In its October 2026 special report, 'Public sector agency responses to IBAC’s recommendations', Victoria’s Independent Broad-based Anti-Corruption Commission (IBAC) examines the corruption risks identified through its work over the past decade, the changes recommended and how agencies have responded. By documenting these responses and progress towards implementation, the report also provides greater transparency about IBAC’s work across the public sector.
In this blog, we explore the report’s key findings, including risks identified across different sectors, recommended actions and implementation progress, with particular attention to conflicts of interest, procurement, and contract management.
IBAC’s role and recommendations
IBAC is Victoria’s independent anti-corruption agency, responsible for preventing and exposing corruption across the public sector. Corruption can involve misusing public office or authority for personal gain or to improperly benefit others, such as awarding contracts to family or friends.
IBAC makes recommendations following investigations and through its education and prevention work. These can involve changes to legislation, policies, organisational systems, training, and disciplinary or management action.
Agencies receiving investigation recommendations must advise IBAC whether they intend to adopt them and explain decisions not to do so. However, they are not legally required to implement recommendations or publicly report on their responses. Recommendations arising from prevention work carry no legislated response requirement.
What the review examined
The report analysed 260 primary recommendations made between 2014 and 2025, covering government departments, local councils, education, health, corrections, ministerial offices, Parliament, and other public bodies. Victoria Police is excluded. Implementation progress was assessed as at June 2026.
Findings across sectors
Of the 260 recommendations, 256 followed investigations. The sectors receiving the most recommendations were:
- Local government: 40
- Corrections: 34
- Education and training: 22
- Ministerial offices: 20.
The corruption risks addressed varied across sectors. Conflicts of interest were the most common risk associated with recommendations in 10 sectors, while procurement and contract management were the leading risks in health and education and training.
Across the public sector, the most frequently identified risks and vulnerabilities concerned:
- Conflicts of interest and declarable associations: 77 recommendations
- Complaint handling, internal investigations and reporting of corruption: 53
- Procurement and contract management: 47
- Information management, security and record keeping: 42
- Oversight of funded agencies, entities, contractors and suppliers: 41.
Importantly, individual recommendations could address multiple risks.
Changes recommended
Reviewing or updating policies, procedures and frameworks was the most common action recommended by IBAC, appearing in 133 recommendations (51%).
Other actions included:
- Training and staff awareness: 60 recommendations (23%)
- Audits and risk management: 52 (20%)
- Legislative or regulatory reform: 46 (18%)
- Disciplinary or management action: 22 (8%).
Implementation and further findings
As at June 2026, IBAC assessed the recommendations as follows:
- 168 fully implemented
- 21 partially implemented
- 37 in planning
- 22 not yet commenced
- 12 with no implementation planned.
Excluding the 59 recommendations still in planning or not yet commenced, IBAC found that 84% of the remaining 201 recommendations were fully implemented, 10% were partially implemented and 6% had no implementation planned.
The report identifies a substantial increase in publicly made recommendations. Between 2021 and 2025, IBAC made almost three times as many recommendations publicly as it did during the preceding seven years (2014-2020). This increase followed the publication of five special reports across 2022 and 2023.
The review also examined transparency, reporting, and implementation timeframes:
- Public visibility: 125 recommendations were made publicly and 135 privately.
- Reporting: 78% of initial implementation reports were received early or on time.
- Follow-up: Of the recommendations assessed as fully implemented, 34% required additional information or action as part of IBAC’s assessment process.
- Implementation time: The median time to full implementation was 13 months.
Other examples in the report include reforms involving education sector integrity, Ambulance Victoria’s drug testing regime, health service oversight, and parliamentary accountability.
Conclusion
The report highlights changes made in response to IBAC’s recommendations and offers public sector agencies examples of how similar corruption risks have been addressed. It also identifies legislative restrictions on publishing recommendations, which IBAC continues to seek to reform. Greater transparency about IBAC’s recommendations and how agencies respond can help strengthen public sector accountability and inform efforts to address corruption risks.
Resource
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CourtHeath acknowledges the Traditional Aboriginal Owners of Country throughout Victoria and pays respect to Elders past and present, and to the ongoing living culture of Aboriginal people.
A participant in the UN Global Compact, CourtHeath seeks to raise awareness about the sustainable development goals and the principles of the Global Compact with business and government organisations in Victoria.
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IMAGE: Used under licence from shutterstock.com
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Written by Wendy Cavenett
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CourtHeath Consulting
CourtHeath Consulting