Australian Jobs (Australian Industry Participation) Rules 2026

The Rules are ancillary to the Australian Jobs Act 2013, which establishes the AIP plan system. An AIP plan is a document prepared by a project proponent for a major project (typically resource, energy, or infrastructure projects of a certain capital value) that sets out how Australian entities will be given a full, fair and reasonable opportunity to bid for the supply of key goods or services. The plan has three parts: Part A (details about the project and procurement), Part B (obligations for the project phase), and Part C (obligations for the operational phase if the project involves a new relevant facility). The concept of “key goods or services” is central: these are goods or services that the project proponent or operator considers to be of strategic importance or high value, as defined in s 5 of the Act. The Rules do not redefine this term but rely on the Act’s definition. The key conceptual addition in the Rules is the contract category system (section 6(3) and 7(3)). Contracts for acquiring key goods or services are classified into five bands: Category A ($1 million to $5 million), B ($5 million to $25 million), C ($25 million to $100 million), D ($100 million to $500 million), E (over $500 million). This categorisation is used in compliance reports and likely also influences which contracts attract closer scrutiny. Another important concept is the “exception to giving draft AIP plan” under section 5. If a project proponent gives a plan to a State or Territory (presumably under a state industry participation policy), and that plan meets the conditions in section 5, the proponent does not have to give the same draft to the Authority. This creates a dual track: one route through the Commonwealth Authority, another through a state. The conditions are designed to prevent states from favouring local suppliers over suppliers from other states (s 5(3)). Note that the exception does not apply if the plan does not comply; in that case, the draft must go to the Authority. The “preliminary trigger day” is defined in s 41 of the Act as the day on which one of five events occurs (e.g., the project proponent makes a final investment decision, applies for a major Commonwealth licence or approval, or receives Commonwealth financial assistance). The Rules require notification of that day with detailed information (section 9). This notification starts the clock for compliance obligations. The Authority’s functions under section 10 extend beyond the AIP plan system. They include managing funding for Industry Capability Network Limited (ICNL), a company that operates a database of Australian suppliers and provides matching services. The Authority also advises on National Reconstruction Fund Corporation and Future Made in Australia initiatives. This embeds the Rules in a broader industrial policy framework, not just procurement fairness. Finally, the concept of “full, fair and reasonable opportunity” is central but not defined in the Rules; it appears only in the conditions for the state plan exception (s 5(2)). The Act uses the same phrase in s 35(1). The lack of definition means the Authority’s guidance and enforcement practice will shape what this means in practice. The Rules also repeatedly mention “Australian entities”, which likely means entities incorporated in Australia or otherwise meeting the Act’s definition. The reporting requirements (s 6(2)(f)(vi)) require reason-giving if a successful entity was not an Australian entity, implying a default expectation of Australian sourcing.

The Rules directly affect project proponents of major projects that fall within the scope of the Act. These are typically large resource, energy, and infrastructure projects with capital expenditure above a threshold set in the Act (the Rules do not specify that threshold, but it is in the Act). The project proponents are usually corporations that own or operate the project. They bear the primary compliance burden: preparing and maintaining AIP plans, giving compliance reports, and making notifications. Operators of new relevant facilities (operational entities for projects that continue after construction) are also directly affected, with similar reporting obligations (section 7). Procurement entities for the project - the entities responsible for acquiring goods or services - are indirectly affected because the project proponent or operator must take steps to ensure those entities comply with the Act’s objectives and obligations. The Rules require reporting on steps taken towards that end (s 6(2)(c) and 7(2)(c)). Australian entities (suppliers) are the intended beneficiaries. The Act and Rules aim to give them a full, fair and reasonable opportunity to bid. The reporting requirements in the Rules create transparency about whether non-Australian entities win contracts and why, which may help Australian suppliers understand barriers. However, the Rules do not create a right of action for suppliers; enforcement is through the Authority. The Authority itself is affected: the Rules expand its functions (section 10) beyond the core AIP plan system to include representing the Department on industry participation matters, managing ICNL funding, and engaging with the National Reconstruction Fund and Future Made in Australia. This gives the Authority a broader bureaucratic role but also resource implications. State and Territory governments are affected indirectly: section 5 allows them to receive AIP plans from project proponents, and the proponent must notify the Authority when the plan is given and when the state decides on it. This creates a coordination point between Commonwealth and state procurement oversight. Industry Capability Network Limited is affected as a recipient of funding managed by the Authority and as an entity in which the Department holds membership. The Rules do not impose duties on ICNL directly, but the Authority’s role in representing the Department may affect ICNL’s operations. The National Reconstruction Fund Corporation and the Future Made in Australia office are indirectly affected because the Authority is required to engage on their initiatives. Consultants and advisers who assist project proponents with AIP plans and compliance reports are indirectly affected: the detailed information requirements (categories, Australian content percentages, reasons for foreign awards) will increase the cost of compliance and the need for specialist advice. Smaller contractors that supply key goods or services to projects may be affected if they become new entrants to the supply chain (the compliance report asks whether the successful entity is new to the project proponent’s supply chain - s 6(2)(f)(viii) and s 7(2)(f)(viii)). This could be used to measure the policy’s success in broadening the supplier base, but it also imposes a tracking burden on proponents. Finally, all taxpayers are affected in an economic sense: the compliance costs of the Rules are ultimately borne by project proponents, who may pass them through to consumers or reduce investment. The requirement to report Australian content percentages and reasons for foreign awards creates a form of public subsidy for local content that may have trade implications under Australia’s international trade agreements (the Rules do not address this). The Rules do not exempt any industry or region from the reporting requirements; the only exception is for state plans that meet specific conditions.

The Rules create duties and rights by specifying requirements under the Act. The primary duty is on a project proponent who chooses to give a plan to a State or Territory rather than to the Authority: the plan must have the key objective of ensuring Australian entities full, fair and reasonable opportunity to bid (s 5(2)), must not discriminate between suppliers from different states or territories (s 5(3)), and must include arrangements to notify the Authority when the plan is given and when the state decides on it (s 5(4)). If the plan does not comply, the exception does not apply and the proponent must give the draft plan to the Authority under the Act. This creates a duty to choose the right path and to ensure the plan complies. For project proponents required to give compliance reports under s 25(6) of the Act, the Rules impose a duty to accompany the report with the information listed in s 6(2). That includes an update on the project, details of participation by Australian entities, steps taken to achieve the objectives in s 35(1) of the Act, steps taken to fulfil the obligations in s 36(1) of the Act (which relate to procurement entity obligations), and supporting documentation. Critically, the proponent must supply for each key good or service acquired in the reporting period: a description, applicable standards, the procurement entity’s name, the contract category (A-E), the successful bidder’s name and location, a reason if the winner was not an Australian entity, the percentage of Australian content (if any), and whether the successful entity is new to the supply chain. The proponent must also provide details of capability, capacity and competitiveness of Australian entities identified through plan implementation, and cumulative commitment totals (all, Australian, non-Australian) expressed in million dollars. The operator of a new relevant facility has an equivalent duty under s 7(2). The duty to report is ongoing, and the information must be accurate; the proponent or operator bears the cost of collection and verification. The Rules give the proponent or operator a right to choose the categories for key goods or services for the purpose of publishing a statement of expectations, but the categories must be “the most reasonable and appropriate in the context of how the project proponent or operator expects the goods and services to be acquired or supplied” (s 8). This is a defined discretion, not an unfettered one. The note to section 8 warns that different classifications can create different impressions, and the categories must reflect accurately the intention about acquisition or supply. The Authority may assist with choosing appropriate categories (s 8 note). In practice, the proponent has a right to propose categories but may face challenge if the Authority considers them unreasonable. The proponent also has a right (or obligation) to notify the preliminary trigger day under s 41 of the Act, and the Rules specify the information that must accompany that notification (s 9). The proponent must provide basic project details, financial information, the trigger day and the triggering event. The Authority gains additional functions under s 10, including providing advice, representing the Department, managing ICNL funding, and engaging on initiatives. These are not onerous duties on private entities but rather powers and responsibilities of the Authority. However, the Authority’s advice functions create a quasi-duty on the Authority to provide assistance, which may be relevant if a proponent seeks guidance on categories or plan requirements. The Rules also provide a saving transitional right (s 12): if a compliance report was due before the commencement day but not yet given, the old rules (2014) continue to apply. This protects proponents from having to redo reports already prepared under the old framework. Importantly, the Rules do not create any private right of action for Australian suppliers. A supplier who believes they were denied a full, fair and reasonable opportunity cannot sue the proponent directly under the Rules; the enforcement is through the Authority’s mechanisms under the Act. The Rules do not prescribe any right to bid or right to be considered; they only require the plan to have that objective and the report to detail steps taken. This is a significant limitation: the duties are procedural and reporting-based, not substantive rights enforceable by third parties.

The Rules themselves do not specify penalties; they are delegated legislation under the Act, and penalties are in the Act. However, the instrument is critical to enforcement because it defines the compliance obligations. Failure to provide a compliance report containing the required information would likely be a breach of s 25(6) or s 26(3) of the Act. The Act provides for civil penalties and other enforcement mechanisms (injunctions, remedial orders). The Rules amplify the potential for penalty because they impose highly detailed reporting requirements. For example, if a proponent omits the reason why a successful entity was not an Australian entity (s 6(2)(f)(vi)), the report would be incomplete and non-compliant. Similarly, if cumulative commitment totals are not expressed in million dollars, the report would not meet the Rules. The contract categories are defined in million-dollar ranges; using a different classification could be non-compliance. The Authority may reject a report or take enforcement action. Section 10 gives the Authority functions that include providing advice and representing the Department on industry participation matters. That implies the Authority has an active role in monitoring compliance. The Authority can also manage funding for ICNL, which gives it leverage over that entity but not directly over project proponents. The note in section 8 indicates the Authority can assist with category selection, which suggests proactive engagement. The penalty provisions in the Act are not recited in the Rules, but the Rules refer to the Authority’s functions and to the requirement to “ensure that the objectives set out in subsection 35(1) of the Act are achieved” (s 6(2)(c)). If the objectives are not achieved, the report must still detail steps taken; failure to take adequate steps could be a breach of the duty to ensure, but note that “ensure” is a strong word. The Authority may interpret it as an obligation of result, not just effort. The enforcement posture will depend on the Authority’s resources and guidance. The transitional provision (s 12) limits enforcement risk by preserving the old rules for reports due before commencement but not yet given. This prevents retrospective application of the new, more onerous requirements. The Rules do not create any criminal offences; they are civil in nature. The risk of a court order to comply or a civil penalty order is real for proponents who ignore their reporting obligations. The Rules also do not provide for any form of public disclosure of reports; the Act may provide for that separately. In summary, while the Rules do not set penalty amounts, they create a dense network of mandatory information that must be included in reports. Any deviation, even a minor omission (e.g., failing to state the Australian or international standard applied), technically renders the report non-compliant and exposes the proponent to enforcement action. The Authority’s discretion to take action will be crucial in practice.

The Rules are subordinate to the Australian Jobs Act 2013 and must be read consistently with it. They implement specific sections of that Act (ss 17(5)(b), 25(7)(b), 26(4)(b), 36(1)(d), 40(1)(d), 41(3)(b), 68(1)(m)). The Rules do not purport to override or modify the Act. They fill in details left open by the Act. The interaction with state laws is explicit in section 5: the exception for state plans allows a project proponent to give a plan to a State or Territory rather than to the Commonwealth Authority, provided the plan meets certain conditions. That means the Rules effectively create a dual regime: if a project proponent is subject to a state industry participation policy (e.g., in Queensland or Western Australia), they may comply with that policy instead of the Commonwealth’s AIP plan requirement, but only if the state plan meets the Rules’ conditions. If the state plan discriminates between suppliers from different states, the exception does not apply and the proponent must give the plan to the Authority. This is intended to prevent protectionist state policies. The interaction with the National Reconstruction Fund Corporation and the Future Made in Australia agenda is explicit in s 10(f). The Authority is required to engage on the development and delivery of initiatives that focus on improving Australian industry participation, including those two. This links the Rules to broader government spending programs. It may create conflicts of interest or at least tensions: the Authority that assesses AIP plans also is tasked with promoting and funding industry participation through other programs. The Rules do not create firewalls. The reference to Industry Capability Network Limited (ICNL) in s 10(b) and (e) links the Rules to a private company that operates a supplier database. The Authority represents the Department in relation to ICNL membership and manages ICNL’s funding. This gives the Authority leverage over ICNL, which many project proponents use to find suppliers. It also means the Authority is involved in a commercial entity’s operations. The Rules will interact with procurement laws and policies at the Commonwealth and state levels. For example, the Commonwealth Procurement Rules require value for money, but the AIP plan system adds a separate layer of local content requirements. Project proponents must navigate both. The Rules do not mention freedom of information, privacy, or trade secrets, but the compliance reports require disclosure of contract details, including successful bidder names, use of Australian/international standards, and reasons for non-Australian awards. This information will be given to the Authority and may be subject to FOI or public release. Proponents may need to consider confidentiality. International trade agreements (e.g., WTO Government Procurement Agreement, free trade agreements) may limit the extent to which the Commonwealth can require preference for Australian entities. The Rules do not address this. The requirement to give reasons if a successful entity was not an Australian entity (s 6(2)(f)(vi)) could be seen as a discrimination unless justified by objective criteria. Proponents may need to ensure compliance with Australia’s trade obligations. The interaction with competition law is indirect: requiring notification of categories and steps to achieve objectives may reduce the risk of anti-competitive behaviour in procurement, but it could also favour incumbents. The Rules do not create a formal review right for aggrieved suppliers; judicial review under the Administrative Decisions (Judicial Review) Act 1977 may apply to decisions of the Authority. But the Rules themselves are legislative, not decisions. Finally, the transitional provisions (s 12) confirm that the old 2014 Rules continue to apply to reports due before commencement but not yet given. This avoids a gap and protects reliance on the old framework.

The Rules are a new instrument made on 3 March 2026, replacing the Australian Jobs (Australian Industry Participation) Rule 2014. Schedule 1 repeals the 2014 instrument in its entirety. There is no direct amendment history within the 2026 Rules; they are the initial version. However, the 2014 Rule had been in force for over a decade and was likely subject to its own amendments (not listed here). The key change from the 2014 version is the substantial increase in detail for compliance reports. The 2014 Rule (which was relatively short) did not specify contract categories A-E, nor did it require reporting of Australian content percentages, reasons for non-Australian awards, or whether the successful entity was new to the supply chain. The 2026 Rules also expand the Authority’s functions to include explicit engagement with ICNL, the National Reconstruction Fund, and Future Made in Australia. The 2014 Rule did not reference those. The exception provisions in section 5 are new. The notification requirement in section 9 (preliminary trigger day) is also specified in more detail than in 2014. The transitional provisions reflect that the 2026 Rules are a replacement, not an amendment. It is likely that the Authority’s practice under the 2014 Rule revealed weaknesses in data collection, driving the more granular requirements. The instrument is made by the Minister for Industry and Innovation (Tim Ayres), whereas the 2014 Rule was made under a different minister. The authority is the same: s 128 of the Australian Jobs Act 2013. The 2026 Rules also include a schedule (Schedule 1) that repeals the 2014 instrument. This is a clean repeal, not an amendment. The instrument will commence the day after registration, meaning it comes into force quickly, with minimal notice to project proponents regarding the new requirements. The transitional provision for reports due before commencement provides some relief, but reports due after commencement must follow the new rules. Practitioners should compare the new rules to the old 2014 Rule text (which is not provided here but can be found elsewhere) to identify specific changes for compliance planning. The Rules do not include explanatory statements or regulatory impact analysis; those would be separate.

The source (the Rules themselves) contains no reference to any court cases, administrative decisions, or litigation history. As a legislative instrument made in 2026, it has not yet been tested in court. However, the underlying Act (Australian Jobs Act 2013) has been in force for over a decade, and there may have been litigation about AIP plans, compliance reports, or the Authority’s decisions. The Rules create new obligations that could generate disputes. Likely areas of litigation include: the meaning of “full, fair and reasonable opportunity” (s 5(2)), whether a state plan complies with that condition, whether the categories chosen under s 8 are “most reasonable and appropriate”, enforcement action for non-compliant reports, and whether the Authority’s findings on compliance are reviewable. The requirement to give reasons if a successful entity was not an Australian entity (s 6(2)(f)(vi)) could lead to disputes about whether the reason given is adequate or whether it hides discrimination. The contract categories are defined in monetary bands; litigation could arise over correct classification (e.g., whether a contract valued at $1 million exactly falls into Category A or Category B? The text says “$1 million or more but not more than $5 million”, so $1 million is included). The Rules use “million dollars” unqualified, which could raise issues about which dollar (Australian, US?) though likely Australian. The Authority’s expanded functions (s 10) could be challenged as ultra vires if they exceed the scope of s 68(1)(m) of the Act. The Rules note that section 68(1)(m) allows specifying “other functions of the Authority”. The listed functions (advice, representation of Department, managing ICNL funding, engaging on National Reconstruction Fund and Future Made in Australia) may be argued to go beyond the purpose of the Act (which is about Australian industry participation in major projects). A court could be asked to determine whether managing funding for a separate company or engaging on unrelated government initiatives falls within the Act’s contemplation. The Authority’s advice functions (s 10(a)) may also create reliance - if a proponent follows Authority advice and later faces enforcement, estoppel arguments might arise, though unlikely given no clear power to bind. The transitional provision (s 12) could be litigated if a report was partially prepared under old rules but not given, and the proponent argues it should be accepted under old rules. The provision is clear: old rules continue to apply. So litigation is unlikely on that point. In summary, no litigation history is in the source, but several provisions invite judicial interpretation. The Rules impose a high compliance burden with significant discretion, which is a recipe for litigation.

Several provisions in the Rules are easy to overlook or misinterpret. First, the exception for state plans (section 5) requires that the plan must not “give preference to suppliers of goods or services located in one State or Territory over suppliers located in another State or Territory”. This is an anti-discrimination clause, but it does not prohibit preference for Australian suppliers over foreign suppliers. So a state plan can favour Australian suppliers overall, as long as it does not favour one state over another. This may be inconsistent with the “full, fair and reasonable opportunity” for all Australian entities, but it is narrower. Proponents using state plans must check carefully that no provision (even an indirect one, like local content bonuses) creates an interstate preference. Second, the compliance report must include “the percentage of Australian content of the goods or services acquired (if any)”. The “if any” clause appears to cover cases where there is zero Australian content, but the proponent must still state the percentage (0%). But the phrasing “(if any)” is ambiguous: could it mean the requirement only arises if there is some Australian content? That interpretation would be odd in a regime designed to track local content. More likely, the proponent must report the percentage regardless, even if zero. But a literal reading could be exploited to avoid reporting when content is nil. Third, the contract categories in s 6(3) use “more than $5 million but not more than $25 million” etc. This means Category A includes contracts from $1 million to $5 million inclusive; Category B includes contracts above $5 million up to $25 million inclusive. There is a risk of misclassification at boundaries, especially for contracts worth exactly $5 million, $25 million, $100 million, $500 million. The rule says “not more than” for Category A, so $5 million is Category A. For Category B, “more than $5 million but not more than $25 million”, so $5 million+$1 is Category B. Exact boundaries are clear but practitioners need to be precise. Fourth, the requirement to provide “any documentation that supports the information provided” (s 6(2)(e), s 7(2)(e)) is open-ended. Failure to provide supporting docs could render the report incomplete. The proponent must decide what documents are sufficient; the Authority might disagree. Fifth, the Authority’s function of “managing funding for the Industry Capability Network Limited” (s 10(e)) may create a conflict if the Authority also evaluates AIP plans that rely on ICNL services. If the Authority decides to cut funding to ICNL, that could affect plan compliance. The Rules do not address this. Sixth, the notification requirement for the preliminary trigger day (section 9) asks for “the amount (if any) of financial assistance from the Commonwealth, a State or a Territory that the project proponent has received, or will receive, for the project”. The phrase “will receive” creates a forward-looking obligation. If the proponent expects assistance that later does not materialise, the notification would be inaccurate. There is no provision to update the notification. This may expose the proponent to a compliance risk if the actual assistance differs. Seventh, the transitional provision only covers reports due before commencement. If a report is due after commencement, the new rules apply even if the AIP plan was approved under the old rules. This means a proponent with an existing approved AIP plan must now produce compliance reports with much more detail than originally planned. Eighth, the definition of “Act” in s 4 is the Australian Jobs Act 2013. But the Act may be amended; the Rules refer to specific section numbers (e.g., 25(6), 35(1)). If the Act is amended after the Rules, the section numbers may change, creating uncertainty. The Rules do not have a dynamic interpretation clause. Ninth, the contract category thresholds are nominal dollar amounts. There is no indexation for inflation. Over time, more contracts will fall into higher categories as prices rise, increasing the reporting burden. Tenth, the requirement to report “details of capability, capacity and general competitiveness of Australian entities identified through implementation of the plan” (s 6(2)(g), s 7(2)(g)) is vague. What constitutes “details”? Is a summary enough? This gives the Authority wide discretion to ask for more information, creating uncertainty and potential disputes.

Project proponents and operators subject to the Australian Jobs Act 2013 must take several steps to comply with the Rules. First, determine whether the project is a “major project” under the Act with a capital expenditure above the threshold. If so, the proponent must prepare an AIP plan. Before deciding whether to give the draft plan to the Authority or to a State or Territory, the proponent should check if a state industry participation policy applies. If giving to a state, the plan must satisfy the conditions in section 5 of the Rules: the key objective must be that Australian entities have full, fair and reasonable opportunity to bid; the plan must not give preference to suppliers from one state over another; and it must include arrangements to notify the Authority when the plan is given and when the state decides. The proponent should document that the plan meets these conditions and keep records of the notification. Second, once an AIP plan is approved (by the Authority or the state), the proponent must establish systems to collect the information required for compliance reports. This is the most demanding part of the Rules. For each reporting period, the proponent must compile: an update on the project; details of Australian entity participation in key goods or services; steps taken to achieve the objectives in s 35(1) of the Act (full, fair and reasonable opportunity for Australian entities) and to fulfil obligations under s 36(1) (obligations for procurement entities); supporting documentation; and a detailed breakdown of each key good or service acquired. For each acquisition, the proponent must record: a description, applicable Australian or international standards, the procurement entity’s name, the contract category (A-E based on total expenditure), the successful bidder’s name and location, a reason if the successful entity is not an Australian entity, the percentage of Australian content (if any), and whether the successful entity is new to the project’s supply chain. This requires close cooperation with procurement entities and suppliers. The proponent should create a centralised database to capture this data in real time, rather than trying to compile it after the fact. Third, the proponent must also identify Australian entities through implementation of the plan and report on their capability, capacity and competitiveness. This may involve ongoing engagement with suppliers and the Industry Capability Network. Fourth, the proponent must calculate cumulative commitments awarded total, and totals to Australian and non-Australian entities, expressed in million dollars. These are cumulative over the life of the project or facility, not just the reporting period. The proponent must ensure consistent tracking. Fifth, for the notification of preliminary trigger day (if not yet done), the proponent must submit to the Authority the information listed in section 9: names, ABN/ACN, project details, type, estimate of capital expenditure, financial assistance amounts, timeframe, trigger day, and the triggering event. This notification is a one-time requirement but must be accurate. Sixth, the proponent or operator must choose categories for key goods or services for the purpose of publishing a statement of expectations (section 8). The categories must be “most reasonable and appropriate” in the context of how the goods or services will be acquired or supplied. The proponent should document the rationale for the chosen categories and, if uncertain, seek the Authority’s assistance (as noted in section 8). This will help defend the classification if challenged. Seventh, the proponent should review the Authority’s expanded functions (section 10). While these do not impose direct duties on the proponent, the Authority’s role includes providing advice on draft AIP plans and requirements for major government procurements, loans and grants. The proponent may wish to engage early with the Authority to clarify expectations, especially for complex procurements. Eighth, the proponent must ensure compliance with the transitional provisions. If a compliance report was due before commencement but not yet given, the old 2014 Rule applies. The proponent should determine which reports fall into that category and prepare them under the old requirements. For reports due after commencement, the new rules apply. The proponent should not rely on the old forms or formats. Ninth, the proponent should implement a compliance audit process to verify that all information required by sections 6 and 7 is included in each report. Missing details (e.g., the standard applied, the reason for a non-Australian award, the Australian content percentage) will likely render the report non-compliant. The proponent should also retain supporting documentation for each report, as required, and ensure it is readily available for the Authority’s review. Tenth, the proponent should monitor any changes to the Act or the Rules; as a new instrument, the Rules may be amended after experience. Proponents should also consider international trade law implications and seek legal advice if the AIP plan might discriminate against foreign suppliers in a way that breaches Australia’s treaty obligations. The Rules do not require a choice between Australian and foreign suppliers, but the reporting regime incentivises Australian content. In summary, compliance requires significant data collection and system investment. The cost of compliance is substantial and should be factored into project budgets. Proponents should start preparing systems early, especially for the detailed acquisition data and cumulative commitment tracking. Ignorance of the specific requirements will not be a defence; the Authority is likely to enforce the new rules strictly. The best approach is to treat the compliance report as a mandatory, auditable document and allocate resources accordingly.