Concerns about NDIS reforms impacting access to support (DRO advocacy) | External submission

National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 Submission 369

National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026

Community Affairs Legislation Committee 1 June 2026

About ACOSS

The Australian Council of Social Service (ACOSS) is a national voice in support of people affected by poverty, disadvantage and inequality and the peak body for the community services and civil society sector.

ACOSS consists of a network of approximately 4000 organisations and individuals across Australia in metropolitan, regional and remote areas. This includes eight Disability Representative Organisations, as well as a wide range of disability service providers, as national members.

Our vision is an end to poverty in all its forms; economies that are fair, sustainable and resilient; and communities that are just, peaceful and inclusive.

Summary

ACOSS recognises the need to reform the NDIS (the Scheme), ensuring it provides sustainable quality services for people with disability and allowing them to lead dignified lives of their own choosing. We support an effective and well regulated scheme that continues to have strong community support. We note that ACOSS’ Disability Representative Organisations (DROs) also support the need for reform of this scheme.

However, it is deeply concerning that despite the collective desire to strengthen the NDIS, the proposed reforms have not been co-designed with the disability community, their advocates or representative organisations. Further, there has barely been any meaningful engagement or discussion with those same stakeholders on such sweeping and significant changes. Given this, ACOSS is seriously concerned about both the substance of the National Disability

Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill,

and the approach taken for progressing it through Parliament.

The NDIS Review proposed structural reform of the Scheme that appears largely ignored in the Bill. The NDIS Review sought to rebalance the current disability services system between the NDIS and broader related services, between individual empowerment and process-driven complexity and between market based personalised approaches and those that build a collective social capital

Submission 369

within the community. The Government’s reforms in this Bill do not reflect a rebalancing of these elements. Instead, the changes predominantly target individual eligibility and packages of support while doing little to address market failures or improve service quality – both key priorities identified by the NDIS Review.

The Bill focuses NDIS reforms on the fiscal sustainability of the Scheme itself. It makes financial sustainability not only a key goal of the Scheme, but a critical factor for both Ministerial and agency decision-makers, dramatically departing from the current emphasis on reasonable and necessary supports, within a rights framework. As such, the Bill would create a dangerous precedent where decisions about individual access to services and supports are determined by reference to Budget policy goals rather than the needs and priorities of the people accessing services.

The risks of getting these reforms wrong is high and potential consequences catastrophic. The NDIS cuts are the single biggest cost-reduction measure in the 2026-27 Federal Budget, dwarfing in scale the combined impact of the proposed changes to negative gearing, capital gains tax and trust reforms. The Bill, combined with the deep, ongoing cuts in this Budget, mean many people with disability, including those with high support needs, will have poorer quality of life, less independence and reduced opportunity for social and community interaction. This is likely to translate into reduced workforce participation for people with disability and greater reliance on income support.

It is estimated that up to 300,000 people may lose access to the scheme in coming years while new support schemes are being developed from scratch, and while state and territory governments rebuild lost institutional capacity to deliver disability support services. Governments must ensure that there are no service gaps in the transition and maintain NDIS support until other service systems are fully operational.

More broadly, the proposed changes will have major flow-on impacts to other services such as health, income support and employment while also shifting the cost and responsibility of care and support to families and unpaid carers. There are serious concerns that women will be most affected by an increased reliance on informal carers.

Recommendations

Recommendation 1: Parliament to defer Bill for further, detailed inquiry to provide greater scrutiny of the proposed changes and more adequately allow input from the wider disability community. Recommendation 2: Government should commit to authentic co-design, through processes that are participative, inclusive, respectful, centred on lived experience and lived expertise, iterative and outcomes focused.

Submission 369

Recommendation 3: Retain the focus in the NDIS Act on a rights-based approach to reasonable and necessary supports for people. Fiscal impacts should not be explicitly included in the Act’s objects.

Recommendation  4:  Restrain enhanced  Ministerial powers by  improving

parliamentary scrutiny and safeguards including:

•  Limiting reliance on  legislative instruments for key policy decisions,

ensuring that nothing restricting access or funding sits in legislative instruments;

Ensuring all major policy settings are in the primary legislation – the Act, and not in the rules;
Imposing stronger limits and review on expanded Ministerial powers including those in Schedule 5, item 1
Ensuring genuine consultation before Ministerial rules are made. Recommendation 5: The Bill should be subjected to a comprehensive, public gender impact analysis and co-design of gender-responsive reforms with women, girls and gender-diverse people with disability. Recommendation 6: The Bill should not be legislated in the absence of a whole-of-government Automated Decision Making (ADM) Framework, and without further information about the proposed use of ADM within the Scheme.

Introduction ACOSS recognises the need for reform of the NDIS to ensure it provides sustainable quality services for people with disability and maintains community confidence in the integrity and effectiveness of the scheme. In this submission, we express our serious concerns about both the process and substance of the proposed NDIS reforms and legislation. Despite acknowledgement by many disability representatives of the problems with the current scheme and willingness to work constructively with Government to rebalance the system, the Government has not co-designed these proposals, nor engaged in any meaningful engagement with those directly affected. This flies in the face of a stated commitment to empower people with disability and recognise their agency and expertise. Our submission outlines several critical issues:
The scale of the program cuts proposed and likely harm;
The shift away from a rights framework to centring fiscal ‘sustainability’ as a key goal for decision-makers;
The extraordinary ministerial discretion proposed to reduce supports across whole categories of support;
The likely adverse gender impacts; and
The failure to address market failures in the targeting of individual eligibility and support packages.

Submission 369

ACOSS strongly supports the submissions, and ongoing advocacy and leadership of our national member Disability Representative Organisations (DROs), including:

Inclusion Australia;
People with Disability Australia;
Australian Federation of Disability Organisations;
Children and Young People with Disability;
National Ethnic Disability Alliance;
Women with Disability;
Australian Autism Alliance; and
National Mental Health Consumer Alliance. We recommend that Committee seriously consider their contributions to the Inquiry. Further detail is set out below.

Proposed NDIS cuts are severe The proposed changes would reduce NDIS spending by $38 billion over the forward estimates, making this the single biggest measure in the Budget. As E61 point out, this is also the biggest single program cut in Australian history, estimating its impact as a $250 billion reduction over a decade. The Committee must explicitly acknowledge the magnitude of these cuts as it determines the lasting impact they will have on the life and livelihood of the disability community. Figure 1: Budget measures by size

Source: E61 and Budget 2026-27

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Further, the Commonwealth’s fiscal sustainability strategy remains unbalanced, relying on deep and lasting NDIS cuts over further reform on overly generous tax concessions to wealthier cohorts. As demonstrated above, the NDIS cuts eclipse the combined total Budget impact of all the proposed tax changes and Australia continues to spend more each year on superannuation tax concessions (about $60 billion) than on the NDIS. ACOSS welcomed the taxation changes in the 2026-27 Federal Budget, but a balanced and holistic Commonwealth fiscal sustainability strategy must rein in unnecessary and costly concessions, instead of adding austerity-style reductions in social service investments. Figure 2: NDIS expenditure forecasts, before and after cut

Sources: Treasury (2026), Budget strategy and outlook. Budget paper no. 1. Australian Government, Canberra; Treasury (2026), Budget strategy and outlook. Budget paper no. 2. Australian Government, Canberra.

Reforms target individual support packages, not market failures The proposed reforms will have severe impacts on many people with disability while doing little to address the flaws in the scheme’s design, which are driving up costs while delivering services of highly variable quality. As e61 note, ’market structure’ is a ‘largely untouched lever’ for controlling the growth in costs. The failure of the market to consistently deliver quality services to people with disability cost effectively is well documented, including by the Independent Review of the NDIS (NDIS Review). “NDIS markets are not like other markets. They are social markets that need effective stewardship. Poor market design is creating perverse incentives and regulatory oversight is not proportionate to risk. The current fee-for-service model rewards providers for the volume of supports they deliver, with little

Submission 369

incentive to improve quality, be innovative or responsive to the needs of all participants. Price caps have become price floors.”1 The NDIS Review noted service quality is highly variable with very limited measurement or transparency of quality of supports, making it impossible for participants to make informed decisions. It also highlighted that the payments system incentivise activity rather than outcomes.2 The NDIS Review proposed a range of measures to improve the functioning of the NDIS market and improve quality, including:

A more active role for government in monitoring the market and addressing issues with access and/or quality;
Establishment of a new National Disability Supports Quality and Safeguards Commission with the resources, powers and approach to proactively and effectively regulate the disability supports market;
Establishing a Dedicated Commissioner for Quality within the National Disability Supports Quality and Safeguards Commission;
Changes to the pricing and payments framework to improve quality and efficiency;
Shifting to an independent body advising on price setting;
Progressively rolling out preferred provider arrangements for capital supports;
Rolling out provider panels in communities with supply gaps;
Developing a quality measurement system to publish metrics of provider performance; and
Publishing a provider of last resort policy to ensure continuous access to service where markets fail. It is extremely disappointing that the Government has targeted individual eligibility and packages of support in the Bill as its main approach to improve the Scheme’s fiscal sustainability, rather than pursuing more fundamental structural changes to the market structure to improve quality and cost-effectiveness.

Reform process needs greater scrutiny and genuine co-design Again, ACOSS supports the government’s intent to improve the sustainability of the NDIS, and to strengthen its social licence with the community. However, given the depth and scale of the reforms being proposed, the complexity of the legislative changes articulated, and the lasting impact such changes would have

1 Department of the Prime Minister and Cabinet, Working together to deliver the NDIS - Independent Review into the National Disability Insurance Scheme: Final Report, 2023, p 25.

2 Department of the Prime Minister and Cabinet, Working together to deliver the NDIS - Independent Review into the National Disability Insurance Scheme: Final Report, 2023, p 32.

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on the operation of the NDIS, the current rushed process borders on anti democratic. Minister Butler announced the NDIS reforms to the National Press Club on 22 April. The Treasurer handed down the Federal Budget with its expenditure reductions to the NDIS on 12 May. The government then introduced the National

Disability Insurance Scheme Amendment (Securing the NDIS for Future

Generations) Bill 2026 (the Bill) - a 109-page Bill with an Explanatory Memorandum near 300 pages - on 14 May. The Committee then invited submissions from the public by 29 May (extended to 1 June), with its report to be issued by 16 June 2026, after which the government may pass the Bill with no further consultation. In only a five-week period, the government has gone from announcing massive proposed changes to the NDIS to seeking to budget and legislate measures it acknowledges will have a lasting, intergenerational impact on people with a disability. This truncated timeframe for such significant and lasting changes (including changes which would avoid further parliamentary oversight if enacted) deprives people with disability, their carers, family, friends and support workers a genuine opportunity to respond to the government’s plan, to provide their lived experience, their practical understanding of the intended and unintended consequences of the proposed changes and how to improve their operation and ensure there are strong safeguards in place. By way of comparison, the NDIS Independent Review received almost 4,000 submissions and travelled to every state and territory to hear directly from people with disability. The NDIS Review said that the NDIS ‘cannot achieve sustainability without improving outcomes for people with disability’. The Disability Royal Commission (DRC) heard from about 10,000 people, many of whom shared experiences, aspirations and ideas, as well as traumatic stories, with the hope of a better future for the disability community. The DRC identified a key theme for an inclusive Australia as ‘people with disability having the support they need to exercise choice and maximise their independence’. The Government cannot point to the NDIS Review consultation process as authorising the changes it now proposes, given that the Final Report was based on the National Cabinet agreement to target annual scheme growth of 8 per cent by 1 July 2026, with sustainability to be ‘an outcome of our reforms, not the driver’.3 Further, ACOSS notes the government has not undertaken any genuine co design of its proposed changes with the disability community directly, nor the DROs, with their detailed understanding of NDIS challenges and possible solutions. This lack of co-design represents a critical flaw in the Government’s overall engagement with the disability sector.

3 Department of the Prime Minister and Cabinet, Working together to deliver the NDIS - Independent Review into the National Disability Insurance Scheme: Final Report, 2023, p 51.

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Without co-design the government’s proposed reforms place NDIS participants at great risk of further negative consequences. For instance, Women With Disabilities Australia (WWDA), which has previously detailed the gender-based problems inherent in the NDIS, has warned the reforms risk deepening existing inequalities for women, girls and gender-diverse people with disability, recommending the Bill not proceed until a comprehensive gender impact analysis has been released and gender-responsive reforms have been co designed with women, girls and gender-diverse people with disability.4 ACOSS strongly urges a more methodical and rigorous approach to parliamentary scrutiny of the Bill, affording people with disability, community sector organisations, and the wider general public a genuine opportunity to review, consider and respond to the various detailed proposed changes and their impacts. Recommendation 1: Parliament to refer the Bill for further, detailed inquiry to provide greater scrutiny of the proposed changes and more adequately allow input from the wider disability community. Recommendation 2: Government should commit to authentic co-design, through processes that are participative, inclusive, respectful, centred on lived experience and lived expertise, iterative and outcomes focused.

NDIS must remain centered on human rights ACOSS does not support the changes to the objects and principles of the NDIS Act which would see the Scheme shift focus from a human-rights based approach focused on individual needs and goals, towards the financial sustainability of the Scheme itself. The NDIS is the key to Australia’s efforts to meet our international obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). Section 3 of the NDIS Act 2013 embeds a human-rights approach to providing reasonable and necessary supports for scheme participants. However, the proposed changes fundamentally alter how ‘reasonable and necessary’ supports are to be understood, by seeking to include a reference in section 3(1)(d) to ‘NDIS supports…consistent with the financial sustainability of the Scheme’. While the current objects have not guaranteed particular outcomes, they provide a framework under which planning decisions should be based on individual circumstances, personal goals, choice and control, with plans shaped by participants. Courts have used the NDIS Act’s objects and principles to guide how the Scheme should be applied. Further, proposed section 17B introduces principles requiring the CEO to prioritise Scheme sustainability when making planning decisions, including by:5

4 Women With Disabilities Australia, Submission: Gendered Risks of the NDIS Amendment Bill 2026, May 2026.

5 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

Submission 369

funding only supports that arise directly from impairments that meet the access criteria;
recognising the role of community and informal supports;
confirming that participants are responsible for day-to-day living costs, including costs incurred whether or not a person has a disability; and
ensuring funding is distributed fairly and consistently across participants with similar needs. In proposing such changes to NDIS principles, the government seeks to overturn legal precedent determined by courts and tribunals favouring participants and prospective participants. This is antithetical to maintaining the human-rights based approach of the NDIS. Please also see our next section, regarding Ministerial powers and intervention, for related points. Recommendation 3: Retain the focus in the NDIS Act on a rights-based approach to reasonable and necessary supports for people. Fiscal impacts should not be explicitly included in the Act’s objects.

Restrain Ministerial powers with better safeguards The Bill introduces a number of extraordinarily broad Ministerial powers with limited safeguards, oversight or accountability mechanisms. In particular, the proposed amendments would allow significant decisions affecting access to supports to be made by the Minister through legislative instrument, with limited transparency, consultation requirements, review rights or ordinary sunsetting requirements. ACOSS urges the Committee to restrain these Ministerial powers and embed sufficient safeguards to ensure proper parliamentary transparency and scrutiny as is expected of any major piece of Commonwealth legislation. Firstly, the Ministerial powers proposed in the Bill are sweeping and unnecessary. Under the proposed changes, the Minister can do any of the following:6

Make ‘support determinations’ to reduce funding available for certain groups of supports, even where supports have already been assessed as reasonable and necessary. Such determinations would apply Scheme-wide, reducing by percentage the amount of funding available to participants who receive supports subject to a determination (s34A);
Make other determinations that set caps on the supports that participants can get, either across the Scheme or to targeted participant groups, including (s33(2EA) and 33 (2EB)): o maximum funding amount for particular supports;

6 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

Submission 369

o maximum frequency and/or duration of support provision,; and o maximum worker-to-participant ratios for specific supports or classes of support.

Make NDIS rules (with state and territory agreement) to exclude groups of people who receive certain supports (for instance, those already receiving services in aged care system) (s25B(4));
Make additional ‘alterations’ to an automatically renewed plan (for example, time-limited funding or temporary variations may not continue into the new plan)(section 50A);
Set the maximum prices for supports that are not self-managed (s45C);
Expand the use of ADM by issuing future legislative instruments, which may authorise ADM for a wider range of purposes (s59C(2)); and
Unilaterally make rules that change the effect of the Act for 12 months after the Bill passes, to operate for up to 12 months, without those rules having to be passed by Parliament (Schedule 5, item 1). The proposed Ministerial powers are not only sweeping, they contain minimal parliamentary scrutiny. A prime example is the Minister’s proposed powers on support determinations (s34A). Support determinations by the Minister would operate through legislative instruments, meaning that any resulting reductions in funding are not reviewable decisions, and thus participants cannot challenge the decisions through available review.7

ACOSS has major concerns with these proposed expansionary and opaque powers, and the precedent they would establish across Commonwealth-funded human services. Firstly, we do not think the Minister requires such a concentration of discretionary powers, and at such a scale. They are not proportionate or reasonable to the objectives being pursed on behalf of the government, namely:8

Fighting fraud and stopping rorts;
Slowing rapid cost increases;
Introducing clearer eligibility requirements; and
Delivering quality services and support to participants. Further, concentrating discretionary decision-making power with the Minister moves sharply away from the current human rights-based approach and its emphasis on supporting individual need, choice and control. As such, these proposed powers would see people with disability bear the daily burden of the

7 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

8 Department of Health, Disability and Ageing, National Disability Insurance Scheme Reforms – Impact

Analysis, May 2026, p5.

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Minister’s ongoing attempts to reduce investment in the Scheme itself, and live with the consequences, both deliberate and unintended. Secondly, granting the Minister these proposed powers would set a dangerous precedent for how future Ministers, and governments, could directly intervene in the funding and administration of the NDIS, as well as other major Commonwealth-funded human services, with minimal oversight and transparency and at the expense of individuals or groups of participants. It would set examples that could be adapted to other demand-driven services.

Recommendation  4:  Restrain  enhanced  Ministerial  powers  by  improving

parliamentary scrutiny and safeguards including:

•  Limiting  reliance on  legislative  instruments  for key  policy  decisions,

ensuring that nothing  restricting access or funding  sits  in  legislative

instruments;

Ensuring all major policy settings are in the primary legislation – the Act, and not in the rules;
Imposing stronger limits and review on expanded Ministerial powers including those in Schedule 5, item 1; and
Ensuring genuine consultation before Ministerial rules are made.

Proposed reforms will negatively impact women and girls ACOSS is concerned that the proposed reforms will have a disproportionately negative impact on the lives of women and girls, both those with disability either on or seeking access to the Scheme, as well as those already caring for people with disability in their family networks.

The reforms are likely to deepen gender inequities already embedded in the NDIS. This is because the NDIS underserves women with disability, with women making up over half the disability population but just over one-third of scheme participants. Research indicates three key reasons why women remain underserviced by the Scheme: 9

Women are underdiagnosed with conditions commonly accepted by the National Disability Insurance Agency (NDIA), such as autism, while being far more likely to be diagnosed with chronic health or autoimmune conditions that are less likely to be accepted by the NDIA;
The gendered nature of caring responsibilities alongside the complications women face in having these responsibilities supported, particularly in relation to parenting; and
Women are socialised to deemphasise their own needs, which may mean women are ‘less effective self-advocates than men’.

9 Women With Disabilities Australia, Submission: Gendered Risks of the NDIS Amendment Bill 2026, May 2026,

p 8-9.

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The proposed reforms would reinforce, if not exacerbate this structural inequality. Women With Disabilities Australia have identified three immediate risks posed to women and girls10:

Tightened eligibility requirements will deepen gendered exclusion, especially for women and girls with fluctuating, episodic, fatigue-related, pain-related, trauma-related, psychosocial and chronic health conditions;
Cutting available supports to participants and applicants, will shift the burden and the cost to families and informal, unpaid carers, especially parents of children with disability;
Delegating major decisions to future rules, technical advice, evidence standards, budget methods and computer-assisted processes increases the risk that gender-biased published research will be given priority and preference over participant experience and outcomes, and practitioner evidence. There are also likely to be negative gendered impacts of proposed reductions to social, civic and community participation (SCCP), as well as interpretation of ‘what is reasonable to expect of family, carers, informal supports and the community’. Women are overwhelmingly primary carers of children. The Bill would require the NDIA to consider the ‘presumption’ that parents are responsible for providing substantial care and support for their children, including supervision, personal care, transport, emotional support and behavioural support (s34(1G)-(1H). This change selectively imports factors from the Supports for Participants Rules, while not importing whether the child’s care needs are greater than a child without disability, or whether the support would improve the child’s capacity.11 Additionally, the Bill would change how any risks to a participant or carer are weighted. Such risk would only lead to funding a formal support where the risk ‘cannot be mitigated through informal or lower cost supports’ (s34(1K)(a)).12 This sets a very high bar and may result in supports being unreasonably denied. A similarly high bar is proposed by the Bill directing that informal supports are prioritised over funding formal supports, except where formal supports are ‘necessary’ (proposed subsection 34(1K)(b)).13 Reducing SCCP funding and increasing the threshold for formal support for children would represent a major shift back to informal and primary carers, overwhelmingly women, to assume more significant daily responsibilities, and financial costs, for supporting children with disability. It would have a direct flow on effect to carers lives and livelihoods, in addition to heightened emotional and

10 Women With Disabilities Australia, Submission: Gendered Risks of the NDIS Amendment Bill 2026, May

11 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

12 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

13 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

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mental load. It would also undermine the Federal Government’s own gender equality policy agenda.14 The Office of Impact Analysis has acknowledged the likely gendered impact in assessing the Bill and its proposals for resetting SCCP budgets:15

“Due to the gendered nature of caring, women are more likely to be impacted by changes to the supports available or provided to the people they care for. 67.7 per cent of primary carers were women in 2022. Changes are likely to increase informal caring responsibilities, which may impact levels of social and economic participation for female carers.”

The Office of Impact Analysis raises a number of issues requiring further examination. It is critical that the full gendered ramifications of these proposed changes are carefully identified, assessed and addressed before the Bill proceeds further. Additionally, there must be a genuine process of co-designing improvements and alternatives in order to remedy gender inequities already inherent in the Scheme. Recommendation 5: The Bill should be subjected to a comprehensive, public gender impact analysis and co-design of gender-responsive reforms with women, girls and gender-diverse people with disability.

Introduction of Automated Decision Making Schedule 3 allows for the use of ADM within the NDIS. As mentioned above, the Bill also allows the Minister to expand both the use and purposes of ADM by issuing future legislative instruments.16 The Schedule does not specify the circumstances in which ADM is proposed to be used, nor identify the risks and mitigations. It should not be legislated in the absence of a whole-of-government ADM Framework, and without further information about the proposed use of ADM within the Scheme. Of specific concern, the legislation would authorise the automation of discretionary decisions in the administration of the NDIS – an alarming and unprecedented step. Since the Robodebt scandal, ACOSS has consistently advocated for the creation of a Digital Protections Framework to safeguard people from adverse impacts of automated government decisions which affect social security entitlements. A requirement for Department of Employment and Workplace Relations (DEWR) to

14 Department of the Prime Minister and Cabinet, Working for Women: A Strategy for Gender Equality, March 2024.

15 Department of Health, Disability and Ageing, National Disability Insurance Scheme Reforms – Impact

Analysis, May 2026, p 60.

16 Justice and Equity Centre, Explainer on 2026 NDIS Bill, 22 May 2026.

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develop such a framework was legislated in 2022, but 4 years later, has not been progressed. In the meantime, the application of the Targeted Compliance Framework (TCF) by DEWR – the conditions and penalties applied for people receiving unemployment payments – via Automated Decision Making has been deemed to be unlawful, with the system unduly constraining the exercise of decision-maker discretion. In his recent report, Automation in the Targeted Compliance System, the Commonwealth Ombudsman recommended that the DEWR Secretary comply with the legislative requirement to develop a Digital Protections Framework. The Government must heed the lessons of Robodebt and, more recently, the TCF and ensure appropriate protective frameworks are in place before expanding the role of ADM in government service delivery. That Framework should require a human-in-the-loop for all adverse decisions affecting individual entitlements or access. Discretionary decision making should not be subject to automation under any circumstances. Recommendation 6: The Bill should not be legislated in the absence of a whole of-government ADM Framework, and without further information about the proposed use of ADM within the Scheme.