Linkage Program Grant Guidelines (2024 edition, second edition): Linkage Infrastructure, Equipment and Facilities

This instrument sets out contractual obligations, institutional responsibilities and administrative procedures that apply to ARC grant applications and funded projects as recorded in the Grant Agreement and associated ARC policies. Mechanically it does the following things:

• Requires variations to the Grant Agreement to be submitted in the circumstances set out in the Grant Agreement and makes them subject to ARC approval (Grant agreement variation, para 1).
• Allocates specific duties to named participants, chief investigators (CIs) and partner organisations that the Administering Organisation must certify have been accepted (Responsibilities; Chief Investigator responsibilities; Partner Organisation responsibilities).
• Imposes pre-commencement obligations on projects, namely an ethics plan and a data management plan, and requires compliance with specified research practice instruments including the Australian Code for the Responsible Conduct of Research (2018), ARC conflict, confidentiality and research integrity policies, and the ARC Open Access Policy (Specific research policies and practices, paras 1-6).
• Establishes monitoring and reporting procedures including mandatory reporting through the Research Management System (RMS), notification obligations for changes to name, address, contact and bank details, the possibility of site visits, re-examination of claims and requests for independent audits of claims and payments (Monitoring and reporting, paras 1-3).
• Sets out administrative probity and appeals arrangements that limit appeals to administrative process errors and require appellants to identify the specific guideline or clause alleged to have been misapplied, and to have an appeal authorised by the Administering Organisation’s Deputy Vice-Chancellor (Research) or equivalent (Appeals process, paras 1-3).
• Requires conflict of interest declarations on application and documented conflict management throughout the project, handled according to the Australian Code and ARC policies (Conflict of interest, paras 1-3).
• Establishes privacy and confidentiality rules linked to the Privacy Act 1988, gives the Australian Government the ability to use and disclose confidential information to other Australian Government business or function, and recognises that documents are subject to the Freedom of Information Act 1982 (Privacy and protection of personal information; Confidential information; Freedom of information, paras 1-2).

The document is a behavioural and administrative instrument rather than a standalone piece of primary legislation. It functions by conditioning grant funding and participation on a set of certifiable behaviours and governance arrangements, and by placing reporting and audit risk on recipients and their administering and partner organisations. The text does not specify monetary amounts, eligibility thresholds or the financial mechanics of payments; those matters sit in the Grant Agreement and other ARC instruments referenced in the text (Grant agreement variation, para 1; Partner Organisation responsibilities, para 1).

The instrument organises obligations around a small set of recurring concepts: participant responsibility, institutional certification, compliance with research practice instruments, pre-commencement plans, monitoring and auditability, probity and limited administrative review, conflict management, privacy and confidentiality, and FOI exposure. Each concept operates through contractual or policy levers rather than criminal statute clauses.

Participant responsibility: All named participants must carry significant intellectual responsibility for project conception, conduct and strategic decisions; and must take responsibility for authorship and intellectual content of applications, including appropriate citation and acknowledgement of third-party contributions (Responsibilities, paras 1-2). These are affirmative duties that allocate academic credit and responsibility to named individuals.

Chief Investigator duties: CIs must provide supervision, support and mentoring for research personnel including HDR candidates and postdoctoral researchers and must commit to carrying out the project rather than acting merely as suppliers of resources (Chief Investigator responsibilities, paras 1-2). These clauses create behavioural expectations of leadership and active engagement by CIs and are likely to be used in monitoring and assessment of performance.

Partner organisation certification: Participating organisations must certify to the Administering Organisation their commitment to completing the project, any financial contributions and that they have appropriate governance arrangements (Partner Organisation responsibilities, para 1). This transfers gatekeeping responsibilities to partner organisations and the Administering Organisation for verifying institutional capacity.

Pre-commencement and research integrity instruments: The project must have an ethics plan and a data management plan in place before commencement (Specific research policies and practices, paras 3 and 6). Projects must comply with the Australian Code for the Responsible Conduct of Research (2018), the ARC Conflict of Interest and Confidentiality Policy (2024), the ARC Research Integrity Policy (2023) and the ARC Open Access Policy (2021) as listed (Specific research policies and practices, paras 1-2 and 5). The text also encourages persistent digital identifiers such as ORCID (para 7).

Monitoring and accountability: Recipients must update personal and banking details, submit reports through the RMS, and expect the ARC to assess reports, conduct site visits, re-examine claims and request independent audits (Monitoring and reporting, paras 1-3). The Australian Government will ensure the grant process adheres to published guidelines, includes safeguards against fraud and unlawful activities and is consistent with the Commonwealth Grant Rules and Guidelines and the ARC Act (Probity, para 1).

Primary affected parties are named participants on grant applications, chief investigators, administering organisations, partner organisations, subcontractors engaged by recipients, and the ARC/Australian Government as funder and monitor.

Named participants: The instrument imposes obligations directly on all named participants in an application to take intellectual responsibility for project conception, conduct and authorship (Responsibilities, paras 1-2). This affects academic staff and other researchers listed on applications irrespective of their employing institution; the obligation to appropriately cite and acknowledge third-party contributions creates a compliance duty at the point of application and through project delivery.

Chief Investigators: CIs are individually required to supervise and mentor research personnel, including HDR candidates and postdoctoral researchers, and to commit to active participation in the project rather than merely supplying resources (Chief Investigator responsibilities, paras 1-2). This allocates managerial and supervisory duties to the CI role and may influence workload allocations and performance expectations at universities and research institutes.

Partner organisations: Participating organisations must provide a certification to the Administering Organisation of their commitment, any financial contributions and governance arrangements (Partner Organisation responsibilities, para 1). This shifts part of eligibility and capacity assurance onto partner organisations, which will need internal governance checks and potentially board or executive sign-off before certifying.

Administering Organisation and Deputy Vice-Chancellor (Research): The Administering Organisation acts as the formal contracting party and gatekeeper for appeals, with appeals requiring authorisation by the Administering Organisation’s Deputy Vice-Chancellor (Research) or equivalent (Appeals process, paras 2-3). The Administering Organisation will therefore carry responsibility for internal review and for ensuring that appeals meet the prescribed procedural threshold.

Subcontractors: The applicant must impose the same privacy obligations on any subcontractors and will be held to account for obtaining consent from the ARC before disclosing confidential information (Privacy and protection of personal information, para 2). This creates an upstream compliance responsibility for recipients engaging contractors or consultants.

ARC/Australian Government: The ARC and Australian Government are the decisionmakers for variations and monitors of compliance; they may authorise audits, site visits and re-examination of claims and payments, and possess disclosure rights for confidential information to other Australian Government business or function (Grant agreement variation, para 1; Monitoring and reporting, paras 2-3; Confidential information, para 1).

This section summarises core affirmative duties placed on individuals and organisations and the rights or powers retained by the ARC/Australian Government as set out in the source.

Duties of named participants

• Take significant intellectual responsibility for project conception, conduct and strategic decisions and the communication of results (Responsibilities, para 1).
• Take responsibility for authorship and intellectual content of the application; cite sources and acknowledge significant third-party contributions (Responsibilities, para 2).

Duties of Chief Investigators

• Ensure effective supervision, support and mentoring for research personnel, including HDR candidates and postdoctoral researchers (Chief Investigator responsibilities, para 1).
• Commit to carrying out the project in an active role rather than acting as a supplier of resources for work that will be undertaken largely by others (Chief Investigator responsibilities, para 2).

Duties of Partner Organisations

• Certify to the Administering Organisation commitment to successful completion, any financial contributions and that appropriate governance arrangements are in place (Partner Organisation responsibilities, para 1).

Pre-commencement duties

• Have an ethics plan in place before commencement (Specific research policies and practices, para 3).
• Have a data management plan in place before commencement, consistent with grant agreement and ARC expectations (Specific research policies and practices, para 6).

Compliance duties

• Comply with all relevant laws, regulations and relevant guidelines; comply with the Australian Code for the Responsible Conduct of Research (2018); and adhere to ARC codes and policies listed on the ARC website (Specific research policies and practices, para 1-2).
• Comply with the ARC Open Access Policy on dissemination of findings (Specific research policies and practices, para 5).

Reporting and administrative duties

• Notify the ARC of any changes to name, address, nominated contact details and bank account details (Monitoring and reporting, para 1).
• Submit required reports through RMS unless otherwise advised, including end of year reports, final reports and post-project reporting (Monitoring and reporting, paras 1-2).

The source provides administrative enforcement tools and monitoring powers rather than listing explicit sanctions or criminal penalties in the text provided. Mechanisms and their operational scope are as follows.

Monitoring and audit powers

• The ARC may re-examine claims, seek further information or request an independent audit of claims and payments (Monitoring and reporting, para 2). This gives the ARC the power to commission external verification of financial and performance claims. The clause explicitly ties audits to claims and payments rather than specifying follow-on remedies in case of adverse findings.

• The ARC may conduct site visits and request records to confirm report details (Monitoring and reporting, para 2). Site visits allow verification of project activity, supervision practices and governance arrangements.

Evaluation powers

• The ARC may evaluate projects to measure outcomes and objectives and may contact recipients after grant completion to assist evaluation (Monitoring and reporting, para 2). Evaluation can inform future funding and program design, and feed into administrative follow-up.

Probity assurance

• The Australian Government will make sure the grant opportunity process is fair, incorporate safeguards against fraud, unlawful activities and other inappropriate conduct and be consistent with the Commonwealth Grant Rules and Guidelines and the ARC Act (Probity, para 1). This clause references higher-order instruments which may contain enforcement provisions; however, the text here does not specify the nature or application of penalties under the CGRGs or the ARC Act.

Appeals and procedural remediation

• The instrument limits appeals to errors in the administrative process; it excludes committee decisions, assessor ratings and assessment outcomes from appeal (Appeals process, para 1). The appeals architecture is procedural rather than substantive and requires identification of the specific guideline or clause alleged to have been misapplied and authorisation by the Administering Organisation’s Deputy Vice-Chancellor (Research) (Appeals process, paras 1-3).

Confidentiality and disclosure

• The Australian Government may use and disclose confidential information about applicants and recipients to any other Australian Government business or function (Confidential information, para 1). Disclosure to other government entities is an enforcement-related power because it allows sharing with investigative, regulatory or administrative functions.

The instrument expressly cross-references several statutory and policy instruments and establishes interactions that affect confidentiality, privacy, research conduct, probity and public access. The references in the text create both compliance obligations and boundary conditions where other laws may override confidentiality claims.

Privacy Act 1988 and Australian Privacy Principles

• The instrument requires that the ARC treat personal information in accordance with the Australian Privacy Principles and the Privacy Act 1988; applicants must certify compliance with the Privacy Act including the APPs and must impose equivalent privacy obligations on subcontractors (Privacy and protection of personal information, para 1-2). This places statutory privacy duties on recipients as a condition of application and project participation.

Freedom of Information Act 1982

• Documents in possession of the Australian Government about the Programme are subject to the FOI Act (Freedom of information, para 1). This creates a legal interaction where confidentiality claims may be tested against FOI exemptions and public disclosure rules. The instrument reiterates the presence of the FOI process on the ARC website (Freedom of information, para 2).

Australian Code for the Responsible Conduct of Research (2018)

• The instrument requires compliance with the Australian Code for the Responsible Conduct of Research (2018) and the ARC Conflict of Interest and Confidentiality Policy (2024) and Research Integrity Policy (2023) (Specific research policies and practices, paras 1-2). This links project conduct to disciplinary and ethical standards that may carry their own institutional consequences.

Commonwealth Grant Rules and Guidelines (CGRGs) and ARC Act

• The probity clause references consistency with the CGRGs and the ARC Act (Probity, para 1). The instrument therefore operates within a larger legal and administrative framework governing Commonwealth grants. Enforcement mechanisms, sanctioning powers and administrative procedures not set out here may be found in those instruments.

Intellectual property law and commercial arrangements

• While the instrument states the ARC does not claim ownership of any IP arising from the project and that IP arrangements should be negotiated between the recipient, partner organisations and other organisations (Specific research policies and practices, para 4), this does not displace statutory IP regimes. Parties remain subject to the Copyright Act and patent law generally and must negotiate contractual IP ownership and exploitation rights consistent with those laws.

The supplied text does not contain an explicit amendment history, legislative citations of enactment dates, version control markers or a schedule of changes. It does reference specific versions of ARC policy instruments, which indicates a contemporaneous policy environment:

• Australian Code for the Responsible Conduct of Research (2018) is cited as the relevant Code (Specific research policies and practices, para 2).
• ARC Open Access Policy (2021 version) is cited (Specific research policies and practices, para 5).
• ARC Research Integrity Policy (2023 version) and ARC Conflict of Interest and Confidentiality Policy (2024) are referenced (Specific research policies and practices, para 2).

These references indicate which versions of named policies the instrument intends to bind recipients to, but the document itself contains no record of prior versions, dates of amendments to this instrument, or legislative amendment notes. There is no statement of commencement date, no consolidated text indicating changes over time, and no footnotes or marginal notes describing prior iterations.

For users requiring a definitive amendment history or a chronology of changes to obligations, the text suggests that the authoritative sources for version control will be the ARC website and the Grant Agreement (Grant agreement variation, para 1; Specific research policies and practices, para 2 and related citations). The instrument’s silence means practitioners should check:

• The current Grant Agreement issued to the Administering Organisation for variation rules and commencement clauses (Grant agreement variation, para 1).
• The ARC website pages for the policies cited to confirm whether later versions have been published and whether the instrument has been updated to reference successors (Specific research policies and practices, para 2; Privacy and protection of personal information, para 3; Freedom of information, para 2).

In short, the instrument references living policy documents but does not itself provide an amendment trail or a historical record.

The supplied text contains no litigation history. It does not cite cases, judicial decisions, or administrative review outcomes. There are no references to precedents, dispute outcomes, or interpretations tested in tribunal or court proceedings within the document.

The appeals process described is administrative and capped to procedural errors rather than substantive review of committee decisions or assessor ratings (Appeals process, para 1). The absence of litigation history in this text implies that any legal challenges or case law relevant to these clauses would need to be searched for externally, for example in case law concerning the CGRGs, the ARC Act, FOI decisions, or privacy disputes under the Privacy Act. This document does not supply such material and does not identify prior litigation outcomes that interpret these clauses.

Practitioners seeking litigation context will need to consult:

• Case law and tribunal decisions interpreting FOI and privacy exemptions (relevant to Confidential information and FOI, paras 1-2).
• Administrative law cases on procedural fairness and appeals in grant processes (relevant to Appeals process, para 1).
• Any CGRGs or ARC Act judicial interpretation concerning enforcement, sanctions and grant management (relevant to Probity, para 1).

Because the instrument itself contains no litigation references, the reader should treat the absence of litigation history as a signal to search external legal databases for precedents that might affect interpretation or enforcement of the obligations described.

This section highlights specific practical risk points, friction areas and tensions that arise from the instrument’s provisions as stated. Each point is grounded in the text.

1. Confidentiality is conditional and limited by FOI and government disclosure powers

• Applicants must clearly identify confidential information and explain why it should be treated as such (Confidential information, para 2). However, the Australian Government may use and disclose confidential information to any other Australian Government business or function (Confidential information, para 1) and all documents are subject to the FOI Act (Freedom of information, para 1). Practical effect: a label of "commercial in confidence" does not guarantee non-disclosure; recipients should plan commercial negotiations accordingly and expect possible FOI exposure.

2. You must obtain written consent before disclosing confidential information, but the Government may disclose it internally

• The Privacy section requires applicants to ask for the ARC’s written consent before disclosing confidential information (Privacy and protection of personal information, para 2). At the same time the Government can disclose the information internally without needing the applicant’s consent (Confidential information, para 1). This creates an asymmetry: recipients need ARC consent to disclose, but cannot prevent internal Government sharing.

3. Appeals are strictly limited and procedurally framed

• Appeals cannot challenge committee decisions or assessor evaluations; they are limited to administrative process errors and must identify an incorrectly applied guideline or clause (Appeals process, para 1). Further, appeals require authorisation by the Administering Organisation’s Deputy Vice-Chancellor (Research) (Appeals process, para 2). Practically, applicants cannot use the appeals process to contest scientific judgments, so dissatisfied applicants must focus on procedural errors and secure institutional sign-off to lodge an appeal.

4. Pre-commencement plans are mandatory; failure to have them may affect start dates or compliance

• An ethics plan and a data management plan must be in place before project commencement (Specific research policies and practices, paras 3 and 6). Failure to have these in place risks non-compliance; operationally teams must schedule ethics approvals and DMP development before commencing funded activities.

This section provides a practical, source-grounded checklist and procedural recommendations to meet the obligations set out in the instrument.

1. Prior to application submission

• Ensure all named participants are prepared to accept intellectual responsibility for the project, authorship and acknowledgements (Responsibilities, paras 1-2). Obtain written confirmations or declarations from each named participant documenting these commitments.
• Engage partner organisations early to secure the certification required by the Administering Organisation concerning commitment, financial contributions and governance arrangements (Partner Organisation responsibilities, para 1). Obtain written evidence of internal approvals and financial commitments to accompany certification.

2. Pre-commencement requirements

• Finalise an ethics plan before commencing project activities and have documented ethics approvals where required (Specific research policies and practices, para 3).
• Prepare a data management plan prior to commencement that complies with the grant agreement and ARC expectations; document storage locations, access rules, retention periods and responsibilities for data stewardship (Specific research policies and practices, para 6).

3. Contractual and IP arrangements

• Negotiate and document IP arrangements between the Administering Organisation, partner organisations and any other organisations before exploitation or commercialisation activities commence, noting that the ARC does not claim IP ownership (Specific research policies and practices, para 4).
• Where collaboration involves industry partners or third-party funders, ensure publication and open access obligations under the ARC Open Access Policy (2021) are harmonised with any confidentiality or IP commercialisation agreements (Specific research policies and practices, para 5).

4. Conflict of interest and governance processes

• Prepare and submit conflict of interest declarations for each named individual at the point of application, documenting perceived, potential or existing conflicts; maintain a documented conflict management plan for the duration of the project in line with the Australian Code and ARC policies (Conflict of interest, paras 1-2).
• Ensure institutional governance arrangements are in place to supervise conflicts, publication approvals and intellectual property oversight as part of partner organisation certifications.