Service Victoria (General) Regulations 2018

The Regulations are short and conceptually focused. Their core concepts are delegation and levels of assurance for electronic identity credentials. Each is anchored to provisions of the parent Act as the source of substantive authority.

Levels of assurance: regulation 6 prescribes four labels for levels of assurance in relation to electronic identity credentials: LOA 1 (Basic), LOA 2 (Medium), LOA 3 (High) and LOA 4 (Very High). The Regulations do not attempt to define the substantive content of those levels. Rather, the Notes attached to regulation 6 explicitly cross‑refer to the Act: “level of assurance” is defined in section 3 of the Act as “the degree of confidence that a credential is taken to provide as set out in the identity verification standards made under section 41 of the Act” (reg 6 Note 1). The Regulations also instruct readers to “see Part 6 of the Act regarding electronic identity credentials and levels of assurance” (reg 6 Note 2). The concept therefore operates as a labelling framework; the measurable features and requirements of each LOA are delegated to identity verification standards under s 41 of the Act.

Delegation: regulation 8 operates in the delegation space. It prescribes, “for the purposes of section 52 of the Act,” a class of persons to whom the Service Victoria CEO may delegate functions or powers: persons employed under Part 3 of the Public Administration Act 2004, insofar as their employment relates to the administration of the Act (reg 8). The earlier objectives provision in reg 1(c) mirrored this focus by stating the Regulations’ objective to prescribe persons and classes of persons to whom the Service Victoria CEO may delegate functions or powers (reg 1(c)). Together, reg 1(c) and reg 8 create a statutory mechanism that identifies an employment-based class for delegation; the substantive authority and mechanics of delegation are located in s 52 of the Act.

Other interpretive concept material: the Endnotes bring in the Interpretation of Legislation Act 1984. That material treats headings, examples, diagrams and notes as forming part of the rule (Endnotes, Interpretation of Legislation Act 1984, Headings and Examples), and confirms style changes authorised by ILA s 54A. Those interpretive rules affect how the Regulations’ short notes and headings are to be treated when reading or construing the Statutory Rule.

Sunset: the Regulations are subject to the Subordinate Legislation Act 1994 requirement that instruments made will sunset after 10 years. The Endnotes state the Service Victoria (General) Regulations 2018 will sunset on 26 June 2028 (Endnotes, General information). The concept therefore carries an automatic expiry unless renewed or remade in compliance with the subordinate legislation regime.

Amendment and revocation: the Regulations themselves are a moving instrument. The Table of Amendments and the in-text revocation annotations show that particular subparagraphs and Parts have been removed by subsequent statutory rules (S.R. No. 38/2024 and S.R. No. 140/2024). The concept here is that the Regulations set up a modular set of provisions that can be pruned or adapted by later subordinate instruments; the specific changes are recorded in the Table of Amendments (Endnotes, Table of Amendments).

In short, the main conceptual architecture is minimalist: labels for LOAs, a prescribed delegation class, and cross-references to the parent Act and its standards for substance, with interpretive conventions taken from the ILA and a statutory sunset date imposed under the Subordinate Legislation Act 1994.

The Regulations affect a narrow set of actors, both within public administration and in the broader ecosystem of identity providers and relying parties, but the text identifies these effects mostly by reference.

Service Victoria CEO and delegates: the Regulations directly structure the CEO’s delegation power under section 52 of the Act by prescribing a class of persons who may receive delegations: persons employed under Part 3 of the Public Administration Act 2004 in relation to administration of the Act (reg 8). That means the CEO has an enumerated pool of employees within the Victorian public service who are statutorily eligible to exercise delegated functions or powers. The Regulations therefore primarily affect who within the public sector can lawfully be given delegated authority to act under the Act.

Public servants employed under Part 3 PAA 2004: those employees are explicitly named as the prescribed class for delegation (reg 8). The Regulations thus confer a statutory status on that employment category for the specific purpose of delegations under the Service Victoria Act. The text limits the class to employees “in relation to the administration of the Act,” which narrows the pool to those whose duties relate to Service Victoria functions.

Identity credential ecosystem: the Regulations prescribe LOA 1-4 labels (reg 6). Although the Regulations do not set substantive verification steps, they formalise the nomenclature that identity providers, digital identity services, relying agencies, and third parties will use to describe the assurance level of an electronic identity credential. The labels are therefore systemically relevant to identity credential issuers and relying parties who will need to map their technical and procedural controls to the LOA labels defined in regulation 6, taking substantive content from the identity verification standards under section 41 of the Act (reg 6 Note 1).

Relying agencies and private sector relying parties: while the Regulations do not themselves impose duties on relying parties, the adoption of LOA labels will affect how agencies and private organisations structure trust frameworks and contracts for digital identity. The regulation’s reference to identity verification standards (s 41 of the Act) indicates that the substantive obligations or expectations tied to each LOA will be set in standards made under the Act, and those standards will determine what relying parties must accept or require. The Regulations therefore affect relying parties indirectly by standardising the labels they must recognise under the Act’s regime.

Regulatory and interpretive actors: because the Endnotes incorporate ILA interpretive rules into the Statutory Rule context (for example, headings and notes forming part of the rule), statutory drafters, legal advisers and courts will treat the Regulations’ headings and notes as part of the instrument. That affects interpretation of any provision in litigation or compliance review contexts (Endnotes, Interpretation of Legislation Act 1984).

Persons not covered: the Regulations do not include contractors, volunteers or other non-employees in the prescribed class for delegation. The prescribed class is tied to Part 3 PAA 2004 employment; the text does not extend delegations to persons outside that statutory employment class (reg 8). Likewise, the Regulations do not themselves impose obligations on identity credential holders or specify verification procedures; those matters are delegated to identity verification standards under s 41 of the Act (reg 6 Note 1).

In sum, the Regulations directly affect the internal delegation architecture of Service Victoria and indirectly affect the identity credentialing ecosystem by standardising LOA nomenclature and pointing to the Act’s standards for content. The material consequences for private parties are primarily mediated through the standards and the parent Act rather than through the Regulations themselves.

The Regulations are sparse in prescriptive duties and rights; they mainly allocate labels and designate a class of delegates. What follows is a source‑grounded account of duties, rights and where duties are absent.

Duties created directly by the Regulations: there are no express operative duties on private persons or agencies set out in the Regulations. Regulation 6 prescribes the levels of assurance labels for electronic identity credentials, but does not impose verification processes, record keeping, disclosure obligations, or penalty regimes tied to those labels. Regulation 8 prescribes a class of persons who may receive delegations, but does not itself require the CEO to delegate or set out the content of delegated powers.

Delegation rights and internal administrative duties: the Regulations authorise the CEO’s delegation power by specifying the class of persons eligible to receive delegations for the purposes of s 52 of the Act (reg 8). That operates as a right for the CEO to delegate to that class, and as a statutory permission for persons employed under Part 3 of the Public Administration Act 2004 to be appointed as delegates. The Regulations therefore create a legal pathway for delegation without spelling out the CEO’s duties in making delegations; the substantive duties on delegates (if any) would be set out in the instrument of delegation and in the parent Act’s delegation regime (reg 8 cross‑refers to s 52 of the Act).

Rights of relying parties: the Regulations do not expressly confer enforceable rights on relying parties to demand credentials at a particular LOA. They supply a uniform terminology , LOA 1 to LOA 4 , which functioning as shared labels can be relied upon in contracts, procurement specifications and operational policies. Any legal entitlement to demand or accept a certain LOA will depend on the Act, identity verification standards under s 41, or contractual arrangements, none of which are set out in the Regulations themselves (reg 6 and Note 1).

Interpretive implications as legal rights/duties: the Endnotes incorporate ILA rules that make headings and notes part of the Statutory Rule (Endnotes, Interpretation of Legislation Act 1984). That means the Notes in regulation 6 , especially the cross-reference to s 3 and the identity verification standards made under s 41 , carry interpretive weight when construing obligations or the meaning of LOA labels. Users cannot treat the Notes as mere commentary for non‑legal effect; they form part of the instrument.

Absences that matter: because the Regulations do not create penalties, compliance obligations or enforcement mechanisms specific to the LOA labels or to delegations, duties and rights will almost entirely be found in the parent Act and in standards made under the Act. The Regulations’ function is therefore primarily definitional and classificatory rather than regulatory in the sense of imposing obligations.

Practical duty consequences: organisations implementing identity credential schemes must align their systems with the LOA labels, but the Regulations themselves do not say how. Delegation arrangements must be structured so that delegates are employees under Part 3 PAA 2004 who are administering the Act; failure to ensure a delegate fits that class could render a delegation procedurally defective relative to the prescription in regulation 8.

In summary, the Regulations establish rights in the sense of authorising delegation to a prescribed employment class and establish standard labels (LOA 1-4) which stakeholders are expected to use. They do not create operative duties, penalty regimes or detailed obligations; those remain in the Service Victoria Act 2018 and any identity verification standards made under it (reg 6 Note 1; reg 8).

The Regulations themselves do not set out penalties or direct enforcement mechanisms. The text contains no express penalty provisions, infringement schedules or compliance enforcement processes within the Statutory Rule.

What the Regulations do with enforcement contexts: the instrument confines itself to definition and prescription. Regulation 6 prescribes the nomenclature for levels of assurance and cross‑refers to identity verification standards under s 41 of the Act for substantive requirements (reg 6 and Note 1). Any enforceable obligations, sanctions, conduct standards, or compliance regimes tied to levels of assurance would therefore need to appear in either the parent Act (for example, in Part 6 referenced by the Regulations) or in the identity verification standards made under s 41. The Regulations point users to those instruments but do not themselves implement enforcement.

Delegation and accountability: regulation 8 prescribes the class of persons eligible to receive delegations under s 52 of the Act. The prescriptive choice of employees under Part 3 of the Public Administration Act 2004 implies that accountability for delegated acts will flow through public service employment and administrative arrangements within Service Victoria. The statutory registration of delegates as employees under Part 3 PAA 2004 will subject delegates to the employment oversight and disciplinary frameworks applicable to Part 3 employees, but those frameworks are managerial and statutory features outside the Regulations themselves. The Regulations do not impose additional penalty or disciplinary sanctions in respect of delegates.

Sunset and validity risk: the Endnotes state that the Regulations will sunset on 26 June 2028 under s 5 of the Subordinate Legislation Act 1994. That has an indirect enforcement consequence: unless remade or otherwise preserved, the Regulations will expire and their prescriptions (such as the LOA labels and the prescribed delegation class) will cease to have effect on that date. Parties relying on the Regulations for legal certainty should therefore monitor the sunset timetable and any remaking process. The Endnotes treat the sunset date as operational information (Endnotes, General information).

Interpretive enforcement: because the ILA interpretive rules have been incorporated as part of the Statutory Rule (Endnotes, Interpretation of Legislation Act 1984), any dispute about meaning will be subject to those interpretive conventions. That affects how courts, tribunals or reviewing authorities construe the Regulations when enforcing obligations in the parent Act or standards cross‑referenced by the Regulations.

In short, enforcement and penalties are located outside the Regulations. The Regulations provide classificatory and delegation prescriptions that feed into enforcement frameworks established by the Service Victoria Act 2018, identity verification standards under s 41, public service employment rules under the Public Administration Act 2004, and general administrative and statutory enforcement mechanisms of the State. The Regulations themselves do not impose a separate enforcement regime.

The Regulations are expressly integrated with several other statutory instruments and laws. The document provides explicit cross‑references that govern interpretation and operational linkages.

Service Victoria Act 2018: the Regulations are made under s 58 of the Service Victoria Act 2018 (reg 2). They reference multiple provisions of the Act. Regulation 6 is expressly “for the purposes of Part 6 of the Act” and prescribes the labels for levels of assurance in relation to electronic identity credentials (reg 6). The Notes to reg 6 rely on s 3 of the Act for the definition of “level of assurance” and on s 41 of the Act for the identity verification standards that give substantive meaning to each level (reg 6 Notes). Regulation 8 is “for the purposes of section 52 of the Act” and prescribes a class of persons eligible for delegation under that section (reg 8). Thus, the Regulations work as subordinate instruments to the Act; they supply definitions and prescribed classes that the Act calls for but leaves to subordinate rulemaking.

Public Administration Act 2004: regulation 8 prescribes persons “employed under Part 3 of the Public Administration Act 2004” as a class of delegates. That ties the delegation architecture under the Service Victoria Act to the employment categories and governance provisions in the Public Administration Act. The effect is that the institutional criteria for delegation are derived from existing public service employment law rather than invented in the Regulations.

Subordinate Legislation Act 1994: the Endnotes record that the Regulations will sunset 10 years after making on 26 June 2018, that is on 26 June 2028, under section 5 of the Subordinate Legislation Act 1994 (Endnotes, General information). This creates a temporal interaction where the subordinate instrument will automatically lapse unless the Secretary of the Department or the Governor in Council remakes or saves it consistent with the Subordinate Legislation Act.

Interpretation of Legislation Act 1984: the Endnotes set out interpretive conventions from the ILA that apply to the Statutory Rule. They confirm that headings, examples, diagrams, notes and punctuation form part of the instrument and that style changes authorised by ILA s 54A apply (Endnotes, Interpretation of Legislation Act 1984). This affects how courts or administrative decision-makers interpret the Regulations in relation to the Act and other laws.

Identity verification standards: the Regulations defer substantive standards for the levels of assurance to identity verification standards made under s 41 of the Service Victoria Act 2018. That creates a hierarchical link: the Regulations provide labels; the identity verification standards provide substance. Relying parties and credential issuers must therefore consult the Act’s standards to determine what each LOA requires in practice.

Amendments and other subordinate instruments: the Table of Amendments shows that S.R. No. 38/2024 and S.R. No. 140/2024 have modified the Regulations by revoking particular subparagraphs and Parts. Those later statutory rules are part of the subordinate legislation network that interacts with these Regulations and with the parent Act. The Table of Amendments also records the dates of making and commencement for the amendment rules (Endnotes, Table of Amendments).

In consequence, the Regulations interact with other laws by filling in discrete definitional and delegation prescriptions called for by the Service Victoria Act 2018, by importing employment categories from the Public Administration Act 2004, and by being interpreted in the light of the ILA. Enforcement, specific obligations and the practical meaning of LOAs are left to the Act and to the identity verification standards made under the Act, and the Regulations are time‑limited by the Subordinate Legislation Act 1994 sunset rule.

The Regulations were originally made on 26 June 2018 by the Governor in Council under section 58 of the Service Victoria Act 2018 and came into operation on 1 July 2018 (reg 3; Endnotes, General information). The document includes an explicit Table of Amendments listing subordinate instruments that have modified the Regulations. The recorded amendments are:

• Service Victoria (Miscellaneous) Amendment Regulations 2024, S.R. No. 38/2024. Date of making 28 May 2024. The Table of Amendments records that regs 9 and 10 of that amending instrument commenced on 29 May 2024 (Endnotes, Table of Amendments). The body of the Regulations records that reg 1(b) was revoked by S.R. No. 38/2024 reg. 9, and that Pt 4 (heading and reg. 7) was revoked by S.R. No. 38/2024 reg. 10 (Reg. 1 notes; after reg 6 and Pt 4 note).
• Service Victoria (General) Amendment Regulations 2024, S.R. No. 140/2024. Date of making 17 December 2024. The Table of Amendments records that those amendments commenced on 2 January 2025 (Endnotes, Table of Amendments). The Regulations themselves record that reg 1(a) was revoked by S.R. No. 140/2024 reg. 5, and that Pt 2 (heading and reg. 5) was revoked by S.R. No. 140/2024 reg. 6 (Reg. 1 notes; Pt 2 note).

As a result of these amendments, specific parts of the original Regulations were excised:

• Reg 1 originally contained multiple objective subparagraphs. Reg 1(a) and reg 1(b) have been revoked by separate 2024 amending instruments. What remains in reg 1 is subparagraphs (c) and (d) which set the Regulations’ objective to prescribe persons and classes of persons to whom the Service Victoria CEO may delegate functions or powers and to prescribe other matters authorised by the Act (reg 1(c) and (d)).
• Pt 2 (heading and regulation 5) has been revoked in full by S.R. No. 140/2024 reg. 6.
• Pt 4 (heading and regulation 7) has been revoked in full by S.R. No. 38/2024 reg. 10.

The Table of Amendments and the in-text revocation notes provide the operative dates for those revocations: reg 1(b) and Pt 4 revocations took effect with S.R. No. 38/2024 (regs commencing 29 May 2024 for regs 9 and 10), while reg 1(a) and Pt 2 revocations took effect with S.R. No. 140/2024 (commenced 2 January 2025). The Endnotes record that this publication incorporates those amendments up to 2 January 2025 (Title and version note).

The Endnotes also record that no explanatory details were entered at the date of publication for the Explanatory details section (Endnotes, Explanatory details). That means the Table of Amendments is the primary source for tracking the statutory changes recorded in the publication.

Finally, the Regulations are subject to the Subordinate Legislation Act 1994 sunset rule: they will sunset 10 years after making, on 26 June 2028, unless otherwise remade or saved under the Subordinate Legislation Act (Endnotes, General information). Practitioners should therefore treat the Regulations as time‑limited and monitor any remaking or saving steps taken before the sunset date.

The published text contains no entries recording litigation or judicial treatment of these Regulations. The Explanatory details section explicitly states “No entries at date of publication” (Endnotes, Explanatory details). The Regulations themselves are brief, prescriptive and largely definitional, which reduces the immediate likelihood of interpretive litigation focused on the Regulations alone; consequential litigation would more likely engage the parent Act, identity verification standards under s 41 of the Act, or employment issues under the Public Administration Act 2004.

Two aspects could, in principle, be the subject of legal challenge or interpretation, though the text contains no reported cases or judicial decisions:

• The meaning and legal effect of the LOA labels in regulation 6 when read alongside identity verification standards made under s 41 of the Act. Any contested point about the substantive requirements tied to an LOA label would likely require reference to the identity verification standards and the parent Act rather than to the Regulations themselves (reg 6 and Note 1).
• The validity or scope of delegations made by the Service Victoria CEO under section 52 of the Act using the class prescribed by regulation 8. Questions about whether a particular person falls within the prescribed class (for example, whether a particular employment relationship is properly characterised as “employed under Part 3 of the Public Administration Act 2004 in relation to the administration of the Act”) could give rise to administrative or judicial review. Again, the Regulations contain no reported decisions on this point.

Because the Endnotes integrate interpretive provisions of the Interpretation of Legislation Act 1984 into the Statutory Rule context, any court review would treat headings and notes as part of the instrument (Endnotes, Interpretation of Legislation Act 1984). Practitioners should therefore anticipate that if litigation arises, courts will treat the notes and headings in the Regulations as legally relevant.

At present, the publication records no litigation. Users seeking precedents or case law must therefore look to decisions involving the Service Victoria Act 2018 and any identity verification standards or delegation instruments made under the Act.

The Regulations are short, but there are several material pitfalls and practical points that can catch practitioners or agencies unprepared. Each is grounded in the text.

1. Labels without substance: regulation 6 prescribes LOA 1-4 labels but does not set the substantive verification, assurance metrics, or operational procedures. The note to reg 6 says that “level of assurance” is defined in s 3 of the Act as “the degree of confidence … as set out in the identity verification standards made under section 41 of the Act” (reg 6 Note 1). Gotcha: adopting the labels without consulting the identity verification standards will leave implementers without legally grounded specifications and may produce mismatches between procurement specifications, contracts and operational practices.

2. Delegation limited to a particular employment class: regulation 8 prescribes the class of persons eligible for delegation as “persons employed under Part 3 of the Public Administration Act 2004 in relation to the administration of the Act” (reg 8). Gotcha: privately contracted staff, external consultants, or staff not employed under Part 3 PAA 2004 will not be within the prescribed class. Delegations given to persons outside the prescribed class could be procedurally defective as a matter of the Regulations’ prescription.

3. Revocations altered original objectives: reg 1 originally contained multiple objectives but subparagraphs (a) and (b) were revoked by amending instruments in 2024 and 2025. Gotcha: relying on an earlier version of reg 1 may lead to incorrect statements of the Regulations’ objectives. Practitioners must check the current consolidated instrument and the Table of Amendments (Reg. 1 notes; Endnotes, Table of Amendments).

4. Sunset date: the Endnotes state the Regulations will sunset 10 years after making, on 26 June 2028 (Endnotes, General information). Gotcha: if the Regulations are relied upon in operational documents, those documents must be updated before the sunset date or risk losing the statutory foundation for delegation classes and LOA labels unless the Regulations are remade.

5. Interpretive weight of notes and headings: the ILA interpretive rules incorporated in the Endnotes mean that headings, examples and notes are part of the Statutory Rule (Endnotes, Interpretation of Legislation Act 1984). Gotcha: expecting notes to be non‑binding commentary is incorrect; they have statutory status for interpretation.

6. No penalty or enforcement regime in the Regulations: the absence of penalties means practitioners must find enforcement powers elsewhere. Gotcha: assuming the Regulations create a standalone compliance regime is incorrect; duties and sanctions will reside in the Act or in standards.

7. Staggered amendment timings: revocations took effect on different dates according to the amending instruments. For example, parts revoked by S.R. No. 38/2024 commenced on 29 May 2024 for the relevant regs, while S.R. No. 140/2024 amendments commenced on 2 January 2025 (Endnotes, Table of Amendments). Gotcha: relying on historic versions without checking commencement dates can produce errors about what was in force at a particular time.

8. Cross‑instrument dependencies: the Regulations’ practical effect depends on other instruments , the Service Victoria Act 2018 (for s 41 identity verification standards and s 52 delegations) and the Public Administration Act 2004 (for the employment category). Gotcha: reading the Regulations in isolation will obscure where substantive duties and rights are actually created.

9. No explanatory details recorded: the Explanatory details section has “No entries at date of publication” (Endnotes, Explanatory details). Gotcha: absence of an explanatory memorandum entry means there is no statutory‑published exposition of legislative intent within this publication to assist interpretation.

10. Narrow scope limits drafting assumptions: some drafters may have assumed the Regulations would contain more operational detail. Gotcha: the minimalist drafting implies that operational rules must come from the Act or from subordinate standards; expecting the Regulations to be a self‑contained operational manual will lead to gaps.

These are concrete, text‑based pitfalls. Each stems from the Regulations’ function as a short subordinate instrument that provides labels and a prescribed delegation class while leaving substantive content, enforcement and operational detail to other instruments.

Compliance with these Regulations requires attention to their limited scope and to the instruments they reference. The following practical steps are grounded in the Regulations and Endnotes.

1. Check the current consolidated text and amendment history before relying on provisions. The Table of Amendments shows changes by S.R. No. 38/2024 and S.R. No. 140/2024 with different commencement dates (Endnotes, Table of Amendments). Ensure legal documents refer to the in‑force version and note the sunset date of 26 June 2028 (Endnotes, General information).

2. For delegation arrangements:

   • Ensure any instrument of delegation by the Service Victoria CEO is to a person who is employed under Part 3 of the Public Administration Act 2004 and whose employment relates to administration of the Service Victoria Act (reg 8). Delegations to persons outside that prescribed class may be inconsistent with the Regulations.
   • Record the employment basis of each delegate in the delegation instrument and in internal governance records to demonstrate that the delegate falls within the prescribed class in reg 8.
   • Align delegation practice with the parent Act’s section 52 mechanics (the Regulations state reg 8 is “for the purposes of section 52 of the Act”) and with public service employment procedures under the Public Administration Act 2004.

3. For identity credential implementation:

   • Use the LOA labels LOA 1-LOA 4 as the formal nomenclature in policies, procurement documents, specifications, contracts and systems (reg 6). Do not invent bespoke labels that conflict with these terms.
   • Consult the identity verification standards made under s 41 of the Service Victoria Act 2018 to determine the substantive verification requirements and the degree of confidence each LOA signifies (reg 6 Note 1). The Regulations themselves do not provide substantive verification steps.
   • Ensure that contracts with credential issuers and relying party agreements map technical controls and assurance measures to the LOA labels as defined by the standards under s 41, not merely to the labels in the Regulations.

4. Interpretation and documentation:

   • Treat the Notes and headings as part of the instrument for interpretive purposes, per the ILA material in the Endnotes (Endnotes, Interpretation of Legislation Act 1984). Document legal reasoning and policy decisions with reference to the notes where relevant.
   • Keep a register of which internal or external personnel are treated as delegates and why, including citational references to reg 8 and to the relevant PAA employment provisions.

5. Plan for the sunset:

   • The Regulations will sunset on 26 June 2028 under the Subordinate Legislation Act 1994 (Endnotes, General information). If your operational arrangements rely on these Regulations (for example, on the LOA labels or on the prescribed delegation class), plan for how you will maintain legal foundation after that date. This may require monitoring whether the Regulations are remade, replaced or otherwise preserved.

6. Monitor adjacent instruments:

   • The substantive duties and enforcement mechanisms will appear in the Service Victoria Act 2018 and in identity verification standards under s 41. Ensure legal and compliance teams have those instruments on their reading list. The Regulations point to these instruments without substituting for them (reg 6 Notes; reg 8 cross‑refers to s 52).

7. Audit and contractual language:

   • When drafting service descriptions, procurement clauses, or SLAs that reference identity assurance, specify which LOA (1-4) is required and link each required LOA to the identity verification standard or to the relevant clause of the Act. Avoid stating obligations using only the label without the reference to the standard.
   • For delegations, ensure operational accountability (reporting lines, supervision and recordkeeping) is in place to align with the delegated powers, since the Regulations themselves do not establish the detail of internal controls.

8. Legal review:

   • Before relying on a delegation or before accepting identity credentials at a given LOA, have legal counsel confirm that the relevant identity verification standards are published, that the delegated person’s employment falls within Part 3 PAA 2004, and that any contractual reliance on LOA labels is consistent with the Act and standards.

9. Keep change control for documents:

   • Because the Regulations have been amended and specific provisions revoked, maintain version control of operational documents to show which legal version was in force at a given time. This is particularly important given staggered commencement dates for amendments (Endnotes, Table of Amendments).

10. Note absence of penalties:

• The Regulations do not create penalties. If compliance obligations are to be enforced, refer to the parent Act and to standards for specific enforcement mechanisms. Design compliance monitoring to reflect obligations from those instruments rather than expecting the Regulations themselves to supply sanctioning provisions.

These steps follow directly from the Regulations’ text and Endnotes. The Regulations prescribe names and a delegation class and point to the Act and standards for substance. Compliance therefore depends on integrating the Regulations with the Service Victoria Act 2018, the identity verification standards under s 41, and the employment framework of the Public Administration Act 2004, while also attending to amendment, commencement and sunset dates recorded in the instrument.