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.



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.



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is related to Australia’s complex industrial relations landscape, which is due in large part to its complicated and outdated awards system; which increases the likelihood of organisations making an honest mistake.  


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.



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.


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.


The Industrial Relations and Other Legislation Amendment Bill 2022, AHRI’s submission to the Queensland Parliament Education, Employment and Training Committee


AHRI submission to the Productivity Commission’s inquiry into Australia’s Productivity Performance.



JobMaker Hiring Credit Rules Submission, 26 November


Submission to SafeWork NSW on Managing the Risks to Psychological Health – Draft Code of Practice, October


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.


Cooperative Workplaces Submission, 9 April