The inserted Part 4A introduces a set of interlocking legal concepts that determine scope and procedure. The key concepts and how the Bill defines or uses them are:

• Mandatory notifier. This is a role, not solely an individual. For a public authority a mandatory notifier includes the principal officer of that authority, Members of Parliament where the public authority is one referred to in s 5(1)(a) or (b) of the Principal Act, and any person or holder of a position nominated by the public authority under s 32B(1) (s 32A definition and s 32B). The Bill therefore combines specific office-holders and nominated positions.

• Mandatory notification. A “mandatory notification” is a notification made by a mandatory notifier to the Integrity Commission in accordance with s 32C (s 32A definition). The duty attaches to the making of that notification “as soon as practicable” after the suspicion is formed (s 32C(1)).

• Suspected misconduct and suspected serious misconduct. The Bill uses the existing terms “misconduct”, “serious misconduct”, “designated public officer” and “public officer” from the Principal Act. The Bill adds a definition for “offence of a serious nature” to support the concept of serious misconduct, defining it as an offence punishable by imprisonment for 12 months or longer (s 4 insertion). The Bill does not itself restate what constitutes “misconduct” or “serious misconduct”, so those existing Principal Act definitions must be consulted to determine precise scope; however the Part expressly covers suspected misconduct or suspected serious misconduct involving persons who are designated public officers or public officers in the public authority to which the notifier belongs (s 32C(1)).

• Temporal reach. The duty is forward-looking from the commencement day in one respect but has retrospective operational effect in another. A mandatory notifier must notify the Commission of suspicions formed before the commencement day as well as after (s 32C(1)). But the duty does not require notification of matters where proceedings relating to the misconduct were concluded under any Act before commencement (s 32C(2)). Also, notifications must cover conduct that occurred when the person was a designated public officer or public officer, even if they no longer hold that status at the time the notification is made (s 32C(3)).

• Institutional interaction. The Integrity Commission is given a supervisory role over mandatory notifications: it can require reports from public authorities, give advice on investigations, exercise functions and powers under s 8 in relation to misconduct, and assume responsibility for investigations, including directing that a public authority stop investigative actions that would impede the Commission (s 32D). The Commission may also inquire into alleged failures to notify and report alleged non-compliance to bodies with inquiry powers (s 32E). The Commission may also issue guidance on form, content, types of matters, and obligations, and must publish that guidance online (s 32F).

• Administrative design of principal officers list. Schedule 1 is the list of principal officers to which certain nomination rules apply. The Act adds the University of Tasmania Vice‑Chancellor to that Schedule (Schedule 1 amendment, s 7). Section 104 is amended to ensure that legislative amendments to Schedule 1 do not prevent later administrative orders under existing subsections being used to amend or substitute the schedule or columns (s 6, insertion of s 104(4)).

• Sunset. The entire Act is subject to repeal one year after commencement (s 8). That creates a temporary statutory regime unless replaced or extended by subsequent legislation.

These concepts together shift some detection and reporting responsibility onto specified public office-holders and nominated officials, create a written-notification procedure to the Integrity Commission, expand the Commission’s oversight tools for notifications, and build in administrative flexibility over the list of authorities and principal officers that carry notification obligations.

The Act affects a set of institutional actors within Tasmania’s public sector and a subset of persons who hold office in those bodies. The affected actors, as derived from the text, are:

• Public authorities. The duty and nomination obligations apply to public authorities as that term is used in the Principal Act, since Part 4A repeatedly addresses “a public authority” and refers to Schedule 1 as listing principal officers of public authorities (Pt 4A, s 32A definition; s 32B; Schedule 1 amendment). The Bill itself amends Schedule 1 to include the University of Tasmania and its Vice‑Chancellor (s 7). For public authorities not specified in Schedule 1, Pt 4A requires nomination of a mandatory notifier (s 32B(1)).

• Principal officers. The principal officer of a public authority is automatically a mandatory notifier (s 32A definition). Where the principal officer position that would be listed in Schedule 1 is vacant, the public authority must nominate a person or position as mandatory notifier (s 32B(1)). The amended s 104 clarifies administrative pathways for changing Schedule 1 (s 6).

• Members of Parliament, in certain circumstances. If a public authority is one of the categories referred to in s 5(1)(a) or (b) of the Principal Act (those cross-references are in the Principal Act, not reproduced here), every Member of Parliament is included as a mandatory notifier for that public authority (s 32A(b)). The Bill text therefore extends the role to MPs for certain authorities, subject to the terms of s 5(1)(a) and (b).

• Nominated individuals or position-holders. Public authorities that are not in Schedule 1, or where the principal officer position is vacant, must nominate a person or holder of a position as a mandatory notifier and notify the Commission in writing (s 32B(1), (3)). The public authority can revoke or change nominations (s 32B(2), (4)).

• Designated public officers and public officers who are the subject of notifications. The Part requires notification of suspected misconduct or serious misconduct by “designated public officers” and “public officers” who hold office, employment or positions in the public authority (s 32C(1)). It also requires that notifications relate to persons who were in those roles at the time the misconduct occurred, regardless of their status at the time of notification (s 32C(3)).

• The Integrity Commission. The Commission is given a statutory role to receive mandatory notifications, to issue guidelines, to require reports, to provide advice, and to assume investigatory responsibility if it chooses (ss 32D, 32F). The Commission also has the discretion to inquire into and report alleged non-compliance by mandatory notifiers (s 32E).

• Public authorities generally are indirectly affected by obligations to report outcomes of their own investigations to the Commission if they have conducted an internal investigation relating to a matter notified under s 32C (s 32C(5)).

Who pays. The text does not specify new funding or penalties. Practically, public authorities will carry administrative and staff time costs for nominating mandatory notifiers, training, receiving and forwarding notifications, preparing reports when required, and maintaining records, because the statutory duties require actions by the authority and its nominated persons (ss 32B, 32C, 32D(1)(a), 32C(5)). The Integrity Commission will bear the administrative burden of publishing and maintaining guidelines, dealing with notifications, conducting inquiries into non-compliance and potentially assuming investigations (s 32F; ss 32D-32E). The Act itself contains no appropriation clause.

The Act’s sunset and the Commission’s ability to amend or revoke guidance frequently mean affected actors must monitor statutory status and guidance over the one-year life of the Act (s 8; s 32F(2)-(3)).

This Part creates discrete duties for mandatory notifiers, notification procedures for public authorities, and defined powers for the Integrity Commission. The text creates duties in these principal areas:

Duties of mandatory notifiers

• Duty to notify: A mandatory notifier for a public authority must notify the Integrity Commission of any matter or information that the notifier suspects, on reasonable grounds, involves or may involve misconduct or serious misconduct by designated public officers or public officers of that public authority, as soon as practicable after forming the suspicion (s 32C(1)). The obligation attaches to suspicion on reasonable grounds, and the timing is “as soon as practicable”.

• Temporal and retrospective application: The duty applies regardless of whether the suspicion was formed before the Part’s commencement day (s 32C(1)). The duty also covers conduct that occurred while the person was a designated public officer or public officer even if they no longer are when the notification is made (s 32C(3)).

• Exceptions: The notifier is not required to notify if the notifier knows that legal, disciplinary, administrative or investigatory proceedings or actions in relation to the conduct were concluded under any Act before the commencement day (s 32C(2)). This is a narrow exception based on concluded processes prior to commencement.

• Non-derogation of other obligations: The duty is expressed to apply regardless of obligations under any Act or obligations of confidentiality about the alleged misconduct (s 32C(7)). That places a statutory obligation to notify above other statutory or contractual confidentiality obligations insofar as the duty applies.

• Regard to guidelines: Mandatory notifiers must have regard to any guidelines issued by the Commission when making notifications (s 32C(6)). The phrase “have regard to” requires consideration, but different statutory language would be required to make guidelines binding.

Public authority duties

• Nomination: If a public authority is not specified in Schedule 1, or the Schedule 1 principal officer position is vacant, the authority must nominate a person or position as mandatory notifier (s 32B(1)).

• Notification of nominations: After nomination or revocation of nomination, the public authority must notify the Integrity Commission in writing as soon as practicable of the person or position nominated or revoked (s 32B(3)-(4)).

• Reporting outcomes: If a public authority has concluded its own investigation or taken other actions relating to a matter to which a mandatory notification relates, it must, as soon as practicable, notify the Integrity Commission of the outcome (s 32C(5)).

• Cooperation and stopping internal action: If the Commission assumes responsibility for an investigation commenced by a public authority, the public authority must stop its investigation or related actions that may impede the Commission’s investigation if directed to do so by the Commission (s 32D(2)).

Integrity Commission powers and procedural rights

• Receive notifications and exercise powers: The Commission may, having regard to principles in s 9 of the Principal Act, require reports, advise public authorities, and exercise any functions and powers in relation to misconduct conferred on it under s 8 (s 32D(1)). The text thus links mandatory notifications to the Commission’s broader powers.

• Investigatory assumption and direction: The Commission may assume responsibility for a public authority’s investigation and direct the public authority to stop actions that impede that investigation (s 32D(2)).

• Inquiry and reporting on non-compliance: If the Commission believes a mandatory notifier has failed to comply, it may inquire into the non-compliance and report the alleged failure to persons or bodies with power to inquire into that non-compliance (s 32E).

• Guidelines issuance and publication: The Commission may determine, amend, revoke and publish guidelines on form, content, types of matters, and obligations for notifications (s 32F(1)-(3)). The Commission must publish guidelines on its website as soon as practicable after issuing them (s 32F(3)).

Rights implicit in the text

• Procedural rights for public authorities and notifiers are not detailed in terms of appeal or review for Commission directions. The text does not create express appeal rights against a Commission direction that a public authority stop an investigation (s 32D(2)). The Commission’s powers to inquire or to report alleged non-compliance similarly are discretionary; the Bill does not specify procedural safeguards or sanctions in relation to those inquiries (s 32E).

• Mandatory notifiers must “have regard to” guidelines; that is a duty to consider the guidelines rather than a strict duty to follow them in every respect (s 32C(6) and s 32F).

• The statute expressly requires notification notwithstanding statutory or contractual confidentiality obligations (s 32C(7)), narrowing any practical right to maintain confidentiality in the face of this Part.

The Act therefore creates affirmative notification duties, reporting and coordination obligations for public authorities, and broad discretionary powers for the Integrity Commission to manage and, if necessary, assume responsibility for investigations arising from notifications.

The Bill does not create new criminal offences, monetary fines, or express administrative penalties for failure to comply with mandatory notification obligations. Enforcement and compliance mechanisms set out in the text are administrative and discretionary rather than penal. Key enforcement features and limits are:

• Inquiry and referral powers. If the Integrity Commission believes a mandatory notifier has failed to comply with s 32C(1), the Commission may inquire into the alleged non-compliance and may report the alleged non-compliance to a person or body that has the power to inquire into it (s 32E). The Act leaves identification of that person or body to the Commission’s choice and to the existing institutional framework.

• Commission’s investigatory power. The Commission may exercise functions and powers under s 8 in relation to misconduct when dealing with mandatory notifications (s 32D(1)(c)). Those s 8 powers may include investigatory or coercive powers provided in the Principal Act, but the Bill text does not restate them. Where the Commission assumes responsibility for an investigation commenced by a public authority, the public authority must stop its investigation where directed by the Commission (s 32D(2)). The power to assume and to direct internal stopping is an enforcement lever that can curtail duplicate or interfering investigations.

• No express sanctions in the Bill. The text does not specify fines, disciplinary consequences, or criminal liability for failing to make a mandatory notification. It grants the Commission soft enforcement options (inquiry, reporting to other bodies) rather than express sanctions. The absence of statutory penalties means enforcement will depend on the Commission’s use of inquiries and on the willingness of bodies receiving reports to proceed with discipline or other action.

• Oversight and guidance rather than punishment. The Commission’s ability to require reports on actions taken by a public authority, and to provide advice on investigations, points to a regulatory design that prioritises oversight and coordination rather than automatic sanctions (s 32D(1)(a)-(b)).

• Interaction with other bodies. Section 32E expressly contemplates reporting alleged non-compliance to a person or body with power to inquire. The Act does not identify those bodies. In practice, that mechanism could link non-compliance to disciplinary authorities, prosecutorial bodies, or parliamentary oversight bodies, but the Act itself is silent on which bodies are appropriate.

• Guidelines and publication. The Commission’s power to issue and publish guidelines (s 32F) creates a compliance architecture based on guidance and transparency. The statutory obligation for notifiers to “have regard to” guidelines (s 32C(6)) is weaker than an explicit binding requirement but can inform the Commission’s assessment of good faith and procedural compliance in inquiries.

• Temporal limitation. The Act will be repealed one year after its commencement (s 8). That sunset narrows the window for enforcement action under this statutory regime and may affect decisions about whether to commence inquiries or refer matters to other bodies.

In short, enforcement under this Bill is administrative, discretionary and routed through the Commission’s investigatory and reporting powers rather than backed by newly created statutory punitive sanctions. The Commission’s decisions about when and to whom to report alleged non-compliance will determine how the duty is enforced in practice (s 32E).

The Bill explicitly addresses certain interactions with other statutory processes, and it leaves other interactions to the operation of the Principal Act and to administrative practice. The text establishes these concrete interactions:

• Pre-existing proceedings concluded before commencement. The duty to notify does not apply where legal, disciplinary, administrative or investigatory proceedings or actions relating to the misconduct were concluded under any Act before commencement day (s 32C(2)). The Act therefore recognises and defers to conclusively concluded pre-commencement actions.

• Confidentiality obligations. The duty to notify applies “regardless of an obligation on the mandatory notifier - (a) under the provisions of any Act; or (b) to maintain confidentiality about the alleged misconduct or alleged serious misconduct” (s 32C(7)). This is an express statutory override of other statutory or contractual confidentiality obligations insofar as they would otherwise prevent making a mandatory notification. The text therefore requires notifiers to prioritise the s 32C(1) duty even where other law appears to limit disclosure.

• Interaction with public authority investigations. Section 32C(4) requires notification regardless of whether the misconduct has been referred to a public officer, principal officer or public authority for the purposes of any Act. That ensures the statutory duty to notify the Commission is not displaced by internal referral mechanisms. Section 32C(5) requires public authorities that have concluded their own investigations to notify the Commission of the outcome. At the same time, s 32D(2) allows the Commission, where it assumes responsibility, to direct public authorities to stop investigations. The Part therefore creates a two-way interaction: parallel reporting obligations plus a Commission power to centralise investigations.

• Commission’s existing powers. The Commission’s power to exercise functions and powers in relation to misconduct under s 8 of the Principal Act when dealing with mandatory notifications (s 32D(1)(c)) links these new duties to the Commission’s pre-existing statutory toolkit. The precise reach of that interaction depends on the content of s 8 and s 9 of the Principal Act, which are incorporated by reference in the Bill.

• Administrative modification of Schedule 1. Section 104 is amended to state that a legislative amendment to Columns 1 or 2 of Schedule 1 does not prevent those Columns or the Schedule from being later amended, or omitted and substituted, by an order under s 104(1), (2) or (3) (s 6, inserting s 104(4)). That preserves the ability to alter the list of principal officers by order notwithstanding previous legislative change. This interacts with administrative law principles about the making of instruments, and it potentially allows the executive to modify who is a principal officer for the purposes of mandatory notifications without further primary legislation.

• Temporal interaction via sunset. The Act contains an express repeal on the first anniversary of its commencement (s 8). That means this mandatory notification regime will coexist with other laws only for a limited period unless extended. The short statutory life changes the interaction with other laws by making any long-term regulatory design temporary unless further legislative action is taken.

• No explicit provision for privilege or evidentiary treatment. The Bill is silent about how evidence arising from mandatory notifications will be treated in criminal or civil proceedings, about legal professional privilege, and about other statutory immunities. The only textual constraint is that confidentiality obligations do not displace the notification duty (s 32C(7)). The absence of explicit clause on privilege leaves potential legal tensions to be managed when and if they arise.

In sum, the Bill expressly prioritises Commission notification over confidentiality obligations and internal referral processes, defers to pre-commencement concluded proceedings, connects to the Commission’s existing powers under s 8 and its principles in s 9, and allows for administrative alteration of Schedule 1. The sunset clause and silence on evidentiary and privilege consequences leave practical interactions to be resolved in implementation.

The Bill text records the amendments it makes to the Integrity Commission Act 2009 and to Schedule 1 of that Principal Act. The mechanical amendments in the Bill are:

• Short title and commencement. The Act is the Integrity Commission Amendment (Mandatory Notifications) Act 2025 and commences on a day to be proclaimed (ss 1-2).

• Principal Act reference. It specifies that references to the Principal Act mean the Integrity Commission Act 2009 (s 3).

• Definition inserted into s 4(1). Section 4(1) is amended by inserting a definition: “offence of a serious nature, in relation to serious misconduct, means an offence punishable by imprisonment for a term of 12 months or longer” (s 4).

• Insertion of Part 4A. After s 32 of the Principal Act the Bill inserts Part 4A, comprised of ss 32A-32F, establishing definitions, nomination procedures for mandatory notifiers, the substance of the mandatory notification duty, the Integrity Commission’s role, non-compliance handling, and guidelines (s 5, Pt 4A).

• Amendment to s 104. Section 104 of the Principal Act is amended by inserting subsection (4) to clarify that legislative amendments of Column 1 or Column 2 of Schedule 1 do not prevent those Columns or the Schedule being amended, or omitted and substituted, by subsequent order under subsections (1), (2) or (3) (s 6).

• Amendment to Schedule 1. Schedule 1 to the Principal Act is amended by inserting after item 7 in Part 1 a new item 8, identifying the University of Tasmania and specifying the Vice-Chancellor of the University of Tasmania as the principal officer for that item (s 7).

• Repeal. The Act includes a sunset: it is repealed on the first anniversary of the day on which it commences (s 8).

• Parliamentary and administrative metadata. The Bill as presented is Bill 69-V, introduced in the House of Assembly and dated 6 May 2026, brought in by the Minister for Justice, Corrections and Rehabilitation, the Honourable Guy Barnett, and certified by the Clerk of the House, Laura Ross. Those particulars are part of the Bill record in the source text.

The amendment history in the text is therefore self-contained: it shows the addition of a temporary mandatory notification regime, a defined threshold for “offence of a serious nature”, an administrative refinement to Schedule 1 amendment powers, and the discrete inclusion of the University of Tasmania Vice‑Chancellor as a named principal officer. The sunset clause means the amendments revert unless replaced or otherwise extended before the first anniversary of commencement.

The Bill text contains no litigation history. There are no cases, judicial interpretations, or administrative tribunal decisions recorded in the instrument provided. Because the provisions are newly inserted into the Principal Act and the Act contains a one-year sunset (s 8), there is no statutory litigation record to summarise in the source text.

Practitioners should note that, given the absence of precedent in the Bill text, the interpretation and enforcement of the new ss 32A-32F will depend on how the Integrity Commission exercises its new powers and, if disputes arise, on judicial or administrative review of the Commission’s decisions under the Principal Act and the Administrative Decisions (Judicial Review) Act regime. The Bill itself does not create procedural rules for review of Commission directions or inquiries, and it does not specify carved-out judicial review pathways.

This section highlights practical legal and administrative issues that arise directly from the textual provisions, specifying who decides, who pays, what behaviour changes and what risks or compliance frictions the text creates.

Mandatory notification despite confidentiality

• The Act requires mandatory notifiers to notify the Commission “regardless of an obligation on the mandatory notifier … under the provisions of any Act” and regardless of confidentiality obligations (s 32C(7)). That is a concrete legal prioritisation of the notification duty over other statutory or contractual confidentiality obligations. The practical consequence is that a mandatory notifier may be compelled by the Integrity Commission’s statute to disclose information that might otherwise be protected by confidentiality, even where those confidentiality obligations appear in separate legislation. It does not, however, spell out how conflicts with legal professional privilege or court-ordered confidentiality are to be resolved. The absence of carve-outs for privilege or evidence complicates internal legal advice and could create uncertainty for lawyers advising notifiers and authorities.

Retroactive reporting burden and surge risk

• The duty applies to suspicions formed before commencement day (s 32C(1)) but does not apply where proceedings were concluded before commencement (s 32C(2)). The practical effect is a potential surge of notifications on commencement as notifiers surface pre-existing suspicions that had not been the subject of concluded proceedings. Public authorities and the Commission must plan for potentially elevated volumes in a compressed timeframe.

Who decides and control of investigations

• The Integrity Commission may assume responsibility for a public authority’s investigation and may direct the authority to stop actions that would impede the Commission’s investigation (s 32D(2)). That places decision-making power over investigatory primacy with the Commission. Public authorities lose discretion to continue internal action where the Commission intervenes. The Bill does not prescribe criteria or procedural safeguards for the Commission’s assumption of responsibility, nor does it specify appeal routes against such a direction.

Administrative nomination and turnover burden

• Where a public authority is not listed in Schedule 1, or the Schedule 1 principal officer position is vacant, the authority must nominate a person or position and notify the Commission in writing (s 32B(1), (3)). Frequent vacancies or organisational change will require repeated nominations and written notices (s 32B(2)-(4)), creating ongoing administrative workload and the risk of non-compliance if authorities fail to notify the Commission promptly of changes.

No express sanctions, reliance on other bodies

• The Act does not create statutory penalties for failing to notify; enforcement is limited to Commission inquiries and reporting to “a person or body” with inquiry power (s 32E). The Commission’s practical leverage therefore depends on the willingness and capability of other bodies to act on referrals. For mandatory notifiers, the absence of specified penalties alters the incentive structure: compliance may be driven more by reputational and oversight concerns than by direct statutory punishment.

Guidelines are influential but not strictly binding

• Notifiers must “have regard to” any guidelines when making a notification (s 32C(6)), and the Commission may amend or revoke guidelines and must publish them (s 32F). The statutory language creates an expectation that guidelines inform practice, but does not render non-conformance per se unlawful. In an inquiry into non-compliance (s 32E), the Commission can treat departure from guidelines as a factor but must exercise its discretion when deciding to pursue further reporting or inquiry.

Schedule 1 alteration by order

• The amendment to s 104 (inserting s 104(4)) clarifies that legislative changes to Schedule 1 do not prevent administrative orders from later amending or substituting the Schedule. This preserves executive flexibility to alter which authorities and which principal officers are captured, subject to the Principal Act’s existing order-making processes. Those changes can affect who must nominate mandatory notifiers and who is automatically a notifier, potentially altering compliance obligations without primary legislation.

Temporal uncertainty and the sunset

• The Act’s repeal on the first anniversary of commencement (s 8) introduces temporal uncertainty. Authorities must decide how much to invest in new processes and training for a regime that, on the face of the Act, is temporary. The Commission and public authorities must plan for either an extension or a cessation of obligations at the one-year mark, which creates opportunity costs in administrative investment.

Effect on internal reporting structures

• The Act requires notification regardless of whether the matter has been referred internally under any Act or to any public officer (s 32C(4)). That may prompt authorities to revise internal reporting lines to ensure timely external notification, potentially increasing duplication if internal investigations proceed while the Commission is determining whether to assume responsibility.

Who pays

• Public authorities will bear the administrative costs of nominations, notifications, preparing reports as required, and modifying internal procedures (ss 32B, 32C, 32D(1)(a)). The Integrity Commission will bear costs for receiving, triaging and acting on notifications, issuing and maintaining published guidelines, and conducting inquiries into non-compliance (ss 32D, 32E, 32F). The Bill does not appropriate funds, so these costs must be absorbed within existing budgets unless separately funded.

These are concrete operational and legal frictions embedded in the statutory text. They are not speculative policy outcomes; they follow from the specific obedience, reporting, and procedural features the Bill creates (ss 32A-32F; s 4 insertion; s 6; s 7; s 8).

This section sets out practical, source-grounded steps a public authority, principal officer, nominated mandatory notifier, or Member of Parliament (where applicable) should take to meet statutory obligations in Pt 4A, and to reduce legal and administrative risk under the Bill.

1. Identify whether your public authority is in Schedule 1 and who is the principal officer

• Check Schedule 1 of the Principal Act, as amended, to confirm whether the public authority is specified and whether the principal officer role is current (s 32B). Note that the University of Tasmania and its Vice‑Chancellor are expressly added (s 7). Remember s 104(4) as amended means Schedule 1 may be amended by order after legislative change (s 6).

2. Where not specified, or where the principal officer position is vacant, make a prompt nomination

• If your authority is not in Schedule 1, or the Schedule 1 principal officer position is vacant, nominate a person or holder of a position as mandatory notifier under s 32B(1). Notify the Integrity Commission in writing as soon as practicable after making the nomination (s 32B(3)). If you revoke or change a nomination, notify the Commission in writing as soon as practicable (s 32B(2), (4)).

3. Prepare internal procedures for identification, recording and reporting of suspicions

• Create clear internal policies that define how staff should escalate information that may amount to misconduct or serious misconduct so nominated notifiers can form a suspicion on reasonable grounds. The statutory duty requires notification “as soon as practicable” after suspicion is formed (s 32C(1)). Document the date and basis of the reasonable grounds in a contemporaneous record to demonstrate adherence to the statutory standard.

4. Train nominated notifiers and principal officers on the scope and timing of the duty

• Training should cover that the duty applies to suspicions formed both before and after the commencement day (s 32C(1)), but does not apply where proceedings were concluded before commencement (s 32C(2)). Emphasise that suspicions about persons who were public officers or designated public officers at the time of the misconduct must be reported even if those persons no longer hold office at the time of reporting (s 32C(3)). Make clear that confidentiality obligations do not excuse non-compliance (s 32C(7)).

5. Establish a form and process aligned with the Commission’s forthcoming guidelines

• While the Commission may issue guidelines under s 32F, notifiers must have regard to those guidelines when making notifications (s 32C(6)). Monitor the Integrity Commission’s website for published guidelines and align your notification form, content, and internal advice to the guidance as soon as it is published (s 32F(3)). Where guidelines are absent initially, adopt robust internal documentation of reasonable grounds and decision-making.

6. Implement a process for notifying outcomes of internal investigations

• If the authority conducts and concludes an internal investigation into a matter that was or should have been the subject of a mandatory notification, ensure there is a mechanism to notify the Integrity Commission of the outcome “as soon as practicable” (s 32C(5)). Maintain records of communications with the Commission.

7. Prepare for Commission requests for reports and for possible assumption of investigations

• The Commission may require a public authority to provide a report detailing actions the authority is taking or intends to take in relation to a mandatory notification (s 32D(1)(a)). Have a designated point of contact and a template report that can be produced promptly. If the Commission assumes responsibility for an investigation, be prepared to stop the authority’s own investigation or related actions that may impede the Commission, if directed (s 32D(2)). Ensure internal legal counsel are ready to manage the transition and to protect evidence and witness access subject to Commission directions.

8. Manage confidentiality and privilege issues proactively

• Although the Act requires notification regardless of confidentiality obligations (s 32C(7)), consider obtaining legal advice where legal professional privilege or court orders may be implicated. Document legal advice and the statutory obligation to notify to reduce risk. For communications to the Commission, use secure channels specified or approved by the Commission, and preserve records in a manner consistent with internal retention policies.

9. Monitor Schedule 1, Commission guidance, and the Act’s temporal limits

• Keep an administrative watch on any orders or legislative changes to Schedule 1 (s 104(4) as inserted) and on amendments to the Part or the expiry of the Act under the repeal clause (s 8). The one-year repeal requires continuous monitoring to determine whether the regime will be extended, modified, or allowed to lapse.

10. Document compliance decisions and consider escalation criteria

• For every decision not to notify because of s 32C(2) (proceedings concluded before commencement), or because no reasonable grounds exist, keep contemporaneous records stating why the decision was taken and who authorised it. If the Commission later inquires into non-compliance (s 32E), documentation will be central to demonstrating good faith and adherence to the duty to have regard to guidelines (s 32C(6)).

11. Budget for administrative costs and training

• Anticipate the administrative costs of nominations, notifications, reports, staff training, and record-keeping. The Act does not appropriate funds, so these costs must be provisioned from existing budgets, which practical compliance planning should reflect.

12. Coordinate with any overlapping oversight bodies

• Where matters may be reportable to other oversight bodies, create a protocol to ensure mandatory notification to the Integrity Commission occurs promptly and to avoid procedural conflicts. The Commission can report alleged non-compliance to other bodies (s 32E), so proactive coordination will reduce the risk of downstream inquiries.

Following these steps will align an authority and its nominated notifiers with the explicit requirements and mechanisms of Pt 4A, reduce the risk of accidental non-compliance, and place the authority in a position to respond promptly if the Integrity Commission exercises its report or investigatory assumption powers (ss 32A-32F; s 4 insertion; s 6; s 7; s 8).