Submission 3366 — Mr Andrew Hartwell (Attachment 4) — NDIS Future Generations Bill

NDIS Supplier Integrity Policy Packs

Consolidated document

Prepared from the NDIS supplier integrity, fraud and anti-competition reform policy pack suite.

Note: Draft email-template sections have been excluded from this consolidated document.

Included policy packs

1. Captive Market and Overseas Price Arbitrage in NDIS Assistive Technology
2. Differential Pricing and the ‘NDIS Price’ Problem
3. Plan Manager Gatekeeping and Barriers to Cheaper Purchasing
4. Agency-Managed Participants and Restricted Supplier Choice
5. International Reference Pricing for NDIS-Funded Products
6. Misleading ‘NDIS Approved’ and Product-Endorsement Claims
7. Product Bundling, Hidden Margins and Itemised Quote Reform
8. Right-to-Repair and Assistive Technology Maintenance Monopolies
9. Conflict-of-Interest Controls for Assessors, Support Coordinators and Suppliers
10. Shell Companies, Related Parties and Beneficial Ownership in NDIS Supply Chains
11. Digital Marketplaces, Referral Fees and Platform Steering
12. Supplier Fraud, Sham Providers and Evidence-Before-Payment Safeguards
13. Regional Thin Markets and Supplier Exploitation
14. Consumer-Law Enforcement and ACCC/NDIS Commission Coordination
15. National Procurement, Pooled Purchasing and Optional Product Panels
16. Participant Vulnerability, Supported Decision-Making and High-Pressure Sales
17. Data Standards for Product-Level Price Monitoring
18. Scheme Sustainability and Commercial Extraction from Participant Plans

Policy Risk Pack 01: Captive Market and

Overseas Price Arbitrage in NDIS Assistive

Technology

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk NDIS participants may be channelled into Australian supplier pathways even where materially similar assistive technology or disability-related products are available overseas at lower prices. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses captive market and overseas price arbitrage in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis NDIS participants may be channelled into Australian supplier pathways even where materially similar assistive technology or disability-related products are available overseas at lower prices.

A market designed to protect participants may inadvertently protect supplier margins. Overseas manufacturers or distributors may establish Australian business entities or local distribution arrangements and then price products to NDIS expectations rather than ordinary global retail comparators.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Create a safe overseas purchasing pathway for self-managed, plan-managed and agency-managed participants where products meet safety, warranty and clinical suitability requirements.

7. Require product-level international reference pricing for high-cost assistive technology and recurring consumables.

8. Publish guidance distinguishing legitimate Australian compliance/service costs from unjustified NDIS- specific margin inflation.

9. Require quotes to disclose whether the product is globally available, the manufacturer, model number, overseas comparator price and Australian distributor margin where practicable.

6. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of captive market and overseas price arbitrage in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue NDIS participants may be channelled into Australian supplier pathways even where materially similar assistive technology or disability-related products are available overseas at lower prices. A market designed to protect participants may inadvertently protect supplier margins. Overseas manufacturers or distributors may establish Australian business entities or local distribution arrangements and then price products to NDIS expectations rather than ordinary global retail comparators. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

5. Create a safe overseas purchasing pathway for self-managed, plan-managed and agency-managed participants where products meet safety, warranty and clinical suitability requirements.

6. Require product-level international reference pricing for high-cost assistive technology and recurring consumables.

7. Publish guidance distinguishing legitimate Australian compliance/service costs from unjustified NDIS- specific margin inflation.

8. Require quotes to disclose whether the product is globally available, the manufacturer, model number, overseas comparator price and Australian distributor margin where practicable.

Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S4. Treasury media release: NDIS Taskforce exposes providers ripping off NDIS: https://ministers.treasury.gov.au/ministers/andrew-leigh-2022/media-releases/ndis-taskforce-exposes-providers ripping-ndis

Fair Pricing and Australian Consumer Law Taskforce established to address providers charging higher prices to NDIS participants.

S15. Queensland Competition Authority Final Report: Price Disparities for Disability Aids and

Equipment: https://www.atsa.org.au/wp-content/uploads/2021/06/QCA_final-report-med-aids.pdf

Found significant price differences for aids and equipment within Australia and between Australia and overseas internet sources.

S20. NDIS how to make a claim: https://www.ndis.gov.au/participants/working-providers/paying-supports/how make-claim

Self-managed participants can upload evidence, receipts, tax invoices and bank statements for claims.

Policy Risk Pack 02: Differential Pricing and

the ‘NDIS Price’ Problem

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Suppliers may treat NDIS funding as a price signal, charging participants more than non-NDIS customers for equivalent products or services. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses differential pricing and ndis price normalisation in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Suppliers may treat NDIS funding as a price signal, charging participants more than non-NDIS customers for equivalent products or services.

The NDIS price guide can become a target price rather than a ceiling. Participants may be charged at or near the maximum price even where ordinary consumers can obtain the same or similar product for less.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require suppliers to disclose non-NDIS retail prices and any difference from NDIS-facing prices.

7. Adopt a fair-pricing declaration for NDIS suppliers, with audit and penalties for unjustified differential pricing.

8. Empower the ACCC/NDIS Taskforce to conduct mystery-shopping and targeted price-comparison investigations.

9. Build participant-facing price-comparison tools for common goods and services.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of differential pricing and ndis price normalisation in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Suppliers may treat NDIS funding as a price signal, charging participants more than non-NDIS customers for equivalent products or services. The NDIS price guide can become a target price rather than a ceiling. Participants may be charged at or near the maximum price even where ordinary consumers can obtain the same or similar product for less. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

13. Require suppliers to disclose non-NDIS retail prices and any difference from NDIS-facing prices.

14. Adopt a fair-pricing declaration for NDIS suppliers, with audit and penalties for unjustified differential pricing.

15. Empower the ACCC/NDIS Taskforce to conduct mystery-shopping and targeted price-comparison investigations.

16. Build participant-facing price-comparison tools for common goods and services. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S4. Treasury media release: NDIS Taskforce exposes providers ripping off NDIS: https://ministers.treasury.gov.au/ministers/andrew-leigh-2022/media-releases/ndis-taskforce-exposes-providers ripping-ndis

Fair Pricing and Australian Consumer Law Taskforce established to address providers charging higher prices to NDIS participants.

S5. DSS media release: Cracking down on overcharging of NDIS participants: https://ministers.dss.gov.au/media-releases/14236

Taskforce operational to address unfair price hikes for NDIS participants.

S9. NDIS Commission fair pricing: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fair-pricing

Fair pricing described as no major price difference between NDIS participant price and other-customer price.

Policy Risk Pack 03: Plan Manager

Gatekeeping and Barriers to Cheaper

Purchasing

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Plan managers may refuse cheaper non-standard, mainstream or overseas purchases because they are harder to verify, categorise or reimburse. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses plan manager gatekeeping and cheaper purchasing barriers in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Plan managers may refuse cheaper non-standard, mainstream or overseas purchases because they are harder to verify, categorise or reimburse.

Participants may have formal choice and control but practical dependence on risk-averse payment intermediaries. This may push them back to more expensive NDIS-specialist suppliers who understand the system and invoice accordingly.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Issue binding plan-manager guidance on assessing cheaper comparable purchases and overseas suppliers.

7. Require written reasons when a plan manager refuses a lower-cost purchasing option.

8. Create an escalation pathway for value-for-money purchase disputes.

9. Develop standard invoice/evidence templates for international and mainstream retail purchases.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of plan manager gatekeeping and cheaper purchasing barriers in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Plan managers may refuse cheaper non-standard, mainstream or overseas purchases because they are harder to verify, categorise or reimburse. Participants may have formal choice and control but practical dependence on risk averse payment intermediaries. This may push them back to more expensive NDIS-specialist suppliers who understand the system and invoice accordingly. This risk is intensified where participants must act through NDIS specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

21. Issue binding plan-manager guidance on assessing cheaper comparable purchases and overseas suppliers.
22. Require written reasons when a plan manager refuses a lower-cost purchasing option.
23. Create an escalation pathway for value-for-money purchase disputes.
24. Develop standard invoice/evidence templates for international and mainstream retail purchases. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S12. NDIS news: Parliament passes tough new laws to protect NDIS from fraudsters, predators and shonks: https://ndis.gov.au/news/11506-parliament-passes-tough-new-laws-protect-ndis-fraudsters-predators and-shonks

Mandated electronic claim forms and new power to request evidence before claims are paid.

S20. NDIS how to make a claim: https://www.ndis.gov.au/participants/working-providers/paying-supports/how make-claim

Self-managed participants can upload evidence, receipts, tax invoices and bank statements for claims.

Policy Risk Pack 04: Agency-Managed

Participants and Restricted Supplier Choice

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Agency-managed participants may have a narrower supplier pool and less practical ability to use unregistered, mainstream or overseas suppliers. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses agency-managed participants and restricted supplier choice in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Agency-managed participants may have a narrower supplier pool and less practical ability to use unregistered, mainstream or overseas suppliers.

Participants with the least administrative capacity may face the most restricted market access and therefore higher prices. The integrity rationale for registered-provider use may unintentionally create a captive-purchasing pathway.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Establish a safe procurement pathway for agency-managed participants to access lower-cost mainstream and international products through NDIA-facilitated purchasing.

7. Permit limited direct retail procurement for low-risk goods with appropriate evidence.

8. Review whether agency-managed participants pay higher average product prices than self-managed participants.

9. Require registered providers to demonstrate value for money against mainstream comparators.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of agency-managed participants and restricted supplier choice in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Agency-managed participants may have a narrower supplier pool and less practical ability to use unregistered, mainstream or overseas suppliers. Participants with the least administrative capacity may face the most restricted market access and therefore higher prices. The integrity rationale for registered-provider use may unintentionally create a captive-purchasing pathway. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

29. Establish a safe procurement pathway for agency-managed participants to access lower-cost mainstream and international products through NDIA-facilitated purchasing.

30. Permit limited direct retail procurement for low-risk goods with appropriate evidence.

31. Review whether agency-managed participants pay higher average product prices than self-managed participants.

32. Require registered providers to demonstrate value for money against mainstream comparators. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S10. NDIS Commission mandatory registration: https://www.ndiscommission.gov.au/about-us/ndis commission-reform-hub/mandatory-registration

SIL and NDIS digital platform providers required to register from 1 July 2026.

S12. NDIS news: Parliament passes tough new laws to protect NDIS from fraudsters, predators and shonks: https://ndis.gov.au/news/11506-parliament-passes-tough-new-laws-protect-ndis-fraudsters-predators and-shonks

Mandated electronic claim forms and new power to request evidence before claims are paid.

S20. NDIS how to make a claim: https://www.ndis.gov.au/participants/working-providers/paying-supports/how make-claim

Self-managed participants can upload evidence, receipts, tax invoices and bank statements for claims.

Policy Risk Pack 05: International Reference

Pricing for NDIS-Funded Products

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk The scheme lacks systematic international reference pricing for high-cost goods and assistive technology. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses international reference pricing in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis The scheme lacks systematic international reference pricing for high-cost goods and assistive technology.

Without global comparator pricing, the NDIA cannot know whether Australian NDIS-funded prices reflect genuine costs or scheme-enabled price inflation.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Commission a renewed national price-disparities inquiry for disability aids, equipment and assistive technology.

7. Create product categories subject to annual international benchmarking.

8. Use international reference prices to inform maximum claimable amounts and procurement panels.

9. Publish price bands and total lifecycle cost benchmarks, including repairs and servicing.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.

 Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of international reference pricing in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue The scheme lacks systematic international reference pricing for high-cost goods and assistive technology. Without global comparator pricing, the NDIA cannot know whether Australian NDIS-funded prices reflect genuine costs or scheme-enabled price inflation. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

37. Commission a renewed national price-disparities inquiry for disability aids, equipment and assistive technology.

38. Create product categories subject to annual international benchmarking.

39. Use international reference prices to inform maximum claimable amounts and procurement panels.

40. Publish price bands and total lifecycle cost benchmarks, including repairs and servicing. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.

S15. Queensland Competition Authority Final Report: Price Disparities for Disability Aids and

Equipment: https://www.atsa.org.au/wp-content/uploads/2021/06/QCA_final-report-med-aids.pdf

Found significant price differences for aids and equipment within Australia and between Australia and overseas internet sources.

Policy Risk Pack 06: Misleading ’NDIS

Approved’ and Product-Endorsement Claims

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Suppliers may use terms such as ‘NDIS approved’, ‘NDIS registered product’ or ‘NDIS funded’ in ways that imply official endorsement or guaranteed funding. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses misleading ndis approval claims in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Suppliers may use terms such as ‘NDIS approved’, ‘NDIS registered product’ or ‘NDIS funded’ in ways that imply official endorsement or guaranteed funding.

Participants may believe a product has been assessed for value, suitability or safety by the NDIS when it has not. This exploits public trust and can distort purchasing decisions.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Prohibit product-level NDIS endorsement language unless expressly authorised.

7. Require standardised wording for NDIS-related marketing and supplier websites.

8. Increase ACCC enforcement and public naming of misleading NDIS claims.

9. Create participant-facing warnings about common NDIS marketing misrepresentations.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of misleading ndis approval claims in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Suppliers may use terms such as ‘NDIS approved’, ‘NDIS registered product’ or ‘NDIS funded’ in ways that imply official endorsement or guaranteed funding. Participants may believe a product has been assessed for value, suitability or safety by the NDIS when it has not. This exploits public trust and can distort purchasing decisions. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

45. Prohibit product-level NDIS endorsement language unless expressly authorised.
46. Require standardised wording for NDIS-related marketing and supplier websites.
47. Increase ACCC enforcement and public naming of misleading NDIS claims.
48. Create participant-facing warnings about common NDIS marketing misrepresentations. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S16. ACCC Thermomix NDIS endorsement penalties: https://www.accc.gov.au/media-release/thermomix pays-penalties-for-allegedly-misleading-customers-over-ndis-endorsement

ACCC infringement notices over alleged false or misleading NDIS endorsement representations.

S17. ACCC Bedshed NDIS endorsement penalties: https://www.accc.gov.au/media-release/bedshed-pays penalties-for-allegedly-misleading-customers-over-ndis-endorsement

ACCC infringement notices over alleged NDIS approval/evaluation claims.

S18. ACCC WeFlex NDIS funding advertisement penalty: https://www.accc.gov.au/media-release/fitness support-company-pays-penalty-over-if-you-have-ndis-funding-its-covered-ad

2026 ACCC penalty over alleged misleading statement about NDIS funding coverage.

S19. NDIS provider responsibilities: https://www.ndis.gov.au/providers/working-provider/provider responsibilities/what-are-responsibilities-provider

Providers must comply with Australian Consumer Law and the Competition and Consumer Act 2010.

Policy Risk Pack 07: Product Bundling,

Hidden Margins and Itemised Quote Reform

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Suppliers may bundle products, assessment, delivery, installation, servicing, warranty and administration in ways that obscure the true product price. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses bundling and hidden margins in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Suppliers may bundle products, assessment, delivery, installation, servicing, warranty and administration in ways that obscure the true product price.

Bundling makes comparison difficult and can hide inflated margins. Participants may be unable to tell whether they are paying for a product, clinical expertise, freight, warranty or administration.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require itemised quotes above a dollar threshold for assistive technology, home modifications and recurring consumables.

7. Mandate separation of product cost, labour, clinical assessment, administration, delivery, servicing and warranty.

8. Create standard quote templates for NDIS-funded products.

9. Use data analytics to flag excessive margins or recurring add-on charges.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of bundling and hidden margins in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Suppliers may bundle products, assessment, delivery, installation, servicing, warranty and administration in ways that obscure the true product price. Bundling makes comparison difficult and can hide inflated margins. Participants may be unable to tell whether they are paying for a product, clinical expertise, freight, warranty or administration. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

53. Require itemised quotes above a dollar threshold for assistive technology, home modifications and recurring consumables.

54. Mandate separation of product cost, labour, clinical assessment, administration, delivery, servicing and warranty.

55. Create standard quote templates for NDIS-funded products.

56. Use data analytics to flag excessive margins or recurring add-on charges. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.

Policy Risk Pack 08: Right-to-Repair and

Assistive Technology Maintenance

Monopolies

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Participants may be locked into authorised repairers, proprietary parts or original suppliers after purchasing assistive technology. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses right-to-repair and maintenance monopolies in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Participants may be locked into authorised repairers, proprietary parts or original suppliers after purchasing assistive technology.

A product may appear competitively priced at purchase but become monopolistic at the repair stage. Delayed repairs can trap people at home or without communication, mobility or personal care equipment.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Introduce right-to-repair rules for NDIS-funded essential assistive technology.

7. Require parts availability, repair manuals and independent qualified repairer access.

8. Set maximum repair response times for essential mobility, communication and personal care equipment.

9. Include lifecycle servicing and repair costs in value-for-money assessment.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of right-to-repair and maintenance monopolies in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Participants may be locked into authorised repairers, proprietary parts or original suppliers after purchasing assistive technology. A product may appear competitively priced at purchase but become monopolistic at the repair stage. Delayed repairs can trap people at home or without communication, mobility or personal care equipment. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

61. Introduce right-to-repair rules for NDIS-funded essential assistive technology.
62. Require parts availability, repair manuals and independent qualified repairer access.
63. Set maximum repair response times for essential mobility, communication and personal care equipment.
64. Include lifecycle servicing and repair costs in value-for-money assessment. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S15. Queensland Competition Authority Final Report: Price Disparities for Disability Aids and

Equipment: https://www.atsa.org.au/wp-content/uploads/2021/06/QCA_final-report-med-aids.pdf

Found significant price differences for aids and equipment within Australia and between Australia and overseas internet sources.

Policy Risk Pack 09: Conflict-of-Interest

Controls for Assessors, Support Coordinators

and Suppliers

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk The same provider network may assess, recommend, supply, install, service or coordinate supports for a participant. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses conflict-of-interest controls in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis The same provider network may assess, recommend, supply, install, service or coordinate supports for a participant.

Participants may be steered toward suppliers or products because of financial relationships, preferred lists, referral arrangements or related-party structures rather than genuine need or value.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require written conflict-of-interest declarations for high-cost products and supplier referrals.

7. Mandate at least two comparable quotes unless clinically inappropriate or urgent.

8. Prohibit undisclosed referral fees or commissions in NDIS-funded supply chains.

9. Audit related-party patterns between support coordinators, assessors and suppliers.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of conflict-of-interest controls in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue The same provider network may assess, recommend, supply, install, service or coordinate supports for a participant. Participants may be steered toward suppliers or products because of financial relationships, preferred lists, referral arrangements or related-party structures rather than genuine need or value. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

69. Require written conflict-of-interest declarations for high-cost products and supplier referrals.
70. Mandate at least two comparable quotes unless clinically inappropriate or urgent.
71. Prohibit undisclosed referral fees or commissions in NDIS-funded supply chains.
72. Audit related-party patterns between support coordinators, assessors and suppliers. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S8. NDIS Commission fraud reporting: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fraud

Fraud Reporting and Scams Helpline and fraudreporting@ndis.gov.au.

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S19. NDIS provider responsibilities: https://www.ndis.gov.au/providers/working-provider/provider responsibilities/what-are-responsibilities-provider

Providers must comply with Australian Consumer Law and the Competition and Consumer Act 2010.

Policy Risk Pack 10: Shell Companies,

Related Parties and Beneficial Ownership in

NDIS Supply Chains

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Supplier and provider misconduct may be hidden through related companies, cleanskin businesses, phoenixing, subcontracting chains or nominee directors. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses shell companies and beneficial ownership in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Supplier and provider misconduct may be hidden through related companies, cleanskin businesses, phoenixing, subcontracting chains or nominee directors.

Bad actors may re-enter the market, acquire registered businesses, obscure related-party relationships or spread activity across multiple entities.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require beneficial-ownership disclosure for registered providers and high-value NDIS suppliers.

7. Link NDIS registration to ASIC director histories, ABNs, tax compliance, sanctions and complaints history.

8. Create sale-of-business notification and approval rules for registered NDIS businesses.

9. Develop risk flags for common ownership across assessment, coordination, supply and repair entities.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of shell companies and beneficial ownership in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Supplier and provider misconduct may be hidden through related companies, cleanskin businesses, phoenixing, subcontracting chains or nominee directors. Bad actors may re-enter the market, acquire registered businesses, obscure related-party relationships or spread activity across multiple entities. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

77. Require beneficial-ownership disclosure for registered providers and high-value NDIS suppliers.
78. Link NDIS registration to ASIC director histories, ABNs, tax compliance, sanctions and complaints history.
79. Create sale-of-business notification and approval rules for registered NDIS businesses.
80. Develop risk flags for common ownership across assessment, coordination, supply and repair entities. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S6. NDIS Integrity and Safeguarding: https://www.ndis.gov.au/ndis-laws/integrity-and-safeguarding

National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026 information.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S8. NDIS Commission fraud reporting: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fraud

Fraud Reporting and Scams Helpline and fraudreporting@ndis.gov.au.

S10. NDIS Commission mandatory registration: https://www.ndiscommission.gov.au/about-us/ndis commission-reform-hub/mandatory-registration

SIL and NDIS digital platform providers required to register from 1 July 2026.

S11. NDIS news: Crackdown on sales of NDIS businesses as mandatory registration set to expand from 1 July: https://www.ndis.gov.au/news/11596-crackdown-sales-ndis-businesses-mandatory-registration-set-expand 1-july

New obligations on NDIS business sales aimed at cleanskin registered businesses.

S12. NDIS news: Parliament passes tough new laws to protect NDIS from fraudsters, predators and shonks: https://ndis.gov.au/news/11506-parliament-passes-tough-new-laws-protect-ndis-fraudsters-predators and-shonks

Mandated electronic claim forms and new power to request evidence before claims are paid.

Policy Risk Pack 11: Digital Marketplaces,

Referral Fees and Platform Steering

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating Medium to High Primary risk Online marketplaces and NDIS-facing platforms may steer participants toward particular providers through ranking logic, referral payments, sponsored listings or preferred supplier arrangements. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses digital marketplaces and platform steering in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Online marketplaces and NDIS-facing platforms may steer participants toward particular providers through ranking logic, referral payments, sponsored listings or preferred supplier arrangements.

Participants may believe they are comparing neutral options while actually being directed through commercial incentives. This is especially risky for people with cognitive disability, low digital literacy or urgent need.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require disclosure of referral fees, commissions, sponsorships and platform ranking logic.

7. Register and audit NDIS digital platforms that influence provider choice.

8. Prohibit dark patterns and misleading neutrality claims in NDIS marketplaces.

9. Create accessibility standards for digital marketplaces and comparison tools.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of digital marketplaces and platform steering in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Online marketplaces and NDIS-facing platforms may steer participants toward particular providers through ranking logic, referral payments, sponsored listings or preferred supplier arrangements. Participants may believe they are comparing neutral options while actually being directed through commercial incentives. This is especially risky for people with cognitive disability, low digital literacy or urgent need. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

85. Require disclosure of referral fees, commissions, sponsorships and platform ranking logic.
86. Register and audit NDIS digital platforms that influence provider choice.
87. Prohibit dark patterns and misleading neutrality claims in NDIS marketplaces.
88. Create accessibility standards for digital marketplaces and comparison tools. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S10. NDIS Commission mandatory registration: https://www.ndiscommission.gov.au/about-us/ndis commission-reform-hub/mandatory-registration

SIL and NDIS digital platform providers required to register from 1 July 2026.

S11. NDIS news: Crackdown on sales of NDIS businesses as mandatory registration set to expand from 1 July: https://www.ndis.gov.au/news/11596-crackdown-sales-ndis-businesses-mandatory-registration-set-expand 1-july

New obligations on NDIS business sales aimed at cleanskin registered businesses.

S19. NDIS provider responsibilities: https://www.ndis.gov.au/providers/working-provider/provider responsibilities/what-are-responsibilities-provider

Providers must comply with Australian Consumer Law and the Competition and Consumer Act 2010.

Policy Risk Pack 12: Supplier Fraud, Sham

Providers and Evidence-Before-Payment

Safeguards

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Fraudulent or sham suppliers may claim for goods or services not provided, exaggerate claims, misuse participant details or exploit payment processes. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses supplier fraud and evidence-before-payment safeguards in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Fraudulent or sham suppliers may claim for goods or services not provided, exaggerate claims, misuse participant details or exploit payment processes.

Fraud reduces funds available for legitimate supports and damages public trust. However, anti-fraud controls may also delay legitimate purchases if not designed around participant need.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Implement evidence-before-payment with clear participant hardship exemptions and rapid escalation.

7. Use product-level and provider-level anomaly detection while preserving human review.

8. Strengthen reporting pathways and protect participants who raise concerns.

9. Distinguish criminal fraud from poor value and from participant misunderstanding.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of supplier fraud and evidence-before-payment safeguards in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Fraudulent or sham suppliers may claim for goods or services not provided, exaggerate claims, misuse participant details or exploit payment processes. Fraud reduces funds available for legitimate supports and damages public trust. However, anti-fraud controls may also delay legitimate purchases if not designed around participant need. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

93. Implement evidence-before-payment with clear participant hardship exemptions and rapid escalation.
94. Use product-level and provider-level anomaly detection while preserving human review.
95. Strengthen reporting pathways and protect participants who raise concerns.
96. Distinguish criminal fraud from poor value and from participant misunderstanding. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S6. NDIS Integrity and Safeguarding: https://www.ndis.gov.au/ndis-laws/integrity-and-safeguarding

National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026 information.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S8. NDIS Commission fraud reporting: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fraud

Fraud Reporting and Scams Helpline and fraudreporting@ndis.gov.au.

S12. NDIS news: Parliament passes tough new laws to protect NDIS from fraudsters, predators and shonks: https://ndis.gov.au/news/11506-parliament-passes-tough-new-laws-protect-ndis-fraudsters-predators and-shonks

Mandated electronic claim forms and new power to request evidence before claims are paid.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

Policy Risk Pack 13: Regional Thin Markets

and Supplier Exploitation

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating Medium to High Primary risk Regional, remote and First Nations communities often have fewer suppliers, higher travel costs and weaker market competition. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses regional thin markets in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Regional, remote and First Nations communities often have fewer suppliers, higher travel costs and weaker market competition.

Thin markets can create both under-supply and overpricing. Without transparent benchmarking it is difficult to separate legitimate remote delivery costs from opportunistic charging.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Develop regional price benchmarks that identify legitimate cost loadings separately from excessive margins.

7. Support pooled purchasing, mobile repair services and local provider development in thin markets.

8. Fund independent advocacy and market-navigation supports in remote communities.

9. Use active commissioning where ordinary competition will not emerge.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of regional thin markets in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Regional, remote and First Nations communities often have fewer suppliers, higher travel costs and weaker market competition. Thin markets can create both under-supply and overpricing. Without transparent benchmarking it is difficult to separate legitimate remote delivery costs from opportunistic charging. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

101. Develop regional price benchmarks that identify legitimate cost loadings separately from excessive margins.

102. Support pooled purchasing, mobile repair services and local provider development in thin markets.

103. Fund independent advocacy and market-navigation supports in remote communities.

104. Use active commissioning where ordinary competition will not emerge. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.

S21. NDIS Review remote and First Nations market challenges: https://www.ndisreview.gov.au/resources/paper/improving-access-supports-remote-and-first-nations communities/1-market-challenges

Describes uneven market development and challenges across participants, supports and locations.

S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

Policy Risk Pack 14: Consumer-Law

Enforcement and ACCC/NDIS Commission

Coordination

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk NDIS supplier misconduct can fall between the NDIA, NDIS Commission, ACCC, ASIC, ATO, state fair trading agencies and police. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses consumer-law enforcement coordination in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis NDIS supplier misconduct can fall between the NDIA, NDIS Commission, ACCC, ASIC, ATO, state fair trading agencies and police.

Fragmented jurisdiction means a supplier may be too commercial for safeguarding enforcement, too small for ACCC priority, too complex for individual complaints and not clearly criminal.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Create a joint NDIS supplier-market integrity unit with triage powers across regulators.

7. Establish shared data protocols for pricing complaints, fraud indicators and provider sanctions.

8. Publish annual enforcement outcomes by category: fraud, misleading conduct, unfair terms, overpricing and unsafe supply.

9. Fund proactive market studies rather than relying solely on participant complaints.

6. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of consumer-law enforcement coordination in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue NDIS supplier misconduct can fall between the NDIA, NDIS Commission, ACCC, ASIC, ATO, state fair trading agencies and police. Fragmented jurisdiction means a supplier may be too commercial for safeguarding enforcement, too small for ACCC priority, too complex for individual complaints and not clearly criminal. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

109. Create a joint NDIS supplier-market integrity unit with triage powers across regulators.

110. Establish shared data protocols for pricing complaints, fraud indicators and provider sanctions.

111. Publish annual enforcement outcomes by category: fraud, misleading conduct, unfair terms, overpricing and unsafe supply.

112. Fund proactive market studies rather than relying solely on participant complaints. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S4. Treasury media release: NDIS Taskforce exposes providers ripping off NDIS: https://ministers.treasury.gov.au/ministers/andrew-leigh-2022/media-releases/ndis-taskforce-exposes-providers ripping-ndis

Fair Pricing and Australian Consumer Law Taskforce established to address providers charging higher prices to NDIS participants.

S5. DSS media release: Cracking down on overcharging of NDIS participants: https://ministers.dss.gov.au/media-releases/14236

Taskforce operational to address unfair price hikes for NDIS participants.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S8. NDIS Commission fraud reporting: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fraud

Fraud Reporting and Scams Helpline and fraudreporting@ndis.gov.au.

Policy Risk Pack 15: National Procurement,

Pooled Purchasing and Optional Product

Panels

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating Medium to High Primary risk The NDIS often purchases products one participant at a time despite national purchasing power. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses national procurement and optional product panels in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis The NDIS often purchases products one participant at a time despite national purchasing power.

Fragmented individual purchasing may preserve choice but waste bargaining power, leaving participants exposed to retail or inflated prices.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Establish optional national product panels for high-volume and high-cost goods.

7. Use pooled purchasing without forcing participants into a single supplier.

8. Publish panel prices as reference points for non-panel purchases.

9. Allow participants to choose non-panel products where clinically justified or better value.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of national procurement and optional product panels in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue The NDIS often purchases products one participant at a time despite national purchasing power. Fragmented individual purchasing may preserve choice but waste bargaining power, leaving participants exposed to retail or inflated prices. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

117. Establish optional national product panels for high-volume and high-cost goods.
118. Use pooled purchasing without forcing participants into a single supplier.
119. Publish panel prices as reference points for non-panel purchases.
120. Allow participants to choose non-panel products where clinically justified or better value. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.

S15. Queensland Competition Authority Final Report: Price Disparities for Disability Aids and

Equipment: https://www.atsa.org.au/wp-content/uploads/2021/06/QCA_final-report-med-aids.pdf

Found significant price differences for aids and equipment within Australia and between Australia and overseas internet sources.

Policy Risk Pack 16: Participant Vulnerability,

Supported Decision-Making and High-

Pressure Sales

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Some participants face high-pressure sales, dependence on providers, cognitive or communication barriers, isolation, family violence or low consumer literacy. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses participant vulnerability and high-pressure sales in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Some participants face high-pressure sales, dependence on providers, cognitive or communication barriers, isolation, family violence or low consumer literacy.

Ordinary consumer consent may not be meaningful where a participant cannot compare options, challenge a provider, understand contractual terms or refuse pressure.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Require plain-English quotes and cooling-off periods for non-urgent high-cost products.

7. Fund independent procurement advocacy for vulnerable participants.

8. Prohibit high-pressure sales tactics and unsolicited NDIS-funded product marketing.

9. Introduce supported decision-making safeguards for high-value purchases.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.

 Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of participant vulnerability and high-pressure sales in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Some participants face high-pressure sales, dependence on providers, cognitive or communication barriers, isolation, family violence or low consumer literacy. Ordinary consumer consent may not be meaningful where a participant cannot compare options, challenge a provider, understand contractual terms or refuse pressure. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

125. Require plain-English quotes and cooling-off periods for non-urgent high-cost products.
126. Fund independent procurement advocacy for vulnerable participants.
127. Prohibit high-pressure sales tactics and unsolicited NDIS-funded product marketing.
128. Introduce supported decision-making safeguards for high-value purchases. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S2. ACCC consumer rights and the NDIS: https://www.accc.gov.au/consumers/specific-products-and activities/consumer-rights-and-the-NDIS

ACCC consumer guidance on NDIS pricing, unfair terms, misleading conduct and scams.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S8. NDIS Commission fraud reporting: https://www.ndiscommission.gov.au/rules-and-standards/ndis-code conduct/fraud

Fraud Reporting and Scams Helpline and fraudreporting@ndis.gov.au.

S19. NDIS provider responsibilities: https://www.ndis.gov.au/providers/working-provider/provider responsibilities/what-are-responsibilities-provider

Providers must comply with Australian Consumer Law and the Competition and Consumer Act 2010.

Policy Risk Pack 17: Data Standards for

Product-Level Price Monitoring

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Current claims and pricing data may not capture enough product-level detail to detect inflated margins, repeated overpricing or supplier concentration. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses product-level data standards in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Current claims and pricing data may not capture enough product-level detail to detect inflated margins, repeated overpricing or supplier concentration.

The scheme may see expenditure but not value. Without model numbers, serial numbers, product categories, country of origin, warranty terms and comparator prices, market analytics remain weak.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Introduce a product-level data standard for high-cost goods and recurring consumables.

7. Require model number, manufacturer, supplier, warranty, repair obligations and itemised charges in claims data.

8. Create analytics to detect price outliers, repeated add-ons and supplier clustering.

9. Share de-identified market intelligence with regulators and participants.

10. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.

 Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of product-level data standards in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Current claims and pricing data may not capture enough product-level detail to detect inflated margins, repeated overpricing or supplier concentration. The scheme may see expenditure but not value. Without model numbers, serial numbers, product categories, country of origin, warranty terms and comparator prices, market analytics remain weak. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

133. Introduce a product-level data standard for high-cost goods and recurring consumables.

134. Require model number, manufacturer, supplier, warranty, repair obligations and itemised charges in claims data.

135. Create analytics to detect price outliers, repeated add-ons and supplier clustering.

136. Share de-identified market intelligence with regulators and participants. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S6. NDIS Integrity and Safeguarding: https://www.ndis.gov.au/ndis-laws/integrity-and-safeguarding

National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026 information.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S12. NDIS news: Parliament passes tough new laws to protect NDIS from fraudsters, predators and shonks: https://ndis.gov.au/news/11506-parliament-passes-tough-new-laws-protect-ndis-fraudsters-predators and-shonks

Mandated electronic claim forms and new power to request evidence before claims are paid.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.

Policy Risk Pack 18: Scheme Sustainability

and Commercial Extraction from Participant

Plans

NDIS supplier integrity, fraud and anti-competition reform suite

Prepared 8 July 2026

At-a-glance

Risk rating High

Primary risk Supplier overcharging, fraud and anti-competitive conduct can be politically misattributed to participant need rather than market extraction. Policy frame Participant choice and control cannot operate as a substitute for market regulation where participants face information asymmetry, disability-related urgency, administrative gatekeeping or captive supplier pathways. Core ask Strengthen supplier transparency, competition, evidence standards and enforcement while preserving safe participant choice.

1. Ministerial issue This pack addresses scheme sustainability and commercial extraction in the NDIS supplier market. The immediate policy problem is that the NDIS can create a highly funded purchasing environment without always giving participants the practical tools, market power or regulatory protection required to obtain fair value. Where participants must rely on NDIS-specific suppliers, assessors, support coordinators, plan managers or claims rules, conventional consumer choice may become constrained by disability-related need and administrative complexity.

The risk is not only fiscal. Overcharging, misleading conduct, hidden margins and anti-competitive supply-chain behaviour reduce the supports available to participants, erode public trust in the scheme, and encourage political narratives that blame participants for cost growth rather than examining commercial extraction from participant plans.

2. Specific risk analysis Supplier overcharging, fraud and anti-competitive conduct can be politically misattributed to participant need rather than market extraction.

Public debate may blame people with disability for NDIS cost growth while commercial practices that extract money from plans receive less scrutiny.

This issue should be treated as a participant rights problem, a consumer law problem and a scheme sustainability problem. A person with disability should not have to become a sophisticated procurement officer in order to avoid being overcharged for equipment, supports or services that are necessary for ordinary life.

The policy challenge is to protect participants from fraud and unsafe supply without forcing them into a narrow domestic provider market. Integrity controls should not make mainstream retail, independent providers or cheaper international purchasing practically impossible where safety, suitability and warranty risks can be managed.

3. Evidence and policy context The NDIS Pricing Schedule describes appropriate and reasonable maximum prices for NDIS supports. In practice, maximum prices can become market reference points where competition is weak or participants have limited bargaining power.

The ACCC has identified NDIS-specific consumer harms, including participants potentially paying higher prices for goods or services compared with non-NDIS consumers, misleading claims and unfair contract terms.

The Fair Pricing and Australian Consumer Law Taskforce was established to address providers charging higher prices to NDIS participants compared with people not on the NDIS.

The NDIS Integrity and Safeguarding Act 2026, mandatory registration reforms and electronic claims reforms strengthen integrity controls, but may also change supplier market dynamics and participant purchasing pathways.

The Queensland Competition Authority has previously found significant price differences for disability aids and equipment within Australia and between Australia and overseas internet sources.

4. Legislative and regulatory hooks  National Disability Insurance Scheme Act 2013 and related rules, pricing arrangements and plan-management arrangements.  National Disability Insurance Scheme Amendment (Integrity and Safeguarding) Act 2026.  NDIS Quality and Safeguards Commission provider registration, fair pricing, Code of Conduct and enforcement functions.  Competition and Consumer Act 2010 and Australian Consumer Law protections against misleading conduct, unconscionable conduct, unfair contract terms and anti-competitive conduct.  Corporations, tax, ABN, product safety and import frameworks relevant to supplier identity, beneficial ownership and product safety.

5. Recommended policy actions

6. Frame NDIS sustainability reform around market integrity as well as participant eligibility.

7. Report annual estimated savings from supplier-market reforms separately from participant support reductions.

8. Protect reasonable and necessary supports while targeting fraud, overcharging and anti-competitive conduct.

9. Establish an NDIS Market Integrity Charter setting supplier expectations and enforcement consequences.

6. Recommended amendments or administrative reforms  Require a formal NDIS Supplier Market Integrity Framework covering fair pricing, product transparency, conflict-of-interest controls, related-party disclosure, overseas comparators and enforcement escalation.  Introduce a product-level data standard for high-cost goods and recurring consumables, including model numbers, manufacturer, warranty, country of origin, itemised components and supplier identifiers.  Require regulators to report annually on NDIS supplier misconduct, including fraud, misleading NDIS endorsement claims, differential pricing, unfair contract terms, high-pressure sales, unsafe supply and anti competitive conduct.  Create a safe value-for-money purchasing pathway that allows participants to access mainstream and overseas products where clinical suitability, safety, warranty and evidence requirements are satisfied.  Ensure provider registration and evidence-before-payment reforms are risk-based and do not unintentionally consolidate the market around high-cost incumbents.

7. Suggested ministerial talking points  NDIS sustainability must address supplier behaviour, not only participant access and plan size.  Participants should not be forced into a captive domestic market where the same product costs more because it is being charged against the NDIS.  Fair pricing requires transparency: participants should know the ordinary retail price, the NDIS-facing price, and the reason for any difference.  Anti-fraud reforms must be designed so they do not block safe, cheaper and mainstream purchasing options.  Every dollar lost to fraud, inflated margins or anti-competitive conduct is a dollar unavailable for independence, safety and participation.

Two-page ministerial brief

Purpose

To advise on the risk of scheme sustainability and commercial extraction in the NDIS supplier market and identify targeted reforms to protect participants, improve market integrity and reduce avoidable scheme expenditure.

Key issue Supplier overcharging, fraud and anti-competitive conduct can be politically misattributed to participant need rather than market extraction. Public debate may blame people with disability for NDIS cost growth while commercial practices that extract money from plans receive less scrutiny. This risk is intensified where participants must act through NDIS-specific claims, registered providers, plan managers, assessors or support coordinators.

Why it matters  Participants may pay more than ordinary consumers for comparable goods and services.  Overcharging and market extraction reduce support available to participants and damage public trust in the NDIS.  Fraud controls that are not carefully designed may unintentionally strengthen incumbent suppliers by making cheaper purchases administratively difficult.  Anti-competitive structures can be hidden behind complexity, bundling, related-party networks and product specific jargon.

Recommended decision Agree to develop a targeted NDIS supplier-market integrity reform stream, including fair-pricing disclosure, international reference pricing, conflict-of-interest controls, product-level claims data, and coordinated ACCC/NDIS Commission enforcement.

Priority actions

141. Frame NDIS sustainability reform around market integrity as well as participant eligibility.

142. Report annual estimated savings from supplier-market reforms separately from participant support reductions.

143. Protect reasonable and necessary supports while targeting fraud, overcharging and anti-competitive conduct.

144. Establish an NDIS Market Integrity Charter setting supplier expectations and enforcement consequences. Risk if no action is taken The NDIS will remain vulnerable to supplier overcharging, avoidable fraud, inflated product costs, weak competition and public criticism that misattributes market extraction to participant support need.

Source notes S1. NDIS Pricing Arrangements and Price Limits: https://www.ndis.gov.au/providers/pricing-and payments/pricing/pricing-arrangements

Sets out appropriate and reasonable maximum prices for NDIS supports from 1 July 2026.

S3. ACCC media release: Australians living with disability at risk of exploitation by NDIS providers breaching consumer laws: https://www.accc.gov.au/media-release/australians-living-with-disability-at-risk-of exploitation-by-ndis-providers-breaching-consumer-laws

2026 ACCC material on NDIS Taskforce harms, higher prices and consumer law breaches.

S4. Treasury media release: NDIS Taskforce exposes providers ripping off NDIS: https://ministers.treasury.gov.au/ministers/andrew-leigh-2022/media-releases/ndis-taskforce-exposes-providers ripping-ndis

Fair Pricing and Australian Consumer Law Taskforce established to address providers charging higher prices to NDIS participants.

S7. NDIS fraud and non-compliance: https://www.ndis.gov.au/governance/fraud-and-non-compliance

Fraud Fusion Taskforce and Government measures to detect and stop fraud.

S13. NDIS Review Final Report: https://www.ndisreview.gov.au/sites/default/files/resource/download/working-

together-ndis-review-final-report.pdf

Recommends governments take a more active stewardship role in NDIS markets and change incentives.

S14. NDIS Review pricing and payment approaches paper: https://www.ndisreview.gov.au/sites/default/files/resource/download/pricing-payments_0.pdf

Describes NDIS market-based approach and pricing/payment issues.