Statement of Principles concerning alcohol use disorder (Reasonable Hypothesis) (No. 85 of 2025)

This instrument is a Statement of Principles concerning alcohol use disorder (Reasonable Hypothesis) (No. 85 of 2025) made by the Repatriation Medical Authority under subsection 196B(2) of the Veterans' Entitlements Act 1986, dated 24 October 2025 and commencing 24 November 2025 (see ss 1, 2, 3). Mechanically, it repeals the prior Statement of Principles concerning alcohol use disorder (Reasonable Hypothesis) (No. 48 of 2017), Federal Register No. F2017L01045 (s 4). It applies to claims that fall within the scope of section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 (MRCA) (s 5). The instrument defines the condition it covers, the minimum factors which must exist for a reasonable hypothesis to be raised linking alcohol use disorder or death from alcohol use disorder to a person’s relevant service, and how those factors relate to other Statements of Principles (ss 7-11; Schedule 1).

Substantively, the Statement of Principles fixes the clinical definition of alcohol use disorder for purposes of claims assessment as the DSM-5-TR diagnostic criteria set out in s 7(2). It expressly excludes alcohol-induced disorders such as alcohol intoxication, alcohol withdrawal, and alcohol-induced mental disorders in the absence of alcohol use disorder (s 7(2) final paragraph). The Schedule clarifies that the RMA treats AUD as attracting ICD-10-AM codes F10.1 and F10.2 for coding purposes, but the operative meaning is the DSM-5-TR definition set in s 7(2) (s 7(3)-(4); Schedule).

On the causal test, the instrument specifies a list of discrete factors at section 9, and states that at least one of those factors must exist as a minimum before it can be said that a reasonable hypothesis has been raised connecting alcohol use disorder, or death from it, with the circumstances of the person’s relevant service (s 9). Section 10 requires that any such factor be related to the person’s relevant service, defines how clinical worsening is to be treated for cases where AUD pre-existed service, and confirms the application of factors that refer to other determinable injuries or diseases will be governed by the terms of whatever other Statement of Principles applies (s 10-11).

The RMA records its view that there is sound medical-scientific evidence that alcohol use disorder and death from alcohol use disorder can be related to relevant service, and states that view as the basis for the factors it sets out (s 8). The instrument is therefore a procedural and evidential map for decision-makers applying the reasonable hypothesis connection test in the VEA and MRCA framework, specifying definitional, temporal and relational conditions that underpin causal linkage assessments.

The instrument organises around several core legal and clinical concepts. These are the legal source and scope, the operational definition of alcohol use disorder, the set of trigger or predisposing factors that suffice to raise a reasonable hypothesis of service connection, temporal windows for those factors, the concept of relevant service, and cross-reference to other Statements of Principles.

1. Legal source and scope: The RMA makes the Statement under s 196B(2) of the VEA (s 3). The Statement expressly applies to claims to which s 120A of the VEA or s 338 of the MRCA applies (s 5). The instrument replaces the earlier No. 48 of 2017 (s 4).

2. Operative definition of alcohol use disorder: The Statement adopts the DSM-5-TR diagnostic criteria in full as the operative definition for claims assessment (s 7(2)). The criteria are reproduced in the instrument and require at least two of a list of specified clinical indicators occurring within a 12-month period (s 7(2) paras 1-10). The Schedule defines DSM-5-TR expressly as the American Psychiatric Association manual (Schedule). The instrument notes that while AUD attracts ICD-10-AM codes F10.1 and F10.2, the meaning for the SOP is the DSM-5-TR definition (s 7(3)-(4)).

3. Exclusions within the clinical definition: The Statement makes clear that the definition of alcohol use disorder excludes alcohol-induced disorders in the absence of alcohol use disorder; examples provided are alcohol intoxication, alcohol withdrawal, and alcohol-induced mental disorders (s 7(2) penultimate paragraph). This is a categorical exclusion for the purpose of claims under this SOP.

4. Death from alcohol use disorder: For claims involving death, the Statement treats death from AUD as including death from a terminal event or condition that was contributed to by the person’s alcohol use disorder (s 7(4)). The Schedule defines “terminal event” with a non-exhaustive list (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) (Schedule).

5. The reasonable hypothesis filter: Section 9 lists the factors that must exist, as a minimum, before a reasonable hypothesis can be said to be raised connecting AUD or death from AUD to relevant service. Those factors include a set of clinically significant disorders of mental health at the time of clinical onset or clinical worsening (22 items listed including PTSD, major depressive disorder, substance use disorder), exposure to stressors of specified categories within precise time windows (category 1A or 1B within 5 years, category 2 within 1 year), bereavement within 10 years, childhood abuse or neglect, persistent pain of at least 3 months, Roux-en-Y gastric bypass within 3 years, morally injurious events within 5 years, intimate partner violence within 5 years, tobacco use at least 0.5 pack-years with particular timing if smoking has ceased, concussion or moderate to severe traumatic brain injury within 3 years, and inability to obtain appropriate clinical management before clinical worsening (s 9).

The Statement is addressed to the statutory claim environment created by the VEA and MRCA. It affects claimants, the Repatriation Medical Authority, decision-makers applying the VEA and MRCA, clinicians preparing medico-legal evidence, and legal and advocacy representatives involved in claims.

1. Claimants: The instrument applies to claims to which s 120A of the VEA or s 338 of the MRCA applies (s 5). The Schedule defines relevant service to include operational, peacekeeping, hazardous, British nuclear test defence service under the VEA and warlike or non-warlike service under the MRCA. Therefore the most immediate group affected are veterans, members of peacekeeping forces, and members of the Forces whose service meets those recorded categories and who lodge claims for recognition of alcohol use disorder or death from alcohol use disorder that raise the reasonable hypothesis connecting factor.

2. Decision-makers and administrators: Although the instrument does not name the claim decision-maker, it is intended to be applied by the decision-making bodies that decide claims under the VEA and MRCA framework. The RMA makes the Statement under s 196B(2) and sets the evidentiary factors that those decision-makers must use when assessing whether a reasonable hypothesis has been raised (ss 3, 9, 10). The instrument therefore affects adjudicators, medical reviewers, and any agency staff who process VEA and MRCA claims that involve AUD.

3. Clinicians and experts: The Statement prescribes the diagnostic framework to be used when identifying alcohol use disorder for claim purposes , the DSM-5-TR criteria (s 7(2); Schedule). Clinicians preparing reports for claimants or for decision-makers will therefore need to frame diagnoses and date clinical onset or clinical worsening against the criteria and the temporal windows specified in s 9.

4. Other SOP authors and cross-referenced medical frameworks: Section 11 creates a pathway where factors in this Statement that refer to another injury or disease will invoke the factors in that other Statement of Principles. Parties and decision-makers working across multiple SOPs , for example psychiatric disorders, traumatic brain injury, chronic pain, surgical sequelae , will need to coordinate the relevant SOP texts.

5. Families and beneficiaries in death claims: The instrument treats death from AUD as including deaths from terminal events contributed to by AUD (s 7(4) and Schedule). This extends the instrument’s reach to cases where a person has died and a claim of service connection for that death is advanced under the applicable VEA or MRCA provisions.

The instrument is not framed as a statute creating freestanding civil duties or criminal offences. Instead it defines the evidentiary threshold and clinical definitions that are to be applied when assessing whether a reasonable hypothesis connects alcohol use disorder, or death from alcohol use disorder, to a person’s relevant service. That structure creates operational duties for decision-makers and practical obligations on parties who prepare and present claims.

1. Duties of the Repatriation Medical Authority: The RMA has exercised its statutory power under s 196B(2) of the VEA to determine this Statement (s 3). The instrument itself contains the RMA’s view about the medical-scientific basis for the factors (s 8), and by publishing the SOP the RMA establishes the criteria decision-makers will follow in assessing the reasonable hypothesis question for AUD claims.

2. Duties of decision-makers applying VEA/MRCA: While this instrument does not itself contain a provision instructing decision-makers, its stated application is to claims to which s 120A of the VEA or s 338 of the MRCA applies (s 5). The functional duty for decision-makers is to treat the factors in s 9, the definitions in the Schedule, and the relational requirement in s 10 as the governing framework for determining whether a reasonable hypothesis has been raised in AUD-related claims. In practice this requires decision-makers to check whether at least one of the s 9 factors is present, whether it is related to the person’s relevant service, and whether the temporal requirements are satisfied.

3. Duties on medical experts and treating clinicians: Clinicians or experts providing evidence for claims must use the DSM-5-TR diagnostic criteria set out in s 7(2) when they opine that a person has alcohol use disorder for the purposes of a VEA/MRCA claim. They should state dates of clinical onset or clinical worsening and document any of the s 9 factors as they apply, including timing relative to onset/worsening.

4. Practical obligations on claimants and representatives: The Statement indirectly requires claimants and their representatives to assemble documentary and clinical evidence to demonstrate the existence of at least one factor in s 9 and to show its relationship to relevant service as required by s 10. For some elements the Schedule clarifies the content of what must be shown, for example the calculation of pack-years, the definition of witness, or the meaning of clinically significant disorder of mental health.

The Statement of Principles contains no penalty or fine provisions, nor does it set out direct enforcement mechanisms in the criminal or civil sense. It is an administrative instrument that specifies criteria for determining whether a reasonable hypothesis exists linking alcohol use disorder or death from alcohol use disorder to a person’s relevant service under the VEA/MRCA claim frameworks. The points below describe how enforcement and compliance will operate in practice as derived from the text.

1. No penal provisions in the instrument: The instrument itself contains no new offences, penalties, sanctions, or enforcement powers. It is a determinative evidentiary statement made under the RMA’s statutory power (s 3) and does not purport to create statutory penalties.

2. Enforcement via claims processes: The practical enforcement of the instrument occurs through the decision-making processes under the VEA and MRCA that apply to claims to which s 120A of the VEA or s 338 of the MRCA apply (s 5). The SOP supplies the criteria decision-makers must use when deciding whether a reasonable hypothesis has been raised. Any corrective or enforcement action (accepting, rejecting, or preferring certain evidence) will be implemented through those statutory claims processes rather than through this Statement directly.

3. Role of the Repatriation Medical Authority: The RMA is the body that determined the Statement (s 3). Its enforcement role is to set the criteria. The instrument does not itself empower the RMA to impose sanctions; rather it provides the technical definitions and factors decision-makers will rely on. The instrument is a direction on medical causation standards to be used in the statutory claims environment.

4. Evidence and proof questions: The Statement specifies what factors must exist to raise a reasonable hypothesis, including timing and diagnosis requirements (s 9; Schedule). Disagreements over whether the necessary factual conditions exist will be resolved within the VEA or MRCA claims processes. The Statement does not itself set evidentiary standards or procedural rules for contested factual issues such as how to prove dates or whether a stressor was related to service. Those procedural rules remain in the broader legislation and departmental practice, which are not replicated in this instrument.

5. Interaction with other Statements of Principles: Section 11 establishes that where a factor in s 9 refers to an injury or disease subject to another SOP, the terms of that other SOP govern. Any disputes as to applicability or interpretation between SOPs will be managed by applying each SOP as in force, again within the statutory claims framework.

The Statement is an instrument under the VEA regime and is expressly linked to both the Veterans' Entitlements Act 1986 and the Military Rehabilitation and Compensation Act 2004. It also references internationally recognised clinical classifications and other Statements of Principles. The following interactions are established by the instrument itself.

1. Source statute and application: The Statement is made under subsection 196B(2) of the VEA (s 3). It applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s 5). Those cross-references are the instrument’s primary legal connectors to the broader compensation and entitlements framework. The scope of application is therefore defined by the statutory definitions of relevant service and the claims provisions found in the VEA and MRCA.

2. Interaction with other Statements of Principles: Section 11 expressly provides that if a factor in s 9 refers to an injury or disease for which a Statement of Principles under s 196B(2) has been determined, the factors in that other Statement apply as in force. This makes the instrument part of a networked system of SOPs. Where factors cross-refer, the terms of the relevant SOP in force will govern the assessment. The instrument thus delegates medical causal assessments for overlapping conditions to the relevant SOP texts.

3. Diagnostic classification systems: The Statement uses DSM-5-TR as the operative diagnostic standard for alcohol use disorder (s 7(2); Schedule). It also notes ICD-10-AM codes F10.1 and F10.2 as the codes that AUD attracts, but clarifies that the meaning for this Statement is the DSM-5-TR definition (s 7(3)-(4)). The Schedule cites the specific edition and effective date for ICD-10-AM (Tenth Edition, effective 1 July 2017) and identifies the copyright holder. Decision-makers, clinicians and record-keeping systems will therefore need to reconcile DSM-5-TR diagnostic terms with ICD-10-AM coding when recording or indexing cases.

4. Definitions of relevant service and procedural statutes: The Schedule defines relevant service to include specific categories under the VEA and MRCA, including operational, peacekeeping, hazardous, British nuclear test defence service, warlike service, and non-warlike service (Schedule). The link to these statutory categories ties the SOP to the substantive eligibility and jurisdictional reach provided by the VEA and MRCA.

5. Non-exhaustive clinical lists and external legal frameworks: The Schedule’s definitions, for example of intimate partner violence, include examples that map to common law or criminal law concepts (violence, threats, neglect, coercion, stalking). The Statement does not attempt to supplant or re-define those legal constructs; rather it lists behaviours that, if shown to have occurred within specified windows, will be treated as factors that may raise a reasonable hypothesis for AUD.

The instrument contains a limited, explicit amendment history within its body. The operative points are the date of determination, commencement, and the formal repeal of the earlier Statement.

1. Repeal of earlier Statement: Section 4 explicitly repeals the Statement of Principles concerning alcohol use disorder (Reasonable Hypothesis) (No. 48 of 2017) (Federal Register of Legislation No. F2017L01045), which was made under subsection 196B(2) of the VEA. The text does not provide a redline or a schedule of the differences between the 2017 instrument and the 2025 instrument. The repeal is unconditional in the instrument text.

2. Dates: The instrument is dated 24 October 2025 (front matter) and commences on 24 November 2025 (s 2). The effective date for use in claims processes is therefore 24 November 2025 forward, replacing the earlier SOP for claims assessed after that commencement date.

3. Identification and numbering: This is Statement of Principles No. 85 of 2025, concerning alcohol use disorder (Reasonable Hypothesis) (front matter and s 1). The instrument bears the signature of the RMA Chairperson on behalf of the Repatriation Medical Authority.

4. Lack of other listed amendments: The instrument contains no list of prior amendments other than the repeal of the 2017 instrument. It does not record any interim amendments between 2017 and 2025 within its text. There is no transitional provision spelled out for claims that straddle the repeal and commencement dates; the instrument simply states that it applies to claims to which the specified sections of the VEA and MRCA apply (s 5) and repeals the prior SOP (s 4).

5. Implications for record-keeping and legacy claims: Because the instrument repeals the 2017 SOP and supplies a new definition and list of factors, practitioners will need to check which SOP applies to claims lodged or assessed around the commencement date. The instrument itself does not contain transitional rules; any transitional handling must be drawn from the VEA/MRCA practice guidance or the administering agency’s procedural directions. The instrument’s repeal provision means that the 2017 text has no continuing operation for claims after commencement unless other statutory provisions provide for transition; such provisions are not in the text of this instrument.

6. No express sunset, variation or review clause: The instrument does not include an internal timetable for review or express power to vary or reissue within its own text. Future amendments would be effected by subsequent determinations under s 196B(2) of the VEA, but that process is not described within this instrument.

The Statement of Principles text before you does not record litigation history, case citations, or past judicial or tribunal decisions. The instrument contains no mention of cases, precedent, or judicial interpretation. The Schedule and the body of the SOP cite only clinical classification systems (DSM-5-TR, ICD-10-AM) and do not reference adjudicative outcomes.

Consequently:

1. No cases are named or discussed in the instrument itself. The text does not identify any litigation that prompted the revision, nor does it reference decisions that have applied prior SOP versions.

2. No judicial construction is contained. The instrument provides statutory definitions and the RMA’s view about the medical-scientific evidence supporting the link between AUD and relevant service (s 8), but it does not contain or summarise judicial or tribunal decisions that adopted, rejected, or interpreted previous SOPs or these concepts.

3. Practical implication for practitioners: Because the instrument does not include litigation history, practitioners seeking to understand how courts or tribunals have applied reasonable hypothesis tests, the exclusion of alcohol-induced disorders, or the temporal windows set out here must look beyond this instrument to case law and administrative decisions under the VEA and MRCA. Those sources are not part of the instrument’s text and are not reproduced here.

4. Uncertainty about judicial reception: The absence of recorded litigation or authority in the text leaves open questions about how courts and tribunals will interpret particular elements of the Statement, such as the interaction between s 10’s relationship-to-service requirement and proof of clinical onset dates, or the treatment of cross-referenced SOPs under s 11. Those interpretative points will be resolved in practice by decision-makers and, if contested, by tribunals and courts; practitioners should therefore expect that some contested issues may require external legal research and potential litigation.

5. No express non-derogation or privative clause: The instrument does not contain language shielding the RMA’s determinations from review. Any challenge to how the SOP is applied in a particular claim will be dealt with under the administrative and merits review routes set out in the VEA/MRCA frameworks. The instrument does not purport to limit judicial review or appeals.

In summary, the instrument provides no litigation history. Understanding how its provisions will fare under judicial or tribunal scrutiny will require review of subsequent decisions and appeals that apply this SOP in claims contexts.

This instrument contains a number of technical features that commonly cause difficulty in application. The following are concrete, source-grounded pitfalls and points where claimants, clinicians and decision-makers should take care when preparing or assessing claims.

1. Diagnostic definition is DSM-5-TR not ICD-10-AM alone: Although the SOP notes that AUD attracts ICD-10-AM codes F10.1 and F10.2 (s 7(3)), it specifies that the operative meaning of AUD for the SOP is the DSM-5-TR criteria set out in s 7(2). A medical report that only cites an ICD-10-AM code without addressing the DSM-5-TR criteria, or that relies only on a descriptor such as “alcohol dependence” without mapping to the DSM-5-TR criteria, risks being treated as non-specific to the SOP’s operative definition.

2. Exclusion of alcohol-induced disorders: The instrument expressly excludes alcohol-induced disorders in the absence of alcohol use disorder (s 7(2) final paragraph). Accordingly, submissions that rely solely on episodes of intoxication, withdrawal, or an alcohol-induced mental disorder, without establishing the DSM-5-TR criteria for AUD, will not meet the SOP’s definition.

3. Temporal windows are specific and varied: Each factor in s 9 carries a specific temporal requirement relative to clinical onset or clinical worsening. Examples include category 1A or 1B stressor within 5 years, category 2 stressor within 1 year, death of a close person within 10 years, persistent pain for at least 3 months before onset/worsening, Roux-en-Y within 3 years, concussion/TBI within 3 years, morally injurious event within 5 years, intimate partner violence within 5 years, and smoking at least 0.5 pack-years with a 3-month rule if smoking has ceased (s 9; Schedule). Failure to establish exact or reasonably accurate timing can be fatal to the factor-based test.

4. Relationship to relevant service is required: Section 10 requires that any factor in s 9 must be related to the person’s relevant service. It is not enough to show the existence of a factor; the factor must be tied to the relevant service category that gave rise to the claim. Practitioners must therefore gather evidence linking the factor to service events or conditions; remote or unrelated stressors may not satisfy s 10(1).

5. Clinical worsening nuance where AUD pre-existed service: Section 10(2) provides that the clinical worsening aspect of s 9 factors applies to material contribution to, or aggravation of, AUD where the disorder pre-existed or was contracted before or during (but did not arise out of) the person’s relevant service. This is a narrower causal pathway than primary causation and requires evidence that service materially contributed to worsening or aggravation.

The Statement establishes a clear set of documentary and clinical tasks for claimants, clinicians and representatives. Compliance in practical terms will mean assembling specific types of evidence, ensuring diagnoses are framed to the DSM-5-TR criteria, and documenting the temporal and service-related nexus required by sections 9 and 10. The following is a pragmatic compliance checklist derived strictly from the instrument text.

1. Confirm the claim falls within scope: Verify that the claim is one to which section 120A of the VEA or section 338 of the MRCA applies (s 5). Confirm the claimant’s service meets one of the Schedule’s relevant service categories (operational, peacekeeping, hazardous, British nuclear test defence, warlike or non-warlike under MRCA).

2. Use DSM-5-TR diagnostic criteria in medical reports: Ensure any clinician’s report diagnosing alcohol use disorder addresses the DSM-5-TR criteria reproduced in s 7(2). The report should state how many and which of the DSM criteria are met, and specify dates of clinical onset or clinical worsening. Do not rely solely on ICD-10-AM codes without mapping to DSM-5-TR, as s 7(3)-(4) makes the DSM definition operative.

3. Address the exclusion of alcohol-induced disorders: If the clinical picture includes alcohol intoxication, withdrawal, or alcohol-induced mental disorders, the clinician’s report must explain why these do or do not amount to alcohol use disorder under DSM-5-TR. The SOP excludes alcohol-induced disorders in the absence of AUD (s 7(2)); therefore reports should make the distinction explicit.

4. Establish at least one s 9 factor and its timing: Prepare evidence that at least one of the factors in section 9 existed before the clinical onset or clinical worsening within the specified time window. For each potential factor, gather corroborating documentation:

   • Clinically significant mental disorder: psychiatric assessments, ongoing management notes, or specialist reports showing severity warranting ongoing management (Schedule).
   • Category 1A/1B stressors: incident reports, military records, witness statements, or contemporaneous medical records showing exposure and timing (Schedule).
   • Category 2 stressors: records of caregiving duties, workplace records, legal files, or medical evidence of long-term disability (Schedule).
   • Death of a close person: death certificate, family statements, dates of bereavement.
   • Childhood harm or neglect: relevant historical records, medical or child protection files if available.