By Darian Macey, June 11 2025
Expect stricter scrutiny of your Indigenous Participation Plans, as Defence is likely to tighten enforcement across the contract lifecycle.
By Darian Macey
Many government agencies, including Defence, are falling short of their obligations to include Indigenous employment and business participation in major contracts. That is the key finding of a new report from the Australian National Audit Office released this week.
For those of us shaping the Defence Estate, this isn’t just a compliance issue—it’s a question of whether our projects are delivering on one of the policy’s core promises: to create real, lasting opportunities for Aboriginal and Torres Strait Islander communities.
The Mandatory Minimum Requirements (MMRs) have been in place since 2016. They apply to Commonwealth contracts over $7.5 million in key sectors—including construction and estate management—and require contractors to hit targets for Indigenous employment and subcontracting. Nearly a decade on, the system is showing its cracks. The latest audit paints a picture of patchy implementation, vague exemptions, and a system that still relies too heavily on unverified contractor reporting.
What the Auditor-General Found
The audit reviewed how well government entities—including the Department of Defence—have responded to earlier recommendations from 2019–20. The findings include:
- $69.3 billion worth of contracts were exempted from Indigenous participation targets—many of them using a catch-all “Other” category that offers little accountability.
- Only 72% of completed MMR contracts were confirmed to have met their targets.
- Of contracts still underway, less than half are currently on track to meet their targets.
- Reporting tools like the Indigenous Procurement Policy Reporting Solution (IPPRS) are underused or not used correctly.
- Defence, while stronger than some agencies, still showed inconsistent performance—particularly in contracts procured through panel arrangements.
Perhaps most critically, the agency responsible for the policy—the National Indigenous Australians Agency (NIAA)—has still not evaluated whether the MMRs are actually achieving their intended impact. In other words, we’re collecting data but not using it to answer the question: is this working?
Why This Matters for Defence Estate Teams
If you’re involved in procurement, contract administration or project delivery on the Defence Estate, this matters.
Every new facility, maintenance package or remote area upgrade is an opportunity to involve Indigenous businesses and workers. And yet, the systems in place don’t always make this easy. Too often, compliance is treated as a once-off box ticked at the tender stage—with little follow-through during delivery.
This is more than a policy failure. It’s a missed opportunity to build meaningful local participation into the Defence infrastructure pipeline.
What You Can Do
Here are six practical steps Defence Estate professionals can take to lift performance and make Indigenous participation real, not rhetorical:
- Update Your Templates and Checklists
Ensure all procurement documents reflect the latest IPP rules. Don’t assume what worked five years ago still applies. - Scrutinise Participation Plans Early
At tender stage, assess the Indigenous Participation Plan as a live strategy—not a token document. Are the targets realistic? Do they reflect the local context? - Track Performance, Not Just Promises
Use the IPPRS properly. Set up contracts promptly, monitor quarterly reports, and don’t finalise contracts without reviewing actual outcomes. - Ask for Evidence
Don’t accept contractor self-reporting at face value. Request payroll data, invoices to Indigenous suppliers, or third-party confirmation. You’re entitled to ask—and expected to verify. - Challenge ‘Other’ Exemptions
If your team is recording MMR exemptions, make sure the reasons are legitimate. The ‘Other’ category should be rare—not routine. - Build Relationships Locally
In regional and remote areas especially, success depends on early engagement. Connect with Indigenous businesses well before the tender goes live.
Looking Ahead
With billions in Defence infrastructure spending planned over the next decade—especially across northern Australia—the scale of opportunity is enormous. But the audit makes it clear: opportunity alone doesn’t deliver outcomes. It takes clear expectations, follow-through, and leadership at every level of project delivery.
If you’re unsure whether your team is meeting the mark, now’s the time to ask. DECnet is here to help contractors, consultants and officials turn good intentions into solid outcomes.
Let’s not wait for the next audit to fix this.
Author: Darian Macey
Darian is a former Engineering Officer with the RAE with tertiary qualifications in Engineering and Project Management. He is a leading practitioner within Australia's NSI sector with previous employment in Government, project management and building contractor organisations.
