO analysis is by the financial year the application was received, to reflect the perspective of applicants from when they applied to the Scheme.

Source: ANAO analysis of the department’s data.

Application prioritisation

3.8 The department’s prioritisation policy (June 2019) establishes three levels of priority for Scheme applications:

• Priority Tier 1 — ‘critical’ — highly time sensitive (for example, applicant’s likely remaining lifespan or extreme vulnerability warrants expedited processing) — expected to be five per cent of applications.
• Priority Tier 2 — ‘high’ — moderately time sensitive (for example, considering the applicant’s vulnerability or an application received over nine months ago) — expected to be 15 per cent of applications.
• Priority Tier 3 — ‘normal’ — standard time sensitivity — standard processing — expected to be 80 per cent of applications.

3.9 The prioritisation policy for the Scheme specified that cases initially assessed and prioritised as ‘normal’ are automatically reprioritised to ‘high’ after nine months. This has not occurred. Cases were reprioritised to ‘high’ automatically after twelve months.

3.10 Of the 63,738 applications received by the Scheme as at 30 June 2025⁵⁵, 517 (one per cent) were categorised in the system as ‘critical’ priority, 34,602 (54 per cent) were categorised as ‘high’ priority, and 28,619 (45 per cent) were categorised as ‘normal’ priority. This does not reflect the priority distribution stated in the prioritisation policy. See Table 3.2.

Table 3.2: Application prioritisation as at 30 June 2025 and priority policy expectations

Note a: Applications may be prioritised in circumstances where an applicant has a terminal illness, is elderly, or where there are any other contributing factors the department’s delegate considers appropriate to warrant expedited processing. The different priority levels are described in paragraph 3.8.

Note b: The total number of applications includes all applications with a status of open, on hold, withdrawn or completed. Open cases include those classified as ‘in progress’ and ‘on hold’.

Source: ANAO analysis of the department’s data.

3.11 As at 30 June 2025 there were 18,728 open high priority cases, with 831 (four per cent) open for less than one year. The department advised ANAO in July 2025 that the prioritisation policy was under review and expected to be updated in September 2025.

Processing time

3.12 The prioritisation policy (2019) established automatic reprioritisation for applications that were still being processed nine months from receipt. The department advised the ANAO in July 2025 that in 2020 the department established a target of processing applications within six months from receipt of application. The target was revised in 2023 when ‘the six-month period was redefined to measure from the time all necessary information was received by the Scheme to when an outcome was offered.’

3.13 As at 27 July 2025, the Scheme website advised the public that it ‘can take between 12 to 18 months [for applicants] to receive an outcome’.⁵⁶ From the start of the Scheme to 30 June 2025 the average processing time for completed applications was 16.3 months, with the longest taking 81 months. Table 3.3 shows that the average processing time did not change by more than one month from 2019–20.

Table 3.3: Average processing time (months) for completed applications by financial year application received, as at 30 June 2025

Note a: Applications received in 2024–25 were excluded from this analysis due to the low number of completed applications.

Source: ANAO analysis of the department’s data.

3.14 Table 3.4 shows that of completed applications, high priority applications had the longest average processing time.

Table 3.4: Average total processing time for completed applications as at 30 June 2025

Note a: Applications may be prioritised in circumstances where an applicant has a terminal illness, is elderly, or where there are any other contributing factors the department’s delegate considers appropriate to warrant expedited processing. The different priority levels are described in paragraph 3.8.

Note b: Average processing time details the average time to process each application’s full duration length, including on hold times, for completed applications. This was calculated from the date a case (for a received application) was ‘created’ in the department’s system, until the date a case was marked with a status ‘completed’.

Source: ANAO analysis of the department’s data.

3.15 Over the life of the Scheme, 7.8 per cent of completed application received the outcome within six months from receipt of the application, with applications taking on average 16.3 months to complete. When considered by the redefined six month period (see paragraph 3.12), 62 per cent of completed applications received the outcome within six months of the final information being provided by the institution(s), with the highest proportion occurring in 2021–22 and the lowest in 2023–24.⁵⁷ (Table 3.5)

Table 3.5: Proportion of completed applications to receive an outcome within six months of final information being provided by the institution(s)

Note a: The ANAO conducted analysis of the timeliness of application processing by examining the department’s data between 1 July 2018 to 30 June 2025. The ANAO included periods of ‘on hold’ status in its analysis as it saw evidence of applications progressing when recorded as ‘on hold’. The reporting of ANAO analysis is by the financial year the application was received, in order to reflect the perspective of applicants from when they applied to the Scheme. The analysis did not include applications submitted in 2024–25 due to the low number completed as at 30 June 2025.

Note b: Percentage does not add up to 100 due to changes in the reporting of process stages over time.

Source: ANAO analysis of the department’s data.

Participating Institutions

3.16 The department advised the ANAO in July 2025 that as at 30 June 2025, 5,269 applications had been associated with a non-Participating Institution, of which 3,191 applications were completed, including 763 where a non-Participating Institution was still part of the case (see Table 3.6).

Table 3.6: Status of applications associated with a non-Participating Institution as at 30 June 2025

Note a: The department advised the ANAO in July 2025 that 763 of the completed applications still had a non-Participating Institution coded on the case.

Note b: The department advised the ANAO in July 2025 that 929 applications were progressing with a non-Participating Institution still coded on the case.

Note c: The department advised the ANAO in July 2025 that 361 applications were put on hold due to the institution not participating or not being identifiable.

Note d: The department advised the ANAO in July 2025 that 12 of the withdrawals were due to a non-Participating Institution.

Source: Department data.

3.17 As of 30 June 2025 there were 911 Participating Institutions (government and non-government). Of those, 779 were non-government institutions.

3.18 Departmental records indicate that as at 30 June 2025, 848 non-government institutions were directly approached by the department to join the Scheme⁵⁸, of which 57 per cent (483) were, or about to be, declared.⁵⁹ Five per cent (41) declined to join the Scheme, of which 13 were publicly disclosed (see paragraph 2.67 and Table 3.7).

Table 3.7: Non-government institutions approached by the department as at 30 June 2025

Note a: Declared status includes those institutions already declared, ready to be declared, or completing the onboarding process

Note b: Not suitable status includes where the institution was misidentified or deemed not responsible by an Independent Decision Maker. It also includes cases where the applicant decided to progress their application without the institution joining the Scheme.

Note c: Declined status includes those institutions publicly disclosed and potentially named.

Note d: The department advised the ANAO that the data does not reflect every institutions since the commencement of the Scheme due to changes in data recording in January 2020.

Source: Department data.

3.19 Over the life of the Scheme, it took an average of 316 days from the department’s initial approach to a non-government institution being declared. The average length of time to declare an institution has increased by 386 per cent since 2018 (Figure 3.2). If an institution needed to be considered under partly participating arrangement it took an average of 1,147 days. This time impacts on the processing of an application unless the applicant choses to proceed without the named institution (see paragraph 1.20).

Figure 3.2: Average days taken for a non-government institution to be declared (from first approach by the department) as at 30 June 2025

Source: ANAO analysis of department data.

3.20 In addition to institutions being approached by the department, institutions can make an unsolicited enquiry about joining the Scheme. As at 30 June 2025, 417 non-government institutions made an unsolicited enquiry to join the Scheme. Of those, 46 per cent (193) were declared and 48 per cent (199) chose not to continue through the process. The department advised the ANAO in July 2025 that:

there are various reasons why enquiring institutions opt out of completing the joining process [including]:

• the process is more involved and protracted than they expect and/or the institution lacks the resources to complete joining steps;
• some institutions incorrectly believe they must participate in the Scheme in order to receive state and territory grant funding (this applies to institutions named in applications);
• the institution is unlikely to meet the requisite financial or legal requirements to participate in the Scheme; or
• institutions simply cease communicating with the Scheme after enquiring.

3.21 In processing institutions into the Scheme, the department prioritises institutions identified in applications, so institutions approached by the department are usually processed before unsolicited enquiries. On average it took 617 days from an institution’s initial unsolicited enquiry to being declared.⁶⁰

3.22 Following onboarding and declaration of an institution, the department engages with the Participating Institutions through the Request for Information process specified in the Act (section 25) outlined in Appendix 3. There is no relationship manager specifically allocated to institutions. The department advised the ANAO in July 2025 that it supports Participating Institutions through training and a dedicated team whose activities include:

• Referring and assessing RFIs [Requests for Information]/Requests for Further Information (RFFIs) extensions to the Scheme
• Clarifying application redactions and other Scheme processes, policies and legislation
• Identifying potential conflicts of interest in responding to RFIs/RFFIs
• Referring RFI/RFFI complaints and addressing RFI/RFFI clarification questions
• Understanding protected information requirements and privacy matters when responding to RFIs/RFFIs
• Facilitating access to institution training and related resources via the Redress Education Portal

3.23 The Act (section 25) specifies that a Participating Institution will be ‘requested to give the information [the RFI response] to the operator’ within eight weeks of the notice date, or four weeks ‘if the Operator considers the application is urgent’. The department advised the ANAO in July 2025 that, ‘the average RFI response time ranges from 37.4 (maximum days of 181) in 2018 to 47.3 (maximum days of 613) in 2024.’

Process improvements

3.24 There have been changes to Scheme application processing since it began. Reasons for this includes legislative changes or reviews into the Scheme.⁶¹

• Establishment of an advance payment process in 2021, for applicants who are terminally ill, aged 70 years and over, 55 years and over for Aboriginal and Torres Strait Islander applicants, or where there are other exceptional circumstances for particularly vulnerable people, while their redress application is considered.
• Expansion of Funder of Last Resort⁶² arrangements in 2021, to provide more survivors with access to redress, in circumstances where the responsible institution is defunct or does not have the financial capacity to join the Scheme.
• Removal of the requirement for a statutory declaration in 2021 so that it was no longer a mandatory part of the application documentation.⁶³
• Establishment of a redress intranet site in 2021, and single source of information for processing staff in 2023 (Maps and Resources Suite), to provide a holistic view of all Scheme application processing tasks linked to existing operational guidance.
• Establishment of a Redress System Improvement taskforce in 2024 to oversee the implementation of the recommendations made in the 2024 Independent Review of the Scheme (see paragraph 3.25). The goal of the program of work was to ensure the Scheme can respond to increases in applicant demand and complexity as the Scheme approaches its closure in 2028.
• Expansion of the eligibility requirements in 2024 to enable people in gaol to make an application to the Scheme without the Operator being required to make a determination that exceptional circumstances apply. The legislative amendment changed the process for applicants with serious criminal convictions.⁶⁴

3.25 In October 2023 the Minister for Social Services initiated an independent review of the funding and operations of the National Redress Scheme (Independent Review).⁶⁵ The final report made 11 recommendations to improve the performance of the Scheme and ensure its suitability and sustainability through to the Scheme’s end in 2028. The Minister for Social Services accepted all the recommendations in April 2024 and noted the department’s plans to implement them.

3.26 As at May 2025 the department advised the ANAO that it had completed 22 out of 24 projects to improve application management in response to the independent review. This included streamlining communications, establishing a decision batching process, reducing workarounds in the system, establishing additional performance indicators and improving application processing rates. Work on establishing a triaging service and improving outcome engagement was in progress.

3.27 On 21 July 2025, the department implemented a new organisational structure for the Redress Group, an outcome of the functional review raised with the Minister for Social Services in February 2025 (see paragraph 2.23). The department advised the Minister that the goal of the changes would be to ‘improve the efficiency of its operations, focussed on processing applications faster.’

Staff support

3.28 The department has training and guidance material for Scheme staff when managing Scheme applications, including process maps, process summaries and guidance materials. This guidance material is available to Scheme staff through the department’s Redress Hub intranet site, launched in November 2021. Prior to the Redress Hub the department’s redress guidance was contained in over 1,000 documents and 330 intranet pages across 11 intranet sites.

3.29 In May 2024, the department reviewed available process maps and identified that approximately two-thirds of all actionable tasks were not supported by formalised operational guidance for staff to use. The 2024 Independent Review recommended that the department support its staff and the IDMs with ‘living’ procedures that operationalise policy and legal advice and service delivery improvements that were suggested as part of the review. In late January 2025 further process maps and documentation were made available to Scheme staff on the Redress Hub intranet site. In February 2025, the department advised the ANAO that the Group’s Maps and Resources Suite (MaRS) intranet site within the Redress Hub will ‘continue to be enhanced to meet operational needs’. They also said that the department was undertaking an audit to identify key gaps where further operational guidance may be needed. As at May 2025 this work was ongoing.

Managing conflicts of interest

3.30 The Australian Public Service Code of Conduct⁶⁶ and the Public Governance, Performance and Accountability Act 2013⁶⁷(PGPA Act) requires employees of a Commonwealth entity to disclose details on any material personal interest that relates to the affairs of the entity. The Redress Act states that the general duties of officials ‘apply to an Independent Decision Maker the same way as they apply to an official’.⁶⁸

3.31 The department has a framework for managing conflicts of interest for redress personnel, which is supported by a Scheme specific conflict of interest strategy. The Scheme’s conflict-of-interest strategy requires all staff in the Redress Group to complete and submit a conflict-of-interest disclosure form, for any real, potential or perceived conflicts:

• at the commencement of the staff member’s engagement;⁶⁹
• every three months⁷⁰; and
• when a conflict of interest arises.

3.32 The department advised the ANAO on 28 March 2025 that completions of conflict-of-interest declarations are monitored by the Group and all declarations must be approved by the relevant manager.

3.33 In 2024 the department conducted a Fraud Risk Data Analytic Treatment project focused on insider threats (see paragraph 2.38 for discussion of fraud risks). The project identified six suspected policy non-compliance matters related to redress staff conflict of interest obligations. The six matters were referred to the Redress Group and each case was assessed by the Group’s Director, Integrity. The Director, Integrity referred relevant cases to the People Services Branch for potential breach of the Australian Public Service Code of Conduct. In May 2025 the department advised ANAO that:

No individual case has resulted in broader changes to the policy, practice or promotion of Conflict of Interest arrangements for staff, however upon each review People Services Branch enquire regarding the frequency of such promotions of the Conflict of Interest policy and practices within Redress to ensure they are appropriate and should any concerns be identified recommendations for improvement would be provided to Redress for consideration and implementation.

3.34 The department advised the ANAO in May 2025 that it would be conducting the Fraud Risk Data Analytic Treatment exercise annually, with the next iteration due by the end of 2025.

3.35 The Scheme’s Conflict of Interest Strategy applies to Independent Decision Makers (IDMs) who are engaged by the department as contractors through a commercial labour hire arrangement. IDMs are subject to an additional disclosure process during recruitment; completing a manual conflict of interest form prior to their interview for the role. Once engaged, the department requires IDMs to follow the same conflict of interest process as other redress staff. The department advised the ANAO on 28 March 2025 that no conflict-of-interest breaches (actual or potential) had been raised for IDMs over the life of the Scheme.

Decision-making framework

3.36 The Act (sections 29 to 33) sets out the decision-making framework for applications to the Scheme. Where the Operator considers that there is a ‘reasonable likelihood that the person is eligible for redress’, they must approve the application (section 29(2)(a)).

3.37 If the application is approved, the Act requires the Operator to make a number of determinations under subsection 29(2), including determining:

• the institution(s) responsible for the abuser(s) having contact with the person;
• the amount of redress payment for a person;
• the amount of the counselling and psychological component of redress for the person; and
• each responsible institution(s)’ share of the costs of the redress payment, counselling and psychological care and administration of the Scheme.

3.38 The Scheme Operator has delegated authority for making determinations on applications for redress to IDMs engaged by the department.⁷¹ In addition to the Act, and the National Redress Scheme Assessment Framework 2018⁷² (the Assessment Framework)⁷³, the department established guidance documents to support decision making under the Scheme including:

• Assessment Framework Policy Guidelines 2019 (Oct 2019);
• Internal Assessment Guide (Version 4.0, Aug 2023)⁷⁴;
• Independent Decision-making Quality Framework (Version 1.0, Apr 2021);
• Statement of Reasons Guide (Version 1.2 Oct 2024);
• An Administrative Decision-making Guide for making a determination under the National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (Version 3.0, Sep 2024);
• Guides to Social Policy Law National Redress Guide (Version 1.25, 20 March 2025); and
• Trauma-informed Framework (May 2023).

3.39 Contributions to the audit raised concerns about the consistency of, and transparency in, decision-making.

3.40 As at 30 June 2025, the average time to progress an application through the department’s decision-making stage (from the date an application is assigned to an IDM, to the date the applicant is advised of the outcome of their application) was 4.2 months, remaining steady or increasing year on year (see Table 3.8). Of the completed applications, 593 took less than one month to complete the decision-making stage, and one application took the longest at 64 months.

Table 3.8: Average decision-making time (months) for completed applications, by year application received as at 30 June 2025

Note a: Data for 2024–25 is not included in this analysis due to the low number of applications received in that year being completed.

Source: ANAO analysis of the department’s data.

3.41 The department has not established performance targets for IDMs or timeliness expectations for IDM decision making. The 2024 Independent Review of the National Redress Scheme⁷⁵ observed that a lack of clear expectations for IDMs was likely contributing to inefficiency in the IDM decision-making process.

Quality assurance of decision making

3.42 In April 2021, the department established an Independent Decision-making Quality Framework (Quality Framework) for the Scheme. The Quality Framework describes the:

• roles and responsibilities of IDMs;
• administrative tools and support for decision making, such as quality checks of documentation during the application management process, and a case allocation process that considers any conflicts of interest of IDMs; and
• the department’s arrangements established to support continuous improvement in the quality and consistency of IDM determinations — including IDM panels, quality checks of the IDMs’ Statement of Reasons⁷⁶, and six-monthly quality reviews.

3.43 The Quality Framework states that ‘a currency review of the [Independent] Decision-making Quality Framework will be undertaken annually’. In May 2025 the department advised the ANAO that the annual currency review had not been conducted.

3.44 The Quality Framework states that IDM panels⁷⁷ would be established to enable IDMs to compare cases and information, to promote consistent decision making and to provide support through mentoring and coaching by other panel members, particularly on complex cases. The department advised the ANAO in May 2025 that there are two panel types; the Chief IDM Panel (established in 2022, and discussed further in paragraph 3.45) and a weekly meeting of newly appointed IDMS and their Team Leader (Executive Level 1) to ‘receive appropriate support during their initial period.⁷⁸’

3.45 The department established a Chief IDMs Panel⁷⁹ in March 2022 in response to a recommendation from the Second Year Review of the National Redress Scheme⁸⁰. The recommendation was that the Australian Government create the position of a Chief IDM to strengthen consistency and integrity in the Scheme’s decision making.⁸¹ The Chief IDMs Panel’s terms of reference state that the panel can provide advice and feedback to IDMs through informal discussions or formal referrals. The department advised the ANAO in May 2025 that as at 15 May 2025, 29 applications had been referred to the panel, and the panel ‘generally responded [to the IDM] within a one to two week period.’ The department did not evaluate the consistency or integrity of the Scheme’s decision making before or after the introduction of the Chief IDMs Panel.

3.46 The Quality Framework requires six monthly quality reviews of IDMs’ ‘Statements of Reasons’ as a process intended to ensure consistency in decision-making standards across IDMs. It notes that they are to be conducted at the discretion of section Directors and occur on a ‘random sample of each Independent Decision Makers’ Statement of Reasons’. The six-monthly checks are in addition to the quality assurance checks that occur during the decision-making phase. The department advised the ANAO in May 2025 that the six-monthly quality reviews have not occurred.

Fraud and corruption control management framework

3.50 The department’s fraud and corruption control framework comprises:

• the Secretary’s Instruction on Fraud and Corruption Control;
• a Fraud and Corruption Control Plan 2024–26;
• a Fraud and Corruption Control Policy;
• an Enterprise Fraud and Corruption Risk Assessment; and
• targeted Fraud and Corruption Risk Assessments.⁸²

3.51 Fraud risk is rated as ‘extreme’ in the June 2023 National Redress Scheme Fraud Risk Assessment (current as at May 2025). Contributions to the audit raised concerns about fraud and ‘claim farming’ in the Scheme.⁸³ Specifically, prevention, identification and management of suspected cases.

3.52 The department developed a National Redress Scheme Fraud Control Plan in 2018 to outline the department’s approach for preventing, detecting and responding to fraud in the development of the National Redress Scheme. It states that fraud detection activities, including the legitimacy of application information, applicant identity checks and monetary payments are the responsibility of the Department of Human Services [now Services Australia]. The department did not revise its fraud control plan after the Machinery of Government changes in 2020.

3.53 The Scheme’s fraud control plan was not revised to accompany its June 2023 National Redress Scheme Fraud Risk Assessment (discussed in paragraphs 2.37 to 2.43). This is inconsistent with the requirements of the department’s Fraud and Corruption Policy (July 2024) which requires an accompanying fraud and corruption control plan for all targeted fraud and corruption risk assessments. The National Redress Scheme Fraud Control Plan and National Redress Scheme Fraud Risk Assessment were updated on 25 and 31 July 2025 respectively.

3.54 With concerns about emerging trends in potential fraud the department commissioned a review of the Scheme’s fraud risk and assurance arrangements.⁸⁴ The report stated that the June 2023 National Redress Scheme Fraud Risk Assessment had not established due dates for the proposed treatments. The report recommended that, given the risk ratings in the fraud risk assessment (which include one extreme, two high and one medium rated fraud risks), as well as the trend of suspected fraud, that the department establish realistic timeframes for each proposed treatment, in conjunction with a strategy to monitor implementation of treatments. The report was not considered by the department’s Audit and Risk Committee. The Scheme’s risk assessment update in July 2025 included due dates for the proposed treatments.

3.55 The fraud review (October 2023) identified ‘at least 60 historical events not previously referred that may be referred to [the Audit and Assurance Branch] once capacity allows the Redress Data and Assurance team to revisit these matters.’ In May 2025 the department advised the ANAO that it was unable to confirm if these matters were subsequently referred to the Audit and Assurance Branch, and that a referral tracking process was established in 2024.

3.56 In April 2025, the department advised the ANAO that between July 2018 and 9 April 2025, there were 137 referrals for fraud/corruption assessments related to the Scheme, 58 per cent of which were the result of external tipoffs, 38 per cent were identified through internal processes and four per cent through a combination of both internal and external.⁸⁵

3.57 The referrals of suspected Scheme fraud or corruption concerned the provision of false and misleading information (87 per cent) or other matters such as the misuse of identity, payment interception and impersonating a public official. The department further advised that of the 137 referrals, 11 per cent had been passed on to investigation (of which 67 per cent were currently open, 20 per cent had been prosecuted, and 13 per cent were closed).

3.58 The department advised the ANAO in July 2025 that it ‘analyses trends relating to both suspected and affirmed Scheme fraud, as well as instances of irregular or linked applications (which are possibly representative of fraud)’ and that there ‘appears to be a growing trend of potentially false applications being submitted to the Scheme.’ The department provided an example of a 2023 departmental briefing to the Secretary about growing trends in clusters of linked applications, applications with similar content and applications with limited detail. As a result, the Secretary led a fraud and assurance governance forum with departmental stakeholders that had fraud or redress responsibilities, where fraud and assurance statistics were discussed.

Does the department have appropriate processes for reviews and complaints of Scheme decisions?

Revocations

3.59 Under section 29 of the Act, the Scheme Operator (Operator) can revoke a determination on an application for redress.⁸⁶⁸⁷ The Secretary has delegated the power to revoke a determination to IDMs. The IDM who made the original decision may choose to revoke a determination if, after the decision has been made and before the applicant accepts or rejects their redress offer:

• the Scheme receives information that the IDM did not have before making the determination; and
• the information is such that, if the IDM had the information before a determination was made, they would have made a different determination.⁸⁸

3.60 The Internal Assessment Guide (see paragraph 3.38) is the primary source of guidance for Scheme staff and IDMs on revocations. Information about the revocation process is available to the public in the department’s Guide to Social Policy Law, National Redress Guide.⁸⁹

3.61 The department advised the ANAO on 16 May 2025 that 436 revocations had been considered since 2019–20, of which 248 (57 per cent) were granted, 115 (26 per cent) were not granted, and 70 (16 per cent) were still in progress. The outcome of granted revocations is detailed in Table 3.9. The number of revocations is not reported to the Group Executive.

Table 3.9: Outcomes of granted revocation requests from 2019–20 to 13 May 2025^a

Note a: Data is at 13 May 2025. Data considers the eligibility and monetary components of the determination and does not include specifics of the responsible institutions or prior payment assessments which could be altered without impacting components of redress.

Source: Department data.

Reviews

Review process

3.62 The Act (Part 4–1) sets out the legislative framework for a review of a determination if a person is dissatisfied with an offer of redress.⁹⁰ A review can be requested by an applicant after a determination is made but before the offer is accepted or rejected, and the application is considered ‘completed’. The Act requires the Operator to follow specific legislative requirements to undertake a review of a determination. Appendix 3 summarises the main tasks in the review process.

3.63 The department provides internal reports to the Group Manager and Branch Managers that include reporting on the volume, status, and outcome of applications subject to a review of determination. The department does not have a process or procedure to guide when and how information from outcome review data is used to inform process improvements.

3.65 The Scheme is exempt from consideration by the Administrative Appeals Tribunal (and its replacement the Administrative Review Tribunal⁹¹) under the Administrative Decisions (Judicial Review) Act 1977. The Second Interim Report of the Joint Select Committee on Implementation of the National Redress Scheme (November 2021) notes that ‘this means that the only avenues remaining for judicial appeal may be to the Federal Court under section 39B of the Judiciary Act 1903 or the High Court of Australia under section 75 of the Australian Constitution.’

3.66 Contributions to the audit raised concerns about the timeliness of review decisions and a lack of clarity about the process. Participating Institution contributions noted that there was no avenue for Participating Institutions to request a review.

Review outcomes

3.67 As at 24 April 2025, the department had received 1,111 requests for review of original determinations, (two per cent of Scheme applications).⁹² There was a 131 per cent growth rate in review requests between 2023 and 2024, which is consistent with the growth in applications over the same period (see Figure 3.3).

Figure 3.3: Number of applications and review requests, by year received

Source: ANAO analysis of the department’s data.

3.68 The most common reasons recorded for a review request was disagreement with the overall decision and with the monetary payment decision. The reasons recorded for review requests are summarised in Table 3.10.

Table 3.10: Reasons recorded for requests to review determination

Note: Multiple reasons can be recorded for a single request. Therefore, the numbers in Table 3.10 exceed the number of review requests received.

Source: ANAO analysis of the department’s data.

3.69 Over the life of the Scheme 93 IDMs were appointed, of which 88 had at least one request for a review of their original decision. The maximum number of review requests received by a single IDM was 62. Fourteen per cent of the IDMs with at least one review requested on their original decision accounted for 47 per cent of the review requests.

3.70 As at 24 April 2025, 54 per cent of the applications with a review request have had their application completed. The average time taken, from the date the review was requested to the date the applicant was advised of the review outcome, was 3.5 months.

3.71 Of the completed applications with a review request, the review affirmed 77 per cent of the original decisions. Of the review determinations that did not affirm the original decision (33 per cent), 83 per cent resulted in an increase in redress. Table 3.11 provides a breakdown of review outcomes.

Table 3.11: Redress review outcomes as at 24 April 2025

Source: ANAO analysis of the department’s data.

3.72 Of the 133 reviews where the reviewing IDM disagreed with the original IDM decision, 53 per cent were due to a disagreement with the original eligibility decision or the extreme circumstances decision⁹³ (see Table 3.12).

Table 3.12: Reasons for review IDM disagreement with original IDM decision

Source: ANAO analysis of the department’s data.

3.73 Of the 88 IDMs that had at least one review requested on an original decision they had made, the reviewing IDM disagreed at least once with the original decision of 48 IDMs (55 per cent). Of the 48 IDMs who had a review result that disagreed with their original decision, eight IDMs (17 per cent) had five or more such review results, with the maximum for a single IDM being nine.

Complaints

Complaint process

3.74 A complaint is defined by the department as:

Expression of dissatisfaction made to or about an organisation, related to its products, services, staff or the handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required.

3.75 The department has a Complaints Handling Policy and Procedure (December 2024, February 2022), and a Scheme Complaints Management Framework (the Complaints Framework, March 2023) which provides guidance for staff who receive, respond to or manage complaints for the Scheme.

3.76 The Scheme’s Service Charter (August 2022) notes the Group will try to:

• make it easy for someone to submit a complaint;
• provide a response within 28 days of receiving a complaint;
• keep complainants informed about the progress of their complaint; and
• learn from complaints to improve the Scheme.⁹⁴

3.77 Contributions to the audit highlighted different levels of knowledge and understanding about the complaints process and outcomes.

3.78 If a complaint is considered to be complex, and the 28-day response timeframe is unlikely to be met, the Redress Complaints team can request an extension from the Audit and Assurance Branch, citing the reason(s) the extension is required. In June 2022 the department started recording if an extension was given. The reason for the extension was not recorded.

3.79 If an applicant is dissatisfied with their complaint outcome they can request a review of the complaint response. Where an applicant remains dissatisfied with the Scheme’s handling of their complaint, a complaint can be escalated to either the Commonwealth Ombudsman or the Australian Human Rights Commission. Additionally, complaints can be escalated to the Minister for Social Services’ Office or directly to a member of the department executive.

3.80 The department has recorded complaints related to the Scheme since July 2018. The recording of the complaint topic or theme was a free text data field until June 2022, limiting analysis for improving processes. Complaint Theme Guidelines were implemented in May 2023 to improve the recording of complaint themes.

3.81 No complaint reporting within the department was done prior to 2022 or from November 2024 to January 2025. Data on the number of complaints related to the Scheme were reported to the department’s Scheme Operations Committee from March to December 2023. The data covered how many complaints had been made, and how they were received: it did not include data on response timeliness, extensions or common themes. Since February 2025 complaint data has been incorporated into a monthly dashboard to the Scheme’s Performance Committee.

Complaint outcomes

3.82 Between July 2022 and November 2024, the Scheme received a total of 1,062 complaints (Figure 3.4).

Figure 3.4: Complaints about the Redress Scheme received by the department between July 2022 and November 2024

Source: ANAO analysis of the department’s data.

3.83 For the complaints recorded as completed between July 2022 and November 2024,⁹⁵ 30 per cent of the complaints were upheld. The average number of days to process a complaint was 19.9 calendar days, ranging from a minimum of less than one calendar day to a maximum of 182 calendar days. The department’s overall policy has specific performance measures for responding to a complaint, stating that 90 per cent of all complaints will be responded to within 28 days. For the examined period, 78 per cent of completed complaints received a response with 28 days. The complaints tracker data does not include detail on any extensions granted to the processing deadline.

3.85 The Office of the Commonwealth Ombudsman’s (the Ombudsman) role is to act as an independent oversight body to ensure that Australian Government agencies act fairly, lawfully and efficiently in their dealings with the public.⁹⁶

3.86 The Ombudsman advised the ANAO that as of 25 March 2025, the Office had received a total of 75 complaints about the National Redress Scheme. The Office may decline to investigate a response for several reasons, ⁹⁷ as outlined under sections 5 and 6 of the Ombudsman Act 1976. Following an assessment of the 75 Scheme complaints, eight matters resulted in an investigation by the Office. The overall themes of the complaints investigated were described by the Ombudsman’s office as:⁹⁸

• five investigations related to delays or failure to act by the department; and
• three investigations related to advice given by the department.

Does the department have fit for purpose processes to manage debt recovery for the Scheme?

3.87 The Act (Part 6–3) and the National Redress Scheme for Institutional Child Sexual Abuse Rules 2018 (the Rules) specify the debt recovery arrangements for the Scheme. The department has summarised the funding contribution liability responsibilities for Participating Institutions in its Guides to Social Policy Law: National Redress Guide (the Guide) available on the department’s website.

3.88 The department has had an Accounts Receivable, Debt Management and Recovery Policy since 2017 which outlines the responsibilities of officials in managing debt recovery. It states that the department is committed to ensuring accurate, timely and efficient receipting of amounts owed to the department. In 2023 the department established a National Redress Scheme Debt Management and Imposition Late Payment Penalty Position Paper (endorsed by the Redress Policy and Strategy Committee 8 March 2023) which outlined the Scheme’s approach to the management of debt owed by institutions.

3.89 Once a redress payment has been made and/or counselling and psychological services have been paid for by the Scheme Operator, the department issues an invoice to the liable Participating Institution(s), or funder(s) of last resort,⁹⁹ on a quarterly basis, to recoup the upfront costs to the Australian Government.

3.90 As at 30 June 2025, $1.78 billion had been invoiced for the Scheme, of which 95 per cent ($1.69 billion) had been recovered from Participating Institutions, with 65 per cent of the invoices issued to Participating Institutions having had at least one payment. Standard Operating Procedures for quarterly invoicing were developed in 2020, and updated in 2021, 2023 and 2024. The department advised the ANAO in October 2024, that the invoicing process was not standardised prior to 2020 and involved the manual creation of invoices.

3.91 The department advised the ANAO that as at October 2024 there were 18 active payment plan arrangements in place¹⁰⁰, with a total balance remaining of $10,467,591. The department’s National Redress Scheme Debt Management and Imposition of Late Payment Penalty Position Paper (March 2023) states that ‘payment arrangements with the Scheme range in length from six to 66 months.’

3.92 As at 30 June 2025, 45 waivers¹⁰¹ of funding contributions had been recorded in the financial data over the life of the Scheme, with an average individual value of $54,263 and a total amount waived of $2,441,856. If a Participating Institution or funder of last resort is not satisfied with a waiver decision, they may request the Operator reconsider the decision within 21 days of the notice of decision. The department advised the ANAO on 26 March 2025 that since the start of the Scheme, eight requests for a review of a waiver decision were made, none of which resulted in a change to the waiver decision.

3.93 Regular invoice reconciliation is important for maintaining accurate records and detecting payment issues and potential fraud. The Scheme has no invoice reconciliation records covering Quarter 1 2018–19 to Quarter 4 2019–20, and Quarter 1 2021–22 to Quarter 4 2021–22. All the available reconciliation records are dated 2024, indicating that the records prior to 2024 were done retrospectively.

Timeliness of payments

3.94 The Act (subsection 153(1)(b)) specifies that funding contributions are payable within 30 days of the date of the invoice. As at 30 June 2025:

• 71 per cent of invoices had received a first payment or been paid in full within 30 days of the date issued (ranging from 64 per cent in 2021–22 to 79 per cent in 2024–25);¹⁰²
• the average number of days before the department received at least one invoice payment was 42 days from date of issue, with the longest being 1,249 days; and;
• the proportion of invoices that received at least a first payment, or were paid in full, over 60 days from the date the invoice was issued ranged from 25 per cent in 2020–21 to six per cent in 2023–24.

Monitoring and reporting of funding contributions

3.95 Prior to 2023 there was no monitoring and tracking of funding contribution invoices and payments for the Scheme. In 2023 the department established a National Redress Scheme Debt Management and Imposition Late Payment Penalty Position Paper (see paragraph 3.88) which established the monitoring and tracking process. The paper did not specify what debt management information would be reported to the executive, and when, to support evaluation of performance.

3.96 Deferment of payments approved under section 153 of the Act, and payment plans approved under section 170 of the Act, were manually recorded and tracked by the department. The department advised the ANAO in October 2024 that payment plans and extensions were reported via a Financial Matters report, until 14 September 2023. This file was regularly overwritten with no version control. The only copy held by the department is dated 14 September 2023. The department further advised that from September 2023 to May 2024 new or amended payment plans were reported monthly to the Branch Manager in a Payment Arrangement Tracker. No record of this was available. In August 2024 a financial monitoring dashboard was tested. The department advised the ANAO in April 2025 that it had not been consistently used and work was underway to develop a new process for reporting on deferred payments and payment plans.

3.97 The department did not monitor Participating Institutions for potential late payment penalties prior to April 2023. The department advised the Deputy Secretary in March 2023 that this was the result of an inability to identify aged debtors due to system limitations and not having debt management arrangements in place. On 4 March 2023 the acting Deputy Secretary, Families and Communities approved a waiver of any potential late payment penalties that had been incurred from the start of the Scheme to 31 March 2023. From April 2023, the department commenced monitoring for late payment penalties. The department advised the ANAO in April 2025 that from 2022–2023 to 2023–2024, seven institutions had late payment penalties identified, totalling $6,680.99, all of which were waived by the acting Deputy Secretary.

End of Scheme planning

3.99 The department received advice in February 2023 that it is appropriate for the department to enter into, modify or terminate arrangements to repay redress debts (in accordance with section 170 of the Act) that extend past the Scheme’s end date, as:

the debt to repay a funding contribution is a Commonwealth debt and the Department is obligated to seek repayment of the debt until it is repaid (or meets other specified criteria) under the Public Governance, Performance and Accountability Act 2013.

3.100 The department’s National Redress Scheme Debt Management and Imposition of Late Payment Penalty Position Paper (March 2023) states that ‘there has been a convention that payment arrangements do not extend beyond the life of the Scheme. However, the delegate may extend the repayment period to cover a longer period if the institution is able to demonstrate a need for it.’ As at 23 July 2025 one payment arrangement had a due date three years beyond the Scheme’s end date.

4.1 Under the Public Governance, Performance and Accountability Act 2013 (PGPA Act), a Commonwealth entity must keep records that properly record and explain the entity’s performance, and measure and assess its performance in achieving its purposes. Performance information is of most value when it is used to assess whether an entity’s purposes are being met, and to provide a mechanism for continuous improvement. In addition to improving performance, well constructed and complete performance information can have an impact on improving productivity, policy and program implementation, integrity and innovation.

4.2 The National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (the Act) requires the Scheme Operator to prepare a report for the Minister for Social Services on the operation of the Scheme as soon as practicable after the end of each financial year.¹⁰³ The matters that the report must include are set out in section 75 of the National Redress Scheme for Institutional Child Sexual Abuse Rules 2018 (the Rules). The Minister for Social Services must present the report to the Parliament.

4.3 Section 192 of the Act requires the Minister for Social Services to conduct a review of the operation of the Scheme as soon as possible after the second and the eighth anniversaries of the start of the Scheme.¹⁰⁴ In addition, Parliament established the Joint Select Committee on Implementation of the National Redress Scheme (September 2019 to April 2022) and the Joint Standing Committee on Implementation of the National Redress Scheme (July 2022 to November 2024 and restarting July 2025) to inquire into, and report on, the response to the recommendations of the Royal Commission into Institutional Responses to Child Sexual Abuse, including the implementation and operation of the Scheme. As at June 2025 there have been six reports from reviews or enquiries into the Scheme.

4.4 The ANAO examined overall Scheme performance reporting, including reporting on the performance of Services Australia under the Redress Program Delivery Services Schedule; what reporting is done on the efficiency of the Scheme; and the monitoring of the implementation of recommendations from reviews and inquiries into the Scheme.

Is appropriate reporting done on the Scheme to monitor progress and outcomes?

Corporate plans

4.5 The Department of Finance describes a corporate plan as:

designed to be a Commonwealth entity’s primary planning document. It provides Parliament, the public and stakeholders with an understanding of the purposes of an entity, its objectives, functions or role. It sets out how the entity undertakes its key activities and role and how it will measure performance in achieving its purposes.¹⁰⁵

4.6 The department’s corporate plans from 2018–19 to 2024–25 identify four outcomes: Social Security, Families and Communities, Disability and Carers, and Housing. The Scheme forms part of the Families and Communities outcome (Program 2.1).¹⁰⁶

4.7 The department had five performance measures and associated targets in its 2024–25 Corporate Plan to publicly report on the performance of the Scheme. Appendix 4 shows how these have changed over time.

4.8 The department’s performance measures for the Scheme do not monitor application processing times for the Scheme from start to finish, and do not reflect the progress of applications. The 2024 Independent review report included a recommendation to develop and implement a concise set of whole-of-scheme performance measures and key performance indicators that enable oversight and drive efficient whole-of-scheme administration (recommendation 4). The department advised the Minister for Social Services in June 2024 that it was developing whole-of-scheme performance measures and key performance indicators that would enable oversight and drive efficient whole-of-scheme administration. In May 2025 the Redress Group approved new key performance indicators ‘expanding … the management information available to the Scheme executive … [allowing] for clear identification of slippage against targets for monthly and annual application finalisation.’

Annual reports

4.9 The department acquits the reporting requirement of the Act by including a report on the operation of the Scheme in its annual reports, which it has done since 2018–19.¹⁰⁷ The annual reports include the department’s assessment of its performance against the measures detailed in the department’s corporate plan for the same financial year (see Appendix 4). The annual reports for 2019–20 and 2021–22 included reporting against performance measures that were not in the corresponding corporate plan as noted in Appendix 4.

Other reports

4.10 Since September 2019, the department has published monthly ‘Updates to the Scheme’ reports on its website. The reports include information on institutions that have declined to participate in the Scheme, the Minister’s Governance Board meeting outcomes, changes to the Scheme during the reporting period, and updated Scheme data.¹⁰⁸

4.11 Since October 2020, the department has periodically published ‘Strategic Success Measures’ reports on its website with the purpose of providing ‘survivors and the broader community an indication of how the Scheme is performing across three priority areas: survivor experience, health of the Scheme and equity of access’.¹⁰⁹ Since December 2022 these reports have included reporting against the Scheme’s performance measures. As at 21 May 2025, the most recent Strategic Success Measures report published on the Scheme’s website was June 2024.

Internal reports

4.12 The department has established internal reports that provide various statistics on applications to the Scheme. Table 4.1 describes the internal reports that were used by the executive within the department to monitor Scheme performance, as at November 2024.

Table 4.1: Departmental internal reports on Scheme performance (as at November 2024)

Note a: Based on the department’s advice.

Note b: The department advised the ANAO in May 2025 that the Scheme ceased producing the dashboard due to the recent change of Minister and it ‘was working with the new Minister’s Office to determine the most appropriate way of providing redress data.’

Source: Department’s advice to the ANAO and the department’s records.

4.13 The content, frequency and data sources for internal reports have changed over time. The reports do not specify the data methodology or highlight when the methodology has changed and why.

Performance reporting under the Bilateral Management Agreement

4.15 As set out in paragraph 2.14 the service arrangements between the department and Services Australia for the National Redress Scheme were incorporated into the Bilateral Management Arrangement on 24 June 2021.

4.16 The National Redress Scheme Service Arrangement (effective from 24 June 2021 to 27 June 2024)¹¹⁰ specified three high-level ‘Key Performance Measures’ that Services Australia was required to report against. Reporting against the Key Performance Measures was provided to the department through an Annual Assurance Statement from the Chief Executive Officer of Services Australia. The three Key Performance Measures were:

• timeliness — Applicants receive payments and services for which they are eligible in a timely manner thereby achieving the policy outcome;
• payment integrity — The accuracy of payments and service outlays are meeting relevant benchmarks and respective entities are able to discharge their responsibilities as agreed in the Bilateral Management Arrangement; and
• relationships management — Business Continuity and Integration of Social Services: Planning, systems, processes and infrastructure are integrated and support business continuity and delivers policy outcomes.

4.17 None of the Annual Assurance Statements for 2020–21 to 2023–24 report against the key performance measures for the National Redress Scheme.

4.18 The National Redress Scheme Service Arrangement included 12 Service Level Agreements which set out the expected performance levels for each service provided by Services Australia for the National Redress Scheme. The arrangement does not require Services Australia to report against the expected performance service levels.

4.19 In February 2025, the department advised the ANAO that:

There were limited clearly defined requirements for reporting against Service Levels specified in the various attachments to the 2021 and 2022 Service Arrangements. However, there was regular engagement and reviews of the Service Arrangements which included performance as one of the elements being reviewed. If issues occurred relating to a specific attachment, the ‘Contact’ against each attachment either liaised with their counterpart in Services Australia to seek resolution of the issue or escalated via the specified Service Arrangement/Schedule Contact Officer role. There is no evidence of [performance] reports found on ARC, SharePoint or Share drive.

There remains regular engagement, at officer level, to monitor performance as a whole and specific issues/areas of concern and/or blockages.

4.20 On 28 June 2024 the department and Services Australia signed a new arrangement for the Scheme — a Program Delivery Services Schedule (the Schedule) for the National Redress Scheme. It includes a statement that Services Australia will ‘report on performance, conformance and assurance to the department, including system usage metrics’. The Schedule contains no key performance measures for services to the National Redress Scheme.

4.21 The Schedule includes 13 Service Level Agreements which set out the expected performance levels for each service provided by Services Australia for the National Redress Scheme. In May 2025 the department requested reporting from Services Australia against the 2024 Service Level Agreements.

4.22 There is no reporting process or established governance arrangements within the department that provides oversight of Services Australia’s performance against the agreed service levels under the Program Delivery Services Schedule. In February 2025, the department advised the ANAO that discussions were underway between the department and Services Australia to improve visibility and oversight within the department of Services Australia’s delivery of services for the National Redress Scheme.

Is there appropriate monitoring and reporting on the efficiency of the Scheme?

4.26 The Department of Finance states that ‘there is a reasonable expectation that performance measurement would include measures of … efficiency of the key activities undertaken to achieve purposes, where appropriate.’¹¹¹ The department has no efficiency measures for the Scheme (see Appendix 4).

4.27 The department established a proxy measure¹¹² for efficiency of processing applications in 2020–21:

at least 80 per cent of applications lodged [in that year] that name institutions that participate in the Scheme, have a decision communicated to the applicant within six months of being received by the Scheme.

4.28 The proxy efficiency measure target for processing applications continued until the 2021–22 annual report when the department changed the target from 80 per cent to 70 per cent, to ‘more meaningfully cover the activities of the department in managing the Scheme’. This target was changed again in the 2022–23 Corporate Plan from 70 per cent to 75 per cent. There have been no further changes to the proxy efficiency measure (see Appendix 4).

4.29 In its 2023–24 Annual Report the department states that:

Measuring the timely and quality finalisation of National Redress Scheme applications and offers made to survivors aims to demonstrate the department has efficiently processed and managed applications. This is a measure of proxy efficiency that demonstrates achievement of a key output of the National Redress Scheme key activity.

Targeting ‘at least 75 per cent of applications that name institutions that participate in the Scheme, have a decision communicated to the applicant within 6 months of all required information being received by the Scheme’ demonstrates proxy efficiency of the key activity by showing applications are processed within a timely and reasonable timeframe, and is reflective of the complexity of the assessment process, available resources to process applications, and institutions that have joined the Scheme.

4.30 In the 2023–24 Annual Report the department reported that, ‘the Scheme is implementing measures to improve the efficiency of the application assessment process and deliver outcomes to applicants sooner.’ It notes that:

The Australian Government provided funding in the 2024–25 Budget for new and expanded services to assist applicants to submit ‘more complete’ applications, and to receive independent legal advice from knowmore Legal Services. Additionally, the Scheme will recruit additional Independent Decision Makers to increase the timeliness of providing outcomes to applicants.

4.31 The 2024 Independent Review of the National Redress Scheme recommended that the department ‘develop and implement a concise set of whole of scheme measures of cost and efficiency that enable oversight and drive efficient Scheme administration’ and ‘develop and implement a concise set of whole of scheme performance measures and KPIs that enable oversight and drive efficient whole of scheme administration.’ All recommendations were accepted by the Minister on 24 April 2024 and the department advised the Minister for Social Services on 7 February 2025 that cost and efficiency measures had been implemented as part of a project to prepare the Scheme’s Estimates Variation for 2025–26. In May 2025 the department advised the ANAO that:

The 2025–26 Estimates Variation was informed by the Scheme’s workforce and cost models combined with modelling of the efficiencies already delivered and/or anticipated through the implementation of improvement initiatives. Updated performance measures developed by the Scheme will inform the Scheme’s monitoring of its performance and approach to whole of Scheme workforce management, informing future Estimates Variations.

Has the department established appropriate arrangements to monitor implementation of review recommendations?

4.36 Since 2018 there have been six reports from reviews or enquiries into the Scheme, including four reports from Parliamentary Committees. The Act requires that a further review takes place as soon as possible after the eighth anniversary of the Scheme start date (1 July 2026).¹¹³

4.37 The six reports made a total of 142 recommendations, of which 53 per cent concerned procedures for processing applications and the wellbeing of applicants. Procedures, governance and finance were themes that occurred in recommendations from all six reports.

4.38 The Australian Government has considered the recommendations from the first five reports and supported (in full, part or principle) 86 (76 per cent) of the 113 recommendations (see Table 4.2). The Final Report by the Joint Standing Committee on Implementation of the National Redress Scheme was published in November 2024 and as at July 2025, the Australian Government’s response was pending.

Table 4.2: Government response to recommendation actions from the first five reports on the Scheme

Note a: Supported includes the following government responses — accepted, agreed, supports.

Source: Departmental analysis

4.39 The Redress Group periodically advises the Group Executive, Secretary and Minister for Social Services about progress on implementing agreed recommendations. The department has advised the Secretary that 88 per cent of the agreed actions across the first five reports have been completed.

4.40 There is no single reporting framework for monitoring the implementation of all agreed report recommendations. Updates on the implementation of the Second Year Review recommendations were given to the Group’s Policy and Strategy Committee. No updates on other reports were given. The Policy and Strategy Committee was replaced by the Group’s Strategic Planning and Risk Committee in 2024, and as at January 2025 it had not received updates on the implementation of agreed recommendations from any of the reports. The departmental Audit and Risk Committee has received updates on issues and risks to implementation of recommendations for three of the six reports. It is unclear how continuity over implementation reporting and monitoring occurred between the six reports.

Appendix 1 Entity response

Appendix 2 Improvements observed by the ANAO

1. The existence of independent external audit, and the accompanying potential for scrutiny improves performance. Improvements in administrative and management practices usually occur: in anticipation of ANAO audit activity; during an audit engagement; as interim findings are made; and/or after the audit has been completed and formal findings are communicated.

2. The Joint Committee of Public Accounts and Audit (JCPAA) has encouraged the ANAO to consider ways in which the ANAO could capture and describe some of these impacts. The ANAO’s corporate plan states that the ANAO’s annual performance statements will provide a narrative that will consider, amongst other matters, analysis of key improvements made by entities during a performance audit process based on information included in tabled performance audit reports.

3. Performance audits involve close engagement between the ANAO and the audited entity as well as other stakeholders involved in the program or activity being audited. Throughout the audit engagement, the ANAO outlines to the entity the preliminary audit findings, conclusions and potential audit recommendations. This ensures that final recommendations are appropriately targeted and encourages entities to take early remedial action on any identified matters during the course of an audit. Remedial actions entities may take during the audit include:

• strengthening governance arrangements;
• introducing or revising policies, strategies, guidelines or administrative processes; and
• initiating reviews or investigations.

4. In this context, the below actions were observed by the ANAO during the course of the audit. It is not clear whether these actions and/or the timing of these actions were planned in response to proposed or actual audit activity. The ANAO has not sought to obtain assurance over the source of these actions or whether they have been appropriately implemented.

• The Department of Social Services and Services Australia established a Redress Shared Risk Management Plan in November 2024.
• On 17 February 2025, the Secretary approved the department’s risk appetite statement.
• In February 2025 the department initiated a monthly email to the Deputy Secretary providing updates on ‘high risks’ identified in the Scheme’s risk management plan, including a draft email for the Deputy Secretary to send to the Secretary informing them of this update.
• In February 2025 the department established a Redress Oversight Committee.
• In May 2025 the department initiated discussions with Services Australia about performance reporting.
• In May 2025 the department agreed additional key performance indicators to enable ‘clear identification of slippage against targets for monthly and annual application finalisation’.
• The National Redress Scheme Fraud Control Plan and National Redress Scheme Fraud Risk Assessment, were updated on the 25 and 31 July 2025 respectively.

Appendix 3 Overview of Scheme application process stages

1. The Department of Social Service’s application management process comprised of six processing stages, with additional processes for applicants requesting a review of their application outcome, summarised in Figure A.1.

2. Table A.1 provides an overview of the activities within each of the six stages and two review processes for the Redress Scheme application process as documented in the department’s Redress Maps and Resources Suite (MaRS) process maps.

Table A.1: Application management stage descriptions

Note a: Applications may be prioritised in circumstances where an applicant has a terminal illness, is elderly, or where there are any other contributing factors the delegate considers appropriate to warrant a higher priority (expedited processing is applied). The department’s prioritisation policy (June 2019) allows for three prioritisation levels:

Priority Tier 1 — ‘critical’ — highly time sensitive — for example, applicant’s likely remaining lifespan or extreme vulnerability warrants expedited processing.

Priority Tier 2 — ‘high’ — moderately time sensitive — for example, considering the applicant’s vulnerability or an application received over nine months ago warrants higher priority processing than the standard application. The department’s prioritisation policy does not align with its current (since 2019–20) practice which is that applications received over 12 months ago are afforded a higher priority status. That is, cases that are initially prioritised as ‘normal’ are automatically reprioritised to ‘high’ in Case Manager after twelve months.

Priority Tier 3 — ‘normal’ — standard time sensitivity — standard processing

The department’s prioritisation policy (June 2019) states that Priority Tier 1 and Priority Tier 2 applications are treated as urgent under the Act. See Table note b.

Cases initially prioritised as ‘normal’ are automatically reprioritised to ‘high’ in Case Manager after twelve months. In March 2025, the department advised the ANAO that it was revising its documented prioritisation policy and associated guidance material.

Note b: The National Redress Scheme for Institutional Child Sexual Abuse Act 2018 (Section 75A and 75B) sets out the department’s powers to request information from applicants (section 24) and institutions (section 25). These powers include legislated minimum timeframes that the department can request that applicants and institutions provide the requested information by (at least four weeks for applications the department considers ‘urgent’, otherwise at least eight weeks). The legislation does not define ‘urgent’. As noted in Table note a, the department’s prioritisation policy (June 2019) states that Priority Tier 1 and Priority Tier 2 applications are treated as urgent under the Act. The legislation allows the department to extend these minimum timeframes. There are no legislated maximum timeframes for any such extensions.

Source: ANAO representation of departmental records.

Appendix 4 Scheme performance measures and targets