Report cover for Submission to AG Department on ADM Reform

Call for a more comprehensive regulatory framework for automated decision-making in the public sector

Author ADM+S Centre
Date 10 February 2025

In a new submission to the Attorney-General Department’s Automated Decision-Making (ADM) Reform consultation, experts from the ARC Centre of Excellence for Automated Decision-Making and Society (ADM+S) urge the government to adopt a more comprehensive regulatory framework for ADM in the public sector. 

The submission argues that the current focus of the consultation paper on legislation and regulation overlooks essential aspects like enforcement and accountability, which are critical to ensuring responsible use of technology in government decision-making.

The response highlights that the existing approach is too narrow, focusing primarily on AI-based systems, while neglecting broader systemic issues. The authors contend that the government should lead by example, setting a standard for safe and accountable technology use that applies to all technical systems, not just AI.

Among the key recommendations outlined in the submission are calls for stronger enforcement mechanisms, including active monitoring and independent oversight. The experts also emphasize the need for transparency in the acquisition of ADM systems, urging the government to adopt robust measures to prevent misuse and ensure accountability across all public sector applications of automated decision-making.

Key recommendations

  • The ADM framework should include enforcement and accountability mechanisms.
  • Systemic and preventative measures, including ex-ante control and active monitoring, are needed.
  • An independent oversight body should monitor and enforce standards across government.
  • Qualified transparency mechanisms should be adopted.
  • Key transparency requirements should be incorporated into the acquisition of ADM systems.

As the public sector increasingly integrates automated technologies, the submission urges policymakers to act quickly to address these gaps, advocating for a regulatory framework that goes beyond individual cases to tackle systemic risks.

Authors:
Dr José-Miguel Bello y Villarino, Prof Emeritus Terry Carney, Prof Kimberlee Weatherall, Dr Rita Matulionyte, Prof Julian Thomas, Prof Paul Henman and Veronica Lenard.

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