23 April 2026
Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra ACT 2600 ndis.joint@aph.gov.au
Dear Committee
Inquiry into the Integrity of the National Disability Insurance Scheme
Thank you for inviting AUSTRAC to make a submission to the Committee’s inquiry into the Integrity of the National Disability Insurance Scheme (NDIS). Of the inquiry’s terms of reference, number one is relevant to AUSTRAC: ‘(1) the nature and extent of non-compliance, including fraud and sharp practices, in the NDIS’.
AUSTRAC is Australia’s financial intelligence unit and anti-money laundering and counter-terrorism financing (AML/CTF) regulator. Our role is to protect the Australian community by identifying, deterring and disrupting serious financial crime, including fraud. We do this through the collection, analysis and dissemination of financial intelligence.
Financial intelligence supports law enforcement, human services and regulatory agencies to detect, investigate and disrupt criminal activity. This includes fraud and misuse of government payment programs. In relation to the NDIS, AUSTRAC identifies financial patterns, behaviours and networks that indicate non-compliance, fraud or sharp practices affecting NDIS payments. We share this intelligence with agencies responsible for operational, regulatory and enforcement responses.
Financial intelligence indicates that non-compliance and fraud within the NDIS reflects patterns observed across other large government payment programs. This includes exploitation by opportunistic individuals, and more organised and networked actors, sometimes facilitated through complex financial arrangements.
The nature of non-compliance and fraud observed includes:
- co-mingling of NDIS funds with other income streams, including proceeds of unrelated criminal activity
- movement of NDIS proceeds offshore without a clear service-delivery purpose
- acquisition of high-value assets such as residential and commercial property, vehicles and luxury goods
- mortgage repayments and loan servicing unrelated to disability service provision
- lifestyle expenditure inconsistent with the scale or nature of legitimate service delivery.
AUSTRAC intelligence has also identified cases in which organised criminal groups exploit NDIS payment flows, either directly through provider entities, or indirectly through associated businesses and individuals. In these cases, NDIS funds may serve both as a source of revenue and in some instances, as a means to launder proceeds from other criminal activity.
While AUSTRAC does not estimate or quantify the total value of fraud within the NDIS, our financial intelligence indicates that NDIS-related fraud can be systemic, networked and financially sophisticated, rather than limited to isolated instances of individual non-compliance.
AUSTRAC receives transaction reports and suspicious matter reports from reporting entities, including banks, remitters and digital currency exchanges. These reports provide essential visibility of financial activity associated with NDIS participants, providers and related entities. Our analysts assess this data to identify:
- unusual or anomalous transaction patterns
- financial behaviour inconsistent with legitimate disability service provision
- money laundering typologies, including cross-border funds flows
- unexplained wealth inconsistent with declared provider income
- networks connecting related individuals and entities.
This informs the production of actionable financial intelligence products, which are disseminated to partner agencies with responsibility for safeguarding NDIS integrity and responding to fraud.
AUSTRAC is an active participant in the Fraud Fusion Taskforce. This multi-agency initiative operates through the Fraud Fusion Centre, to strengthen the Commonwealth’s response to fraud against government programs including the NDIS. Through the Fraud Fusion Taskforce, AUSTRAC:
- shares financial intelligence to support joint targeting and operational prioritisation
- contributes to an improved understanding of how organised crime exploits payment systems and regulatory gaps
- assists in identifying emerging fraud and money laundering methods
- contributes to multi-agency analytical products
- supports coordinated disruption activity.
AUSTRAC also hosts staff from the National Disability Insurance Agency in our public-private partnership, Fintel Alliance. These arrangements support greater capability building, information exchange and engagement between the National Disability Insurance Agency, industry partners and law enforcement. This improves early detection and awareness of fraud risks, including against government-funded programs identified in the Fintel Alliance Strategic Priorities 2026.
In 2020 AUSTRAC worked with government and industry partners to develop the [National Disability Insurance Scheme fraud prevention financial crime guide](https://www.austrac.gov.au/industry-and- business/education-and-resources/publications-and-resources/ndis-fraud-financial-crime-guide). The guide assists reporting entities and government agencies to identify, escalate and respond to financial crime risks associated with the NDIS.
The guide also outlines:
- key financial indicators associated with NDIS fraud and non-compliance
- common fraud and misuse typologies
- practical guidance to improve the quality, consistency and relevance of suspicious matter reporting.
The guide provides financial indicators commonly used to identify NDIS-related fraud, including:
- transaction volumes or values inconsistent with the size or nature of services provided
- rapid movement of NDIS payments through multiple accounts, including personal or unrelated business accounts
- funds sent to family members/associates overseas without a clear service-delivery rationale
- NDIS funds moving between linked companies, family members or associated charities
- payments to related parties without evident service delivery
- use of cash, digital currency or alternative payment methods that reduce financial transparency.
The indicators are risk based and contextual. Individually, they do not establish wrongdoing, but when observed in combination, assist agencies to prioritise inquiry, investigation and intervention.
Recent and ongoing AML/CTF reforms are strengthening AUSTRAC’s ability to detect and respond to fraud against government programs, including the NDIS. Key reform impacts include:
- expansion of AUSTRAC’s regulated population to include additional professional service providers such as accountants, increasing visibility over businesses that can help establish complex financial arrangements
- enhanced reporting and customer due diligence obligations, improving the quality and timeliness of intelligence
- modernisation of regulatory tools to better address emerging risks, including digital payments and virtual assets.
These reforms will enable AUSTRAC and partner agencies to intervene earlier in the financial lifecycle of fraud, reducing harm and improving disruption outcomes.
Yours sincerely
redacted: s47F - personal privacy
Dr John Moss AIM Deputy Chief Executive Officer Intelligence