Publishing & reporting requirements

Under the CGRPs accountable authorities and officials must use GrantConnect to publish:

• all forecast grant opportunities where these have been developed
• all grant opportunity guidelines (GOGs) – except where a publishing exemption has been approved
• any alterations or addenda to grant opportunity guidelines:
  • alterations and addenda include but are not limited to corrections to currently published documents, changes to close times for applications, questions and answers (Q&As) documents and frequently asked questions (FAQs) documents.
• reportable variations (such as significant additional payments of relevant money, extension into a new financial year, or a change in organisation details) no later than 21 calendar days after the variation for the grant takes effect
• where a minister has approved a grant in their own electorate
• where a minister has approved a grant that officials recommended be rejected.

Accountable authorities and officials may choose to publish information on other platforms. GrantConnect is the authoritative source for grant information and any information published elsewhere must be the same, or a subset, of the information published on GrantConnect.

Officials are encouraged to forecast grant opportunities. Forecasting grant opportunities provides potential grant applicants with the opportunity to plan projects and applications for future grant opportunities. 

Forecasting opportunities may help to facilitate early consultation with stakeholders, consistent with the principle of collaboration and partnership.

Where forecast opportunities are developed, these must be published on GrantConnect.

The CGRPs (section 5) and the PGPA Rule (section 25F) contain reporting requirements for grants.

NCEs must report information on individual grants on GrantConnect no later than 21 calendar days after the grant agreement takes effect (date of effect).

The approval date for reporting purposes is the date that the decision-maker (as listed in the GOGs) makes a decision to award a grant.

Where there is a grant agreement, the start date for reporting purposes is generally the date the grant agreement is executed (signed by both parties). However, if the grant agreement contains a specified start date that occurs after the execution of the grant agreement, then for reporting purposes the start date is the specified date.

Where there is no grant agreement, officials may decide on a specific date of effect or start date and document the decision to choose this date. In these cases, the date of effect may be:

• the date of the first payment
• the date of the announcement of successful grantees
• a planned delayed start for grant projects to coincide with the commencement of the financial year
• another specified date.

Whichever date of effect is decided and documented, details of the grant must be published no later than 21 calendar days from this date.

Officials should adopt a consistent approach for grants awarded in the same grant opportunity.

Grants awarded should be linked to the relevant grant opportunity identification number (GO ID) for transparency. The GO ID is the unique identifier on GrantConnect that relates to that grant opportunity.

The exception to publishing a GO ID is where:

• for a specific policy reason, the Minister for Finance has provided an exemption for the publication of the grant opportunity guidelines (NCEs)
• the CCE or Minister makes a decision not to publish the guidelines (PGPA Rule).

Entities must also report grant variations.

It may be appropriate to vary a grant agreement in limited circumstances. Grant agreements should only be varied when:

• it is necessary to extend the time to enable the grantee to complete the projects or activities set out in the original agreement, and then only for the length of time needed to achieve completion, and
• the variation does not significantly change the scope of the initial agreement.

A variation should not be used as an alternative to appropriately planning a new grant opportunity.

When recommending or approving a variation to a grant agreement, officials and decision makers should consider the key principle of achieving value with relevant money. Extending a grant agreement through a variation for continued or new grant activities may not always achieve value with relevant money. This could be because:

• changes have occurred that impact the grantee’s ability to deliver the activities
• input costs have changed
• new potential grantees have emerged that could offer solutions that better achieve the policy outcome.

Where variations have been used more than once, officials should consider why they are being used and consider other options, such as using longer term grant agreements or undertaking a new process.

Variations made to grants awarded must be reported on GrantConnect within 21 calendar days after the variation takes effect. Reportable variations include:

• significant additional payments of relevant money
• extensions into a new financial year
• changes in organisation details.

Minor variations, including indexing, changes to project team members or date changes in the same financial year, do not need to be reported on GrantConnect.

When publishing a variation, the grant award notification must be updated. Officials must link the grant variation information on GrantConnect to the previously published grant opportunity guidelines.

When updating a Grant Award notification for variations it is better practice to link the GO ID.

Under the CGRPs, ministers (including parliamentary secretaries, senators and assistant ministers but not including presiding officers) must report decisions to approve a grant: 

• in their own electorate, except in limited circumstances (CGRP paragraph 4.11) 
• that officials ‘recommended be rejected’ (CGRP paragraph 4.12). 

These reports must be provided to the Minister for Finance and reported on GrantConnect as soon as practicable after the approval is given (CGRP paragraph 4.13). The Minister for Finance must table copies of these reports in each House of Parliament as soon as practicable after the end of each quarter.  

When briefing a minister as the approver of a grant, officials should advise the minister if a proposed grant would be in the minister’s own electorate. A grant is in a minister’s own electorate when: 

• the grant recipient’s address is in the minister’s own electorate, and/or
• all or part of the approved grant activity will be delivered in the minister’s own electorate.

Where part of the activity approved for a grant by the minister will be delivered in the minister’s own electorate, the minister should report the proportion of the activity to be delivered in the electorate. Where this is not known, the minister must report the whole amount.

The report on GrantConnect must include a summary of the basis of the approval. 

The grants awarded must be published before information on ministerial decisions can be reported and linked in the system.

The Grants Toolkit provides templates to help with ministerial reporting. 

Reports tabled under paragraph 4.12
Reports made under paragraph 4.12 are tabled annually in Parliament under Senate Order 23E and are available on the Parliament of Australia website. Links to these are available in the right-hand menu of this page under Publishing and Reporting Requirements.

Publishing exemptions 

In limited circumstances, the Minister for Finance may approve an exemption from the requirement to publish. Paragraph 5.8 of the CGRPs and subparagraph 25F(3) of the PGPA Rule outline the grounds for exemptions to reporting grants information on GrantConnect.

NCEs

Where officials assess that publishing grant information, in accordance with the CGRPs could adversely affect the achievement of government policy outcomes, the responsible minister may seek an exemption from the Minister for Finance.

The responsible minister must write to the Minister for Finance detailing their reasoning for the exemption. Officials should consult Finance before commencing this process.

CCEs

Where CCE accountable authorities or their minister considers there is a specific policy reason not to publish, or for one-off ad hoc grants, they may decide not to publish grants information. They must make a record of their decision and reasons.

Reporting on confidentiality provisions 

There are generally 2 broad types of confidentiality related clauses used in grant agreements:

• general clauses referencing confidentiality requirements in legislation, such as under the Privacy Act 1988 (Privacy Act)
• special confidentiality provisions, which protect the confidentiality of: all or part of the grant agreement; or information obtained or generated in relation to the grant project.

The CGRPs and PGPA Rule provide that officials must identify whether a grant agreement contains confidentiality provisions. When entities publish information on individual grants awarded on GrantConnect, they must include information identifying whether a grant agreement contains any confidentiality provisions and if so, provide the reasons why they are included. References to requirements in other legislation do not need to be reported. There is no threshold for reporting on confidentiality provisions contained in grant agreements.

For additional information on reporting on confidentiality provisions, officials can draw from information provided for procurement contracts.

Privacy exemptions

There may be circumstances where officials determine that public reporting of grants in accordance with the CGRPs is contrary to the Privacy Act, other statutory requirements, or the specific terms of a grant agreement. 

In these circumstances, the relevant officials must publish as much information as legally possible and must fully document the reasons for not fully reporting. Officials should also take all reasonable steps to ensure that future grant agreements contain provisions that do not prevent the disclosure of information.