AHRI submissions
AHRI advocates on key issues that affect workplace matters, and the HR profession, on many levels, including presenting evidence to government agencies and royal commissions. Below you can see a list of all of AHRI’s past submissions to government.
Access any of the submissions by clicking the text links below.
2026
February
The Australian HR Institute (AHRI) has made a submission to the Government’s review of the Fair Work Legislation Amendment (Closing Loopholes) Acts 2023 and 2024.
This is the third AHRI submission to an IR/ER inquiry in as many weeks, reflecting the volume and pace of legislative changes in recent years. AHRI’s submission draws heavily on our recent research, which includes a representative survey of more than 600 employers and six focus groups with senior AHRI members from across Australia.
Overall, AHRI’s evidence shows strong support for the policy intent of recent workplace reforms, including positive impacts on productivity and employee engagement. Many employers report that legislative changes have prompted organisations to review and strengthen policies, frameworks and workplace practices in areas such as sexual harassment prevention, workforce planning, flexible working and psychosocial risk management.
At the same time, HR professionals report significant implementation pressure arising from the cumulative pace of reform. Interpreting legislative changes, updating policies and systems, and training managers and employees have increased costs and workload. Members also emphasised that successful implementation depends heavily on line manager capability, with many organisations investing in training and guidance to ensure new obligations are applied consistently and fairly.
Based on this evidence, AHRI’s submission does not see a strong case for further reform at this stage. Instead, the focus should be on supporting implementation of recent reforms through clearer guidance, realistic timeframes and a greater focus on employer and public and employer investment in management capability, which is low in Australia by international standards. AHRI will therefore continue to make the case for policy interventions, such as an advisory services offering to support work-related training and financial incentives, to increase public and employer investment in skills.
AHRI has made a submission to the House of Representatives Standing Committee on Employment’s Inquiry into the National Employment Standards (NES).
HR professionals continue to strongly support the NES as a vital safety net. However, concerns remain about how it interacts with modern awards and enterprise agreements. It is this layering of entitlements, not the purpose of the NES, that is driving complexity and compliance risk.
Our members report practical confusion around notice periods, maximum weekly hours, annual leave for shift workers and overlapping redundancy obligations.
While AHRI research shows that recent employment legislation has positively impacted productivity and employee engagement, it has also placed significant workload and stress on HR professionals. Although, a majority support extending the right to request flexible working to all workers, the immediate priority is stability.
AHRI has made a submission to the Senate Education and Employment Legislation Committee’s inquiry into the Fair Work Amendment (Right to Work from Home) Bill 2025.
AHRI’s evidence shows flexible and hybrid work is already well established, with more than 80% of employers offering work-from-home options. In our response, AHRI argues that the current framework is largely supporting productivity without the need for more prescriptive regulation, which risks making it harder for employers and employees to reach mutually beneficial arrangements that reflect role requirements, team needs and organisational context.
AHRI does not support expanding legislated WFH entitlements, as proposed in the bill. However, AHRI supports the proposal to extend the right to request flexible work to all employees as a simpler, more consistent approach that can support attraction, retention and fair access.
2025
September
AHRI has made a submission to the Productivity Commission’s Inquiry into ‘Building a Skilled and Adaptable Workforce’.
In our response, AHRI welcomes the Commission’s recommendations, particularly the examination of financial incentives, such as tax credits, to encourage small and medium-sized business (SMBs) to invest in work-related training, and the development of dedicated SME advisory services to help employers access training support.
We argue that a central goal of any advisory service should be to strengthen people management capability in Australian workplaces, giving employers access to expert guidance on best practice leadership and people management skills.
AHRI also recommends that these services promote the adoption and spread of High-Performance Work practices across the economy, given their proven link to stronger organisational performance.
August
AHRI has made a submission to the Treasury’s Issues Paper on Non-competes clauses and other restraints’.
In our response, AHRI argues that non-compete clauses, when used for the right reasons and applied appropriately, can work for both individuals and employers.
However, with a large proportion of employees in some Australian workplaces covered by non-compete clauses as part of their employment contracts, AHRI supports the introduction of a high-income threshold below which non-compete clauses would not be permitted, and a 12-month maximum duration for those earning above the threshold. We caution against introducing shorter limits, which could discourage employers from sharing vital confidential information with staff and undermine organisational performance.
AHRI also supports retaining the use of non-solicitation clauses for all employers to help protect intellectual property, client relationships and teams.
2024
May
AHRI has made a submission to the Treasury’s Issues Paper on Non-competes and other restraints: understanding the impacts on jobs, business and productivity.
In our response, AHRI argues that non-compete clauses (which prevent an employee from joining a competitor organisation within a period of time), used for the right reasons and applied in the right way, can work for both individuals and employers.
However, with a large proportion of the workforce in some Australian workplaces covered by non-compete clauses as part of their employment contracts, AHRI supports some tightening of the regulation of non-compete clauses. AHRI’s main proposal is the introduction of a high-income threshold for non-compete clauses. We believe that a threshold will make it easier for firms to improve workforce skills and productivity through increased job mobility while still protecting the business interests of other firms.
In our response, AHRI argues that expanding working from home rights risk raising expectations among employees and exacerbating existing tensions between those who can work from home those and those who cannot. Such tensions are documented in a recent AHRI report on flexible working and hybrid working, which shows that around 36% of employees cannot work from home.
AHRI instead proposes extending the right to request flexible working arrangements to all employees in 2027. AHRI argues that this would be a more effective way of helping facilitate discussions between managers and staff about remote and hybrid working possibilities and other flexible working arrangements.
March
AHRI has made a submission to the Fair Work Commission’s (FWC) Discussion Paper on Work and Care (Modern Awards 2023-24). The FWC is proposing in its review of modern awards to expand working from home rights and narrow the grounds for refusing flexible work requests to “unjustifiable hardship”.
In our response, AHRI argues that expanding working from home rights risk raising expectations among employees and exacerbating existing tensions between those who can work from home those and those who cannot. Such tensions are documented in a recent AHRI report on flexible working and hybrid working, which shows that around 36% of employees cannot work from home.
AHRI instead proposes extending the right to request flexible working arrangements to all employees in 2027. AHRI argues that this would be a more effective way of helping facilitate discussions between managers and staff about remote and hybrid working possibilities and other flexible working arrangements.
2023
June
Wage underpayment
AHRI has made a submission to the Government’s consultation paper on wage underpayment. The government is seeking to increase penalties for wage underpayment and ‘introduce a criminal offence for the most serious forms of exploitative conduct’.
In our response, AHRI argues that the government should be prioritising increasing funding for enforcement and education activity. This is because evidence suggests that financial penalties in Australia for non-compliance are already very high by international standards. In contrast, Australia’s active enforcement of underpayment is lower than many of our international counterparts.
AHRI also proposes funding for employer organisations, professional bodies and trade unions to help educate their members about employment regulation. This call is related to Australia’s complex industrial relations landscape, which is due in large part to its complicated and outdated awards system; which increases the likelihood of organisations making an honest mistake.
May
The employment status of casual workers
AHRI has made a submission to the government consultation paper on the rights of casual workers . The government is seeking responses about how best to introduce an objective test that determines when an employee can be classified as a casual. The objective is to ‘provide a clearer pathway to permanent work’.
AHRI proposes that the right to request casual conversion, which is currently restricted to small employers, should be extended to all organisations. AHRI believes that this proposal will lead to a better outcome from both an employment and productivity perspective. This is because the light-touch nature of our proposal will lead to less management time spent administering the red tape associated with the current requirement for some organisations to make a written offer to convert their casual employees to permanent employment. Our proposals will in turn lead to lower labour costs, which all things being equal, should mean that employers will employ more people.
2022
November
Fair Work Amendment (Paid Family and Domestic Violence Leave) Bill 2022: AHRI’s submission to the Senate Education and Employment Committees
The Labor Government has introduced legislation that would give employees experiencing family and domestic violence ten days of paid family and domestic violence leave over a 12-month period. If the legislation passes, the Fair Work Amendment (Paid Family and Domestic Violence Leave) Bill 2022 would replace the existing entitlement in the NES to five days of unpaid family and domestic violence leave and benefit full-time, part-time and casual employees.
AHRI has made a submission to the Senate Education and Education Committee’s inquiry into the bill. AHRI’s submission can be found here: AHRI-Family-Domestic-Violence-Leave-Bill-2022-Submission.pdf
The Committee has both endorsed the bill and recommended that a review be carried out 18 months after the introduction of the new entitlement, which is likely to be in February 2023 for most organisations. Small businesses would have an extra 6 months to implement the legislation.
AHRI will be monitoring and reporting on the latest developments of the legislation, which would include contributing to the 18-month review by asking members how the legislation has impacted your organisation.
September
Secure Jobs Better Pay Bill: AHRI’s submission to the Senate Education and Employment Committees
The Labor Government has introduced legislation (Fair Work Legislation Amendment (Secure Jobs Better Pay) Bill 2022 Fair Work Act 2009 (the FW Act). This would give the Fair Work Commission more powers in relation to flexible working arrangements. These include becoming involved in a wider number of disputes and making orders about different working arrangements.
AHRI is concerned about the proposed enhanced role due to concerns about costs and the administrative burden, which will hamper productivity and stifle job growth. In AHRI’s view, the decision to offer employees flexible work, and precisely which flexible working arrangements to adopt, should be determined solely by organisations themselves. AHRI believes that extending the existing right to request flexible working to all employees would be a far more effective way of improving the uptake of flexible working practices.
At the same time, AHRI supports some elements of the bill, including the proposed expansion of an employer’s obligation to discuss and consider different flexible working arrangements with employees. AHRI believes that this will improve the chances of optimal outcomes for both employers and employees, because it ensures that both parties are fully informed about their choices.
AHRI has made a submission to the Senate Education and Education Committees’ inquiry into the bill. AHRI’s submission can be found here: Submission to the Senate Education and Employment Committee on the Secure Jobs Better Pay Bill 2022
The committees have recommended that the bill be passed while offering some recommendations. AHRI will be monitoring and reporting on the latest developments of the legislation.
July
The Industrial Relations and Other Legislation Amendment Bill 2022, AHRI’s submission to the Queensland Parliament Education, Employment and Training Committee
March
2020
November
JobMaker Hiring Credit Rules Submission, 26 November
October
August
Submission to the Australian Government’s Industrial Relations Reforms 2020 Cooperative Workplaces, August. This submission was prepared on behalf of AHRI by an Industrial Relations Working Group consisting of AHRI members, specialist advisors and employees: Lisa Mannering, Leisa Messer, Natalie Morris, Colleen McAleese, Briarna Hughes, Sarah McCann-Bartlett, Elaina Pittas, Nick Ruskin, Susan Sadler, Gerry Treuren and Donna Young.
April
Cooperative Workplaces Submission, 9 April