Period Products and Facilities (Access) Act 2023

The Act defines and organises a small set of legal concepts that structure rights and duties. These concepts are largely set out in Part 1 and the Dictionary and are used to allocate responsibilities across directorates, education providers, hospitals and approved entities.

• Period poverty: The Act defines period poverty functionally as circumstances, financial, social, cultural or physical, that prevent access when needed to (a) period products, (b) menstrual hygiene information, (c) toilets, (d) handwashing facilities, or (e) sanitary waste facilities (s 7). The definition is broad and non‑exhaustive of causes, linking poverty to barriers across products, information and basic facilities rather than only inability to purchase products.
• Period product: The Dictionary defines period product as a manufactured item designed to absorb or collect menstrual flow and gives examples including menstrual cups, period underwear, sanitary pads and tampons (Dictionary). The definition is product‑centric and excludes non‑manufactured improvised materials; it does not prescribe brand, standard, or medical classification.
• Principles of dignity: Section 6 sets mandatory principles that must be taken into account when exercising a function under the Act. These require recognition that period poverty may arise from economic disadvantage and intersecting identity factors, that not every menstruating person identifies as a woman, and that access should afford reasonable privacy, protection of personal information consistent with the Information Privacy Act 2014, equal access irrespective of identity, and avoidance of humiliation with age-appropriate participation in decision-making (s 6).
• Suitable places list and approved suitable places: The minister must maintain a suitable places list of public places where products are to be made available (s 8). The list must include public places across a range of geographic locations and any approved suitable place (s 8(2)). Entities may apply to have places approved and included on the list; approvals are made by the director-general under approval guidelines and may be conditional (ss 11-12).
• Access arrangements and guidelines: Access arrangements are written arrangements for providing access at a place, and differ by context (public place, government school, other education provider, hospital) (Dictionary; ss 10, 14-15, 18). Approval guidelines and access guidelines are notifiable instruments; access guidelines may be sector specific and can set procedures on privacy and protecting personal information (ss 12, 22).
• Administrative actors: The Act allocates duties to particular administrative actors. Director-general(s) are central: the director-general must ensure supply at suitable places (s 9(1)), make access arrangements for public places and approved places (s 10), approve applications for approval (s 11(2)), make approval guidelines (s 12(1)), ensure supply in hospitals (s 17(1)) and publish information (s 21(1)). The director-general responsible for administering the Education Act 2004 has specific duties for government schools (s 14). Responsible entities for approved suitable places have reporting duties and compliance obligations (s 12(4)-(5)).
• Coverage boundaries: The Act limits workplace obligations to persons involved in territory-funded work or public employees (s 19(1)-(2)); it excludes the home of a territory worker as a workplace (s 19). Hospitals are explicitly defined for Division 2.3 as public hospitals or public day hospitals and include a health facility prescribed by regulation, and public hospitals include approved mental health facilities providing inpatient services (s 16; Dictionary).
• Transparency and review: The Act requires public notice for some access arrangements (government schools and hospitals, ss 14(3), 18(3)), annual reporting by responsible entities for approved places (s 12(4)) and an annual statement in the directorate’s annual report (s 23). The Minister must review the Act’s operation at least every three years and present the review to the Legislative Assembly (s 24).

These concepts structure where duties attach, what counts as the statutory target (products, facilities, information), and the administrative instruments to implement the policy. The notifiable instrument treatment for the suitable places list and guidelines means the detailed operational settings are delegated to subordinate instruments, not detailed in the primary Act (ss 8(3), 12(3), 22(4)).

The Act allocates duties and imposes obligations on a defined set of public entities and private-ish entities seeking approval. It also creates rights of access for individuals experiencing period poverty. The principal affected parties are:

• Director-generals of ACT directorates: Multiple director-generals have express duties. The director-general with administrative responsibility for a public place on the suitable places list must create written access arrangements (s 10(1)). The director-general must also ensure period products are made available at each place on the suitable places list (s 9(1)). The director-general responsible for administering the Health Act 1993 must ensure products are provided on hospital premises and must make and publicly notify hospital access arrangements (ss 17-18). The director-general responsible for the Education Act 2004 must make access arrangements for government school premises and give public notice (s 14). The Act therefore distributes implementation duties across different directorates.
• Education providers: All education providers (as defined in Dictionary) must ensure period products are available on their premises for students experiencing period poverty and must comply with access arrangements (s 13). This includes government schools (with additional procedural requirements) and other registered providers such as registered training organisations and higher education providers, and any entity prescribed by regulation (Dictionary).
• Responsible entities for approved suitable places: Any entity approved to add a place to the suitable places list must comply with the access arrangements and report annually on compliance when requested by the director-general (ss 11(3), 12(4)-(5)). These entities initiate an application to be on the suitable places list and carry ongoing compliance obligations.
• Hospitals and hospital administrators: The director-general responsible for the Health Act must ensure supply at hospital premises for patients and visitors experiencing period poverty and must make and publish access arrangements for hospitals (ss 17-18). Hospitals that are prescribed health facilities (Dictionary) fall within the definition for Division 2.3.
• People experiencing period poverty, including students, patients, visitors and community members: The Act creates an express entitlement that period products be made available free of charge for use by people experiencing period poverty at suitable places, education premises and hospital premises (ss 9(1), 13(1), 17(1)). It also entitles workers in territory-funded work and public employees to access toilets, handwashing and sanitary waste facilities consistent with dignity principles (s 20).
• Employers and contractors involved in territory-funded work and public sector employers: Section 20 imposes workplace facility access duties in relation to territory-funded work and public employees. The Act cross-references the Government Procurement Act 2001 for the meaning of territory-funded work (s 19; Dictionary). The duty is to provide access to facilities consistent with the Act, dignity principles and any access guidelines (s 20(2)).
• The Minister and the Executive: The Minister must maintain the suitable places list (s 8(1)), review the Act every three years and present the report to the Legislative Assembly (s 24). The Executive may make regulations under s 25. The director-general must make approval and access guidelines and include statements about the Act’s operation in annual reports (ss 12, 22, 23).
• Communities and service providers: Community facilities, libraries and health centres are given as examples of suitable places (s 8(2) Examples). Entities that provide services to people likely to experience period poverty may apply to be approved suitable places and thereby carry compliance duties if approved (s 11(1)).

Who pays is not explicit in the Act. The director-general must ensure provision at public places on the suitable places list (s 9(1)), suggesting government budgets will meet the cost at public places, but for approved suitable places the Act places compliance and reporting duties on the responsible entity without specifying funding arrangements (s 9(3), s 11(3)-(4)). This creates implementation choices about whether government or responsible entities budget for product procurement, stocking, maintenance and disposal, to be resolved in practice through guidelines, administrative policy and possibly regulations (s 25, ss 12 and 22 notifiable instruments).

The Act creates a set of affirmative duties for administrative actors and education providers and corresponding entitlements for individuals experiencing period poverty. The duties are primarily administrative and process‑focused, with some core supply obligations.

Duties requiring provision of period products and facilities

• Director-general obligations for public places: The director-general must ensure period products are made available free of charge at each place on the suitable places list (s 9(1)). The director-general must also make written access arrangements for public places on the list (s 10(1)). When making products available the director-general must comply with the access arrangements (s 9(2)).
• Education provider supply duties: Every education provider must ensure period products are available free on the provider’s premises for students experiencing period poverty (s 13(1)). They must comply with access arrangements for their premises (s 13(2)).
• Hospital supply duties: The director-general administering the Health Act 1993 must ensure period products are available free on hospital premises for patients and visitors experiencing period poverty (s 17(1)). They must also make written access arrangements for hospitals and publicly notify them (s 18).
• Workplace facilities duties: Persons working in territory-funded work and public employees must have access to toilets, handwashing and sanitary waste facilities in a manner consistent with the Act’s object, dignity principles and access guidelines (s 20).

Duties about procedural arrangements, guidelines and approvals

• Suitable places list and approvals: The Minister must maintain the suitable places list (s 8); entities may apply to have places approved (s 11). The director-general may approve places if applications meet approval guidelines and are likely to improve access (s 11(2)). Approvals may be conditioned and responsible entities must report on compliance annually or on request (ss 11(3)-(4), 12(4)).
• Access and approval guidelines: The director-general must make approval guidelines for applying and approving places (s 12(1)). The director-general may make access guidelines setting out how to respect dignity when implementing obligations under the Act (s 22(1)). Both guidelines are notifiable instruments (s 12(3), s 22(4)).
• Written access arrangements: For public places, approved suitable places, government schools, other education providers and hospitals, the Act requires written access arrangements that are consistent with dignity principles and that provide for how a person accesses products in a way that respects dignity and for a reasonable range of products (ss 10(3), 14(2), 15(3), 18(2)).

Rights and protections for individuals

• Right to free products when experiencing period poverty: Persons experiencing period poverty have a statutory entitlement to free access to period products at suitable places, on education premises, and on hospital premises (ss 9(1), 13(1), 17(1)). The Act requires that access be provided in ways that respect dignity (ss 6, 10(3), 14(2), 15(3), 18(2)).
• Privacy and information protection: The Act requires that personal information of people accessing products be protected in a way that complies with the Information Privacy Act 2014 (s 6(c)(ii); s 22(3)(c) specifically allows procedures for protecting personal information).
• Information access: The director-general must ensure that information about menstruation is available online and in hard copy and in languages used by people at risk of period poverty, and that age-appropriate information is provided (s 21).

Administrative enforcement mechanisms and remedial powers

• Removal power for approved places: The director-general may remove an approved suitable place from the suitable places list if the responsible entity is not complying with access arrangements or any condition of approval (s 11(5)).
• Reporting obligations and oversight: Responsible entities must report on compliance; directorates must include statements about the Act’s operation in annual reports; the Minister must review the Act every three years and present a report to the Legislative Assembly (ss 12(4), 23-24). These mechanisms create administrative visibility and political oversight as the principal accountability levers.

Notably absent in the Act text are explicit sanctioning provisions such as civil penalties or criminal offences attached to non-compliance with many duties. The Act relies on administrative compliance tools (reporting, removal of approval, public notice, review and the political/accountability process). The front matter notes penalty unit values applicable under the Legislation Act 2001 at the republication date, but the Act contains no express penalty sections tied to non-compliance.

The Act structures enforcement primarily through administrative obligations, reporting, removal of approvals and transparency obligations rather than through specified fines or criminal sanctions in the body of the statute. Key enforcement and penalty-related features are:

• Administrative removal power for approved places: The director-general may remove an approved suitable place from the suitable places list if the responsible entity is not complying with access arrangements or a condition of approval (s 11(5)). This is an operational sanction that removes the place from the formal list and thereby relieves the statutory supply obligations associated with inclusion on that list for the entity.
• Reporting and transparency obligations: Responsible entities for approved suitable places must report on compliance with access arrangements each year or when requested (s 12(4)). The director-general must include a statement about the Act’s operation in the directorate’s annual report (s 23). The Minister must conduct and present a triennial review (s 24). These requirements are enforcement by visibility, enabling administrative remediation and parliamentary oversight rather than financial penalties.
• No express fines or criminal offences in the Act: The Act does not create specific offences or civil penalties for failure to provide products, to prepare access arrangements, or to comply with guidelines. The republication front matter records penalty unit values for general reference , $160 for an individual and $810 for a corporation as the penalty unit value at the republication date under the Legislation Act 2001 , but there is no internal cross-reference in the Act that attaches penalty units to specific contraventions (front matter note; see Legislation Act 2001, s 133 as cited in the republication header). Consequently, non-compliance triggers administrative remedies rather than statutory monetary penalties as written.
• Administrative discretion and delegated instruments: The Act gives the director-general the power to make approval guidelines and access guidelines (ss 12, 22), and makes the suitable places list a notifiable instrument (s 8(3)). This delegation means compliance standards, eligibility criteria, application processes and sector-specific procedures are set in subordinate instruments which themselves are subject to the notifiable instrument regime (including potential disallowance procedures where relevant). Enforcement therefore depends on the content and enforceability of those subordinate instruments.
• Interaction with other administrative regimes: The Act requires personal information to be protected in compliance with the Information Privacy Act 2014 (s 6(c)(ii)). Breaches of privacy obligations could attract remedies under that Act or the Information Privacy framework. Workplace facility obligations are tied to territory-funded work definitions in the Government Procurement Act 2001 (s 19; Dictionary), potentially bringing procurement and contract compliance consequences in that sphere.
• Practical enforcement levers: In practice, enforcement will likely occur through administrative follow-up, public reporting, conditions attached to approvals, withdrawal of approvals for non-compliant entities, political scrutiny via annual reporting and the triennial review, and any contractual remedies in territory-funded work arrangements. The Act expressly contemplates public notice for access arrangements in government schools and hospitals (ss 14(3), 18(3)), which also creates reputational and political enforcement pressure.

Implementation therefore relies on administrative governance, subordinate instruments, reporting obligations and the political process. The Act does not create a scheme of statutory fines or criminal sanctions for breach of its supply obligations, so enforcement is institutional and administrative in form rather than punitive under this primary statute.

The Act cross-references and operates alongside multiple existing statutory regimes and administrative instruments. These interactions determine definitions, standards of privacy, procurement boundaries, reporting obligations and review/oversight mechanisms.

• Legislation Act 2001: The Act relies on the Legislation Act for drafting conventions, definitions and the notifiable instrument regime. The dictionary notes that definitions in the Legislation Act (for example director-general, entity, Executive, Minister, public employee, public notice, Speaker) are relevant (Dictionary). The suitable places list and guidelines are notifiable instruments (ss 8(3), 12(3), 22(4)), meaning they are published under the Legislation Act regimes and potentially subject to procedural controls.
• Information Privacy Act 2014: The Act requires that a person’s personal information be protected in a way that complies with the Information Privacy Act 2014 (s 6(c)(ii)). Access guidelines may specify procedures for protecting personal information (s 22(3)(c)). This means agencies must align operational privacy practices for distribution and any data collection with the IPA 2014 obligations, and privacy complaints or remedies would proceed under that statutory framework.
• Education Act 2004: The director-general responsible for administering the Education Act 2004 has specific duties to make written access arrangements for government schools and to give public notice of those arrangements (s 14). The Act’s duties for education providers also interact with registration, governance and funding obligations under the Education Act and any sectoral regulatory instruments. The Dictionary definition of education provider imports other Commonwealth Acts for registered training organisations and higher education providers (Dictionary).
• Health Act 1993 and Mental Health Act 2015: Division 2.3 cross-references the Health Act 1993 for the definition of health facility and makes hospital coverage explicit for public hospitals and public day hospitals and includes an approved mental health facility that provides inpatient services (ss 16-17; Dictionary). The director-general responsible for the Health Act must make access arrangements for hospitals and give public notice (s 18). This embeds the duties into the administrative structure governing health services and their operational policies.
• Government Procurement Act 2001: Part 3 workplace obligations refer to the concept of territory-funded work and direct readers to the Government Procurement Act 2001, s 22F for the meaning (s 19; Dictionary). This links workplace facility duties to procurement contracts and territory-funded projects and may affect obligations negotiated into procurement contracts and the responsibilities of contractors and public employees.
• Annual Reports (Government Agencies) Act 2004: The director-general must include a statement about the Act’s operation in the directorate’s annual report under the Annual Reports (Government Agencies) Act 2004 (s 23). This creates an accountability pathway through existing annual reporting frameworks.
• Regulations and subordinate instruments: The Executive may make regulations for the Act (s 25). The Act relies heavily on subordinate instruments: the suitable places list, approval guidelines and access guidelines are notifiable instruments (ss 8(3), 12(3), 22(4)). These instruments will determine operational detail and their legal validity, content boundaries and procedural controls will be governed by the Legislation Act and regulatory policies.
• Privacy and anti-discrimination frameworks: While not explicitly cross-referenced beyond the Information Privacy Act 2014, the dignity principles (s 6) require non-assumptive approaches to gender identity and to aspects of identity that may intersect with period poverty. This will interact practically with anti-discrimination frameworks and policies in service delivery and education settings. Practitioners should align access arrangements with equal opportunity and anti-discrimination legal obligations where applicable.

The Act therefore does not operate in isolation. Its implementation relies on established administrative, procurement, education and health statutory frameworks. The Act delegates operational detail to notifiable instruments and uses existing reporting and privacy regimes to enforce information protection and transparency. Agencies implementing the Act must align access arrangements and guidelines with these other statutes to avoid conflict and to ensure coherent administrative practice.

The republished Act includes a short amendment history in its endnotes and commencement record. The salient legislative milestones and amendments recorded in the republication are:

• Original enactment and commencement: The Period Products and Facilities (Access) Act 2023 was notified on the legislation register on 23 June 2023 (A2023-22). Sections 1 and 2 commenced 23 June 2023 under Legislation Act s 75(1). The remainder of the Act commenced on 23 December 2023 (s 2 and Legislation Act s 79), as recorded in the legislation history (Endnotes, Legislation history).
• Amendment by Statute Law Amendment Act 2025: The Act was amended by the Statute Law Amendment Act 2025 (A2025-29). That amending Act was notified on the legislation register on 6 November 2025. Sections 1 and 2 of that amending Act commenced 6 November 2025 (Legislation Act s 75(1)), and Schedule 3 Part 3.66 of the amending Act commenced 26 November 2025 by the commencement provisions of the amending Act (Legislation history, endnote 3).
• Specific textual amendments noted in endnotes: The amendment history notes that section 2 was omitted (s 2 om LA s 89(4)) and that the Dictionary was amended by A2025-29 amdt 3.223 (Endnotes, Amendment history). The republished law indicates editorial and formal changes consistent with the Legislation Act part 11.3, and those editorial changes are shown as authorised republication updates where applicable.
• Republication history: The republished law provided is Republication No 2, effective 26 November 2025. The earlier republication R1 had effective date 23 December 2023 covering the new Act (Endnotes 5).

Practitioners should consult the legislation register for the full text of the amending instrument A2025-29 and any uncommenced amendments or modifications. The Act’s notifiable instruments (approval guidelines and access guidelines) and the suitable places list are instruments that may be amended more frequently; the Act allows those to be changed by the responsible director-general and minister, and these changes will be recorded separately on the register under the notifiable instrument regime (ss 8(3), 12(3), 22(4)). The Endnotes refer readers to the legislation history and amendment history for details.

Given the statutory reliance on subordinate instruments, many operational changes affecting implementation are likely to occur through those instruments and through administrative policies rather than through primary legislation amendments. Therefore, tracking updates to the notifiable instruments and any regulations made under s 25 is necessary for current compliance obligations and procedural detail.

The republished Act and its endnotes contain no references to judicial decisions, regulatory determinations, or litigation specifically arising under this Act. The Act itself does not name any cases. The endnotes provide the act's legislative and amendment history but do not record any court or tribunal proceedings (Endnotes 3-5).

Because the Act directly imposes administrative duties and leaves enforcement to administrative and reporting mechanisms rather than statutory penalties, the avenues for litigation would likely arise in two broad areas, if disputes were to occur:

• Administrative law challenges: Actions by an applicant, an approved entity or an administrative actor could generate judicial review proceedings under administrative law principles, for example on grounds of unreasonable exercise of discretion by a director-general (such as in approving or removing a suitable place), or procedural fairness in approvals and removals, or on validity grounds of subordinate instruments (approval and access guidelines, and the suitable places list). The Act’s delegation of operational detail to notifiable instruments means courts could be asked to review the legality of those instruments or specific administrative decisions under the Administrative Decisions (Judicial Review) Act 1977 or relevant ACT administrative law principles.
• Statutory interpretation or compliance disputes: If an education provider, hospital or responsible entity were to contest whether they fall within the Act’s definitions, whether they have complied with access arrangements, or who should bear costs of provision, those disputes could generate civil litigation. Similarly, privacy complaints under the Information Privacy Act 2014 arising from implementation of this Act might lead to tribunal or court proceedings concerning privacy compliance.

As of the republication date there is no recorded case law arising from this Act shown in the republished text. Practitioners seeking litigation precedents or case law should check the ACT court and tribunal databases and legal reporting services for any matters brought after the republication date. The Act’s emphasis on administrative and reporting controls suggests the more probable early litigation uses would be judicial review of administrative decisions or challenges to subordinate instruments rather than high-volume private enforcement claims, but that is an observation about probable litigation vectors rather than a record of existing cases.

The Act leaves several key operational and legal questions open and contains drafting features that produce practical compliance and implementation risks. These issues are important for lawyers, procurement officers, school administrators and hospital managers.

1. Funding ambiguity for approved suitable places and public places

• The Act mandates that the director-general ensure period products are made available at each place on the suitable places list (s 9(1)), which suggests government-funded supply for places owned or administered by the relevant directorate. However, for approved suitable places the responsible entity must comply with access arrangements (s 9(3)) and report annually (s 12(4)), while nothing in the primary text sets out who pays for products in approved places. Implementation will require administrative policy or regulation to allocate procurement, stocking and waste disposal costs. Absent explicit funding paths, responsible entities could face unbudgeted operational costs or disputes with the directorate.

2. No express monetary penalties or criminal sanctions

• The Act relies on removal of approvals and reporting rather than statutory fines for non-compliance (ss 11(5), 12(4)). The absence of explicit penalties may limit enforcement options or shift reliance onto political and reputational pressures. If agencies expect statutory penalties to back compliance, they will need to develop administrative levers instead.

3. Product scope is limited to manufactured items

• The definition of period product is confined to manufactured items designed to absorb or collect menstrual flow (Dictionary). That excludes improvised or non‑manufactured materials that some people may use. The definition also does not specify quality, medical standards or environmental requirements for products, which could create procurement disputes about acceptable product ranges in the "reasonable range" requirement of access arrangements (s 10(3)(b)).

4. "Reasonable range" and "reasonable amount of privacy" undefined

• The Act repeatedly mandates a "reasonable range" of products and a "reasonable amount of privacy" (ss 10(3)(b)(ii), 14(2)(b), 15(3)(b), 18(2)(b); s 6(c)(i)). These are normative terms left to access guidelines and administrative practice. Absent clear standards in the access guidelines, disputes could arise over sufficiency of product types, quantities and privacy arrangements.

5. Different procedural treatments create potential inequities

• Government schools and hospitals require public notice of access arrangements (ss 14(3), 18(3)), whereas other education providers must merely make arrangements available to students (s 15(4)). Approved suitable places must report annually to the director-general (s 12(4)). The differing publicity and transparency requirements could produce uneven public awareness and inconsistent practical access across contexts.

6. Workplace scope limited and home excluded

• The workplace duties under Part 3 apply only to persons working in territory-funded work or who are public employees (s 19(1); s 20). The Act explicitly excludes the home of a territory worker as a workplace (s 19). This leaves large segments of private-sector workplaces and remote/home workers outside the statutory workplace facility duties, which could reduce practical access for employees outside the public/tender sphere.

7. Interaction with privacy and identity obligations

• The dignity principles require compliance with Information Privacy Act 2014 when protecting personal information and recognise diversity of identity (s 6). But the Act does not specify data practices. Access arrangements and guidelines must be drafted carefully to avoid privacy breaches or indirect discrimination; the Act authorises access guidelines to state procedures for protecting personal information (s 22(3)(c)), but until those guidelines are made, agencies lack statutory operational detail.

8. Operational supply chain, stocking and waste management omitted

• The Act requires sanitary waste facilities but does not specify waste handling, frequency of restocking, maintenance responsibilities or operational thresholds for vandalism or theft. These practical elements will need resolution through subordinate instruments and operational policies; failure to do so will create logistical deficits.

9. Reliance on subordinate instruments and director-general discretion

• The Act delegates much operational detail to approval and access guidelines and the suitable places list as notifiable instruments (ss 8(3), 12(3), 22(4)). The quality and content of those instruments will shape compliance burdens, eligibility criteria and the practical experience of users. Director-general discretion in approvals contains potential for procedural fairness disputes unless clear criteria and processes are published.

10. Reporting and oversight cadence may be slow

• The Minister must review the Act every three years (s 24), and responsible entities report annually (s 12(4)). If implementation problems are identified, the triennial review cycle may delay statutory-level reform. Annual reporting may identify issues, but remedial change via subordinate instruments or departmental policy could still be necessary and may not require legislative amendment.

These "gotchas" are concrete operational and legal gaps and tensions in the Act as drafted. They point to the areas where agencies must develop clear subordinate instruments, budgetary allocations and inter-departmental coordination to turn statutory intentions into consistent on-the-ground access.

This section provides a practical compliance checklist tailored to the principal actors named in the Act: relevant director-generals and directorates, education providers (government and non-government), responsible entities for approved suitable places, hospital administrators, and employers/contracting officers engaged in territory-funded work. Each item cites the statutory provision that creates the duty.

For director-generals and ministries (general)

• Maintain the suitable places list as a notifiable instrument and ensure geographic coverage to provide reasonable access (s 8(1)-(2), s 8(3)). Draft procedures for adding and removing places and resolve intra‑directorate responsibilities where multiple director-generals might have administrative responsibility.
• Ensure that for each public place on the suitable places list there are written access arrangements consistent with the principles of dignity and providing a reasonable range of products and respectful access procedures (s 10(1), s 10(3)).
• Draft and publish approval guidelines for approved suitable places. Address eligibility criteria, application forms, decision criteria, length of approval and any conditions that may be imposed (s 12(1)-(2)). Publish the guidelines as a notifiable instrument (s 12(3)).
• Prepare access guidelines detailing how obligations should be implemented to respect dignity, including sectoral procedures, privacy protocols and guidance on "reasonable amount of privacy" and "reasonable range of products" (s 22(1)-(3)). Make these guidelines a notifiable instrument (s 22(4)).
• Incorporate privacy compliance checks into access arrangements and guidelines, ensuring adherence to the Information Privacy Act 2014 as required by s 6(c)(ii) and s 22(3)(c).
• Include a statement about the Act’s operation in the directorate’s annual report under the Annual Reports (Government Agencies) Act 2004 (s 23).

For director-general responsible for Education Act 2004 (government schools)

• Make written access arrangements for government schools consistent with the dignity principles, specifying how students access products respectfully and the reasonable range of products available (s 14(1)-(2)).
• Give public notice of access arrangements for government schools (s 14(3)).
• Coordinate with school administrations on stocking, procurement, supply frequency, waste facilities and privacy measures.

For other education providers (registered training organisations, higher education providers and regulated entities)

• Ensure written access arrangements exist that comply with the principles of dignity and provide respectful access and a reasonable product range (s 15(2)-(3)).
• Make the arrangements available to students (s 15(4)).
• Consider aligning procurement and stock management with government access guidelines to ensure consistency and to benefit from any centralised purchasing arrangements.

For hospitals and health services

• The director-general responsible for the Health Act 1993 must make written access arrangements for hospitals and publicly notify them (s 18(1)-(3)). Hospital administrators should ensure in-ward and visitor access to products, sanitary waste facilities and handwashing infrastructure in compliance with these arrangements.
• Ensure the hospital’s waste management and infection-control procedures are integrated with sanitary waste facility obligations (s 17(1), s 18(2)).

For entities applying to be approved suitable places

• Use the approval guidelines to prepare your application, ensuring you meet eligibility criteria including providing services to people likely to experience period poverty and providing those services from the place (s 11(1)(a)-(b); s 12(2)).
• Be prepared to accept conditions of approval and to report annually or on request on compliance with access arrangements (ss 11(3)-(4), 12(4)).
• Consider budgeting for procurement, stocking and sanitary waste management until administrative funding arrangements are clarified.

For employers and contractors in territory-funded work and public employees

• Ensure workplaces for persons working in territory-funded work and public employees provide access to toilets, handwashing and sanitary waste facilities consistent with the Act’s object, dignity principles and access guidelines (s 20(1)-(2)). Ensure that home-based work is not treated as a workplace for these duties if performing territory-funded work (s 19).
• Procurement officers should review Government Procurement Act 2001 contracts to include facility requirements and compliance clauses where territory-funded work is involved, as the Act cross-references territory-funded work definitions (s 19; Dictionary).

Operational and procedural compliance steps (common to all actors)

• Develop standard operating procedures for stocking levels, frequency of replenishment, theft/vandalism contingencies, and waste disposal. The Act requires sanitary waste facilities but leaves operational detail to guidelines; agencies should set standards in their access arrangements and guidelines (s 10(3)(b); s 18(2)(b)).
• Protect personal information: Implement procedures consistent with the Information Privacy Act 2014 for any records, usage data or reporting that involve personal information of people accessing products (s 6(c)(ii); s 22(3)(c)).
• Provide multi‑lingual and age-appropriate information: Ensure that the information about menstruation published online and in hard copy is available in languages used by people at risk of period poverty and includes age‑appropriate materials (s 21(1)-(2)).
• Visibility and communication: For government schools and hospitals, publish access arrangements publicly (ss 14(3), 18(3)). For other providers, ensure students and visitors can readily find and access the arrangements (s 15(4)).
• Recordkeeping and reporting: For approved suitable places, prepare annual compliance reports and make them available to the director-general upon request (s 12(4)). Directorates must include statements about the Act in annual reports (s 23).
• Monitor and review: Engage with the triennial statutory review process to report implementation problems and seek regulatory or budgetary solutions; prepare evidence and metrics for the Minister’s review under s 24.

Practical procurement and budget advice

• Because the Act does not prescribe funding mechanics for approved suitable places, agencies should consider centralised procurement frameworks to achieve economies of scale and consistent product quality. The Government Procurement Act 2001 may govern procurement for territory-funded work and agencies should coordinate purchasing accordingly.
• Set minimum product standards and a product range in access guidelines to reduce disputes about what constitutes a "reasonable range" (s 10(3)(b)(ii), s 14(2)(b)(ii), s 15(3)(b)(ii), s 18(2)(b)(ii)).
• Include clear roles for supply, restocking, signage, privacy facilities and sanitary waste servicing in access arrangements to avoid implementation gaps.

By following the statutory text and preparing subordinate instruments and operational policies in line with the Act’s dignity principles, directorates and providers can convert the Act’s obligations into consistent practice. The Act gives administrative tools for compliance but requires active policy choices around funding, procurement, privacy and logistics to achieve the statutory objectives.