This page provides guidance to support PGPA Act entities and companies in meeting the requirements of the PGPA framework. These guidance pages support accountable authorities and officials to apply the intent of the framework. It is an official’s responsibility to ensure that Finance guidance is monitored regularly for updates, including changes in policy/requirements.
Key points
This guide explains the key terms used by the Public Governance, Performance and Accountability Rule 2014 (PGPA Rule), offers examples of how to report the information in the annual report to meet the requirements and provides a summary of best practice reporting.
The PGPA Rule (Sections 17AG(7) and (7A) and sections 17AGA(2) – (3)) outlines reporting requirements for the annual reports of all non-corporate Commonwealth entities (NCEs). NCEs must report on the number of and expenditure on new and ongoing reportable consultancy and non-consultancy contracts, and on organisations receiving amounts under reportable consultancy contracts or reportable non-consultancy contracts, during the reporting period for any contract published on AusTender.
The information reported in the annual report should be consistent with what is reported on AusTender.
Terminology
Expenditure is calculated on an actual (cash) basis and is to be disclosed inclusive of GST.
Refers to an arrangement that is published on AusTender as a consultancy.
Refers to an arrangement that is published on AusTender and is not a reportable consultancy contract. This means that a contract published on AusTender as anything other than a consultancy, is a reportable non-consultancy contract for the purposes of the reporting requirements.
For the purposes of the reporting requirements, this refers to contracts that have activity during the reporting period, such as providing payment to the other party to fulfil their obligations.
Refers to those to whom the consultancy and non-consultancy contracts were awarded.
Organisations should be reported separately if they have different Australian Business Number’s (ABNs). This means that subsidiaries should be reported separately to their parent entity, and organisations part of a professional service network (common with accounting and law firms) should also be reported separately. The name of the organisation should be reported consistent with how it appears on AusTender and ABNs should be reported along with the name
This refers to the total amounts an organisation received as part of an entity’s total expenditure in the reporting period for each category of contract (that is, consultancy contracts and non-consultancy contracts). The amounts are reported separately for each category of contract, not for the total expenditure on all contracts. When reporting, only those organisations who received the 5 largest shares should be disclosed. Where organisations receive one of the largest shares and more than 5% of expenditure, this information should only be reported once.
References to “the period” are taken to mean the current reporting period for which the annual report is being prepared. References to “a previous reporting period” are taken to mean all reporting periods prior to the current reporting period.
Example: Reportable contract data for 2020-21
The Department is a non-corporate Commonwealth entity. The Department’s 2020-21 reportable contract data was as follows:
Consultancy contracts
Engaged in 2020-21 to provide expert advice to the Department. This was reported as a consultancy contract in AusTender. The Department spent $8.0 million under the contract in 2020-21.
Engaged in 2020-21 to provide financial advice to the Department. This was reported as a consultancy contract in AusTender. The Department spent $1.8 million under the contract in 2020-21.
Engaged in 2020-21 to provide strategic information technology advice to the Department. This was reported as a consultancy contract in AusTender. The Department spent $80,000 under the contract in 2020-21.
Engaged in 2018-19 to provide independent advice. This was reported as a consultancy contract in AusTender. The end date for this contract is reported in AusTender as 23 June 2020, however the final payment was made on 7 July 2020. As there was activity on the contract in the reporting period, it is defined as an ongoing contract. The Department spent $2.5 million under the contract in 2020-21.
Engaged in 2020-21 to provide consulting services. This was reported as a consultancy contract in AusTender. The Department spent $0.5 million under the contract in 2020-21.
Engaged in 2020-21 to undertake a due diligence review. This was reported as a consultancy contract in AusTender. The Department spent $0.2 million under the contract in 2020-21.
Non-consultancy contracts
Was engaged in 2020-21 to provide office equipment. The Department spent $2.3 million under the contract in 2020-21.
Engaged in 2020-21 to develop process documentation. The Department spent $1.8 million under the contract in 2020-21.
Engaged in 2020-21 to provide media services to the Department. Genius Media Ltd is a subsidiary of Genius Communications Ltd. The Department spent $0.9 million under the contract in 2020-21.
Engaged since 2019-20 to provide auditing services. Finest Finance is a part of a professional service network of accounting advisory firms across the world. Finest Finance (Evaluations) Ltd is also part of this network. The network members are independent firms that do not practice jointly. The Department spent $3.0 million each year under the contract.
Have been engaged since 2019-20 to provide short-term backfilling of administrative staff, when ongoing employees go on leave. The Department spent $1.5 million under the contract in 2020-21.
Engaged since 2019-20 to provide media services for the Department’s ongoing business. The Department spent $4.0 million under the contract in 2020-21.
Engaged on an ongoing basis since 2019-20 to provide training each year to the incoming graduates to the Department. The training is provided to the graduates at the Department’s premises. The Department spent $0.2 million under the contract in 2020-21.
The Department leases its office space from Property Holdings Pty Ltd. This contract was entered into in 2018-19 for a 5 year term. The Department spent $0.5 million under the contract in 2020-21.
Example: Reporting Tables in the annual report
The following tables set out the correct way for the Department to report on the 2 categories of contracts;
- Expenditure on reportable consultancy contracts
- Expenditure on reportable non-consultancy contracts.
A data template following this structure is available for entities to follow when disclosing information in the annual report.
Table 1 for both categories of contract outlines the number of and expenditure on such contracts, and provides the total of those columns.
Table 2 for both categories of contract provides information on those organisations who received the 5 largest shares of an entity’s expenditure on such contracts, and those organisations who received 5% or more of an entity’s expenditure on such contracts. Reporting this information in the same table avoids duplication as there will be overlap.
Table 3 for both categories outlines the additional information to be reported in the annual report for expenditure on contracts. The table format is a presentation suggestion, which entities can follow if they choose. The calculations for this data are below.
This table is an example of calculating which organisations should be reported in an annual report to satisfy the requirements in sections 17AGA(2) and 17AGA(3) (that is, organisations that received shares of the consultancy and non-consultancy reporting expenditure).
| Reportable consultancy contract expenditure | Reportable non-consultancy contract expenditure | |
$ | $ | |
| Finest Finance (Evaluations) Ltd | $2,500,000 |
|
| Finest Finance Ltd | $1,800,000 | $3,000,000 |
| Consultants R Us Pty Ltd | $500,000 |
|
| Best Expert Advice Pty Ltd | $200,000 |
|
| Assistants-On-Call Pty Ltd |
| $1,500,000 |
| Genius Communications Ltd |
| $4,000,000 |
| Skilful Training Pty Ltd |
| $2,000,000 |
| Advisors & Sons Pty Ltd | $8,000,000 |
|
| IT Specialists Ltd | $80,000 |
|
| Excellent Equipment Ltd |
| $2,300,000 |
| Genius Media Ltd |
| $900,000 |
| Property Holdings Pty Ltd |
| $500,000 |
| Total expenditure | $13,080,000 | $14,200,000 |
|
| |
| 5% of total expenditure | $654,000 | $710,000 |
This table is not required for reporting; it is for illustrative purposes only.
Reportable consultancy contracts
In this example, Department A has 6 new and ongoing consultancy contacts in the 2020-21 reporting period. To meet its reporting requirements under section 17AGA(2), Department A would need to report the organisations that received the 5 largest shares AND all those organisations that received at least 5% of the total expenditure on consultancy contracts. The completed reporting table is on page 5. Consultants R Us Pty Ltd and Best Expert Advice Pty Ltd are reported because they are one of the organisations that received the 5 largest shares, even if they did not receive at least 5% of the total expenditure on reportable consultancy contracts. IT Specialists Ltd is not reported because it does not meet either criteria.
Reportable non-consultancy contracts
In this example, Department A had 8 new and ongoing non-consultancy contracts in the 2020-21 reporting period. To meet its reporting requirements under section 17AGA(3), Department A would need to report the organisations that received the 5 largest shares AND all those organisations that received at least 5% of the total expenditure on non-consultancy contracts. The completed reporting table is on page 6. Property Holdings Pty Ltd is not reported in the annual report because it is not one of the organisations that received the 5 largest shares and it did not receive at least 5% of the total expenditure on non-consultancy contracts.
Expenditure on reportable consultancy contracts
Table 1
| Reportable consultancy contracts 2020-21 | Number | Expenditure $ | PGPA Rule requirement |
|---|---|---|---|
| New contracts entered into during the reporting period | 5 | $10,580,000 | 17AG(7)(a)(i) & 17AG(7)(a)(ii) |
| Ongoing contracts entered into during a previous reporting period | 1 | $2,500,000 | 17AG(7)(a)(iii) & 17AG(7)(a)(iv) |
| Total | 6 | $13,080,000 | - |
Table 2
| Organisations receiving a share of reportable consultancy contract expenditure 2020-21 | Expenditure | PGPA Rule Requirement |
|---|---|---|
| Advisors & Sons Pty Ltd | $8,000,000 | 17AGA(2) |
| Finest Finance (Evaluations) Ltd | $2,500,000 | |
| Finest Finance Ltd | $1,800,000 | |
| Consultants R Us Pty Ltd | $500,000 | |
| Best Expert Advice Pty Ltd | $200,000 |
Table 3
| PGPA Rule requirement | |
|---|---|
| During 2020-21, five new reportable consultancy contracts were entered into involving total actual expenditure of $10.58 million. In addition, one ongoing reportable consultancy contract was active during the period, involving expenditure of $2.5 million. | 17AG(7)(b) |
| Annual reports contain information about actual expenditure on reportable consultancy contracts. Information on the value of reportable consultancy contracts is available on the AusTender website. | 17AG(7)(d) |
| Decisions to engage consultants during 2020-21 were made in accordance with the PGPA Act and related regulations including the Commonwealth Procurement Rules and relevant internal policies. | 17AG(7)(c)(i) |
| The Department selects consultants through the use of panel arrangements or by making an open approach to market. | 17AG(7)(c)(ii) |
| The Department engages consultants when it requires specialist expertise on policy design, financial viability, and information technology strategic planning. Independent evaluations on the Department's outcomes are also required. | 17AG(7)(c)(iii) |
Expenditure on reportable non-consultancy contracts
Table 1
| Reportable non-consultancy contracts 2020-21 | Number | Expenditure $ | PGPA Rule requirement |
|---|---|---|---|
| New contracts entered into during the reporting period | 3 | $5,000,000 | 17AG(7A)(a)(i) & 17AG(7A)(a)(ii) |
| Ongoing contracts entered into during a previous reporting period | 5 | $9,200,000 | 17AG(7A)(a)(iii) & 17AG(7A)(a)(iv) |
| Total | 8 | $14,200,000 | - |
Table 2
| Organisations receiving a share of reportable non-consultancy contract expenditure 2020-21 | Expenditure | PGPA Rule Requirement |
|---|---|---|
| Genius Communications Ltd | $4,000,000 | 17AGA(3) |
| Finest Finance Pty Ltd | $3,000,000 | |
| Excellent Equipment Pty Ltd | $2,300,000 | |
| Skilful Training Pty Ltd | $2,000,000 | |
| Assistants-On-Call Pty Ltd | $1,500,000 | |
| Genius Media | $900,000 |
Table 3
| PGPA Rule requirement | |
|---|---|
| Annual reports contain information about actual expenditure on reportable non-consultancy contracts. Information on reportable non-consultancy contracts' value is available on the AusTender website. | 17AG(7A)(b) |
Best Practice Approach
To assist entities in meeting reporting requirements, Finance has collated best practice approaches based on previous reporting. It is important to note that these are not required by the PGPA Rule but will assist in the analysis of the information provided:
When reporting the largest share of the total expenditure for consultancy or non-consultancy contracts, entities may include:
- an additional column indicating what proportion of the overall expenditure that particular share is, and
- an additional row indicating the total expenditure of the largest shares combined and the proportion of the overall expenditure that total is.
Total reportable consultancy contract expenditure in 2020-21 = $13,080,000
| Organisations receiving a share of reportable consultancy contract expenditure 2020-21 | Expenditure $ | Proportion of 2020-21 total spend (%) |
|---|---|---|
| Advisors & Sons Pty Ltd | $8,000,000 | 61 |
| Finest Finance (Evaluations) Ltd | $2,500,000 | 19 |
| Finest Finance Ltd | $1,800,000 | 13.8 |
| Consultants R Us Pty Ltd | $500,000 | 3.8 |
| Best Expert Advice Pty Ltd | $200,000 | 1.5 |
| Total of the Largest Shares | $13,000,000 | 99.4 |
Total reportable non-consultancy contract expenditure in 2020-21 = $14,200,000
| Organisations receiving a share of reportable non-consultancy contract expenditure 2020-21 | Expenditure $ | Proportion of 2020-21 total spend (%) |
|---|---|---|
| Genius Communications Ltd | $4,000,000 | 28.2 |
| Finest Finance Pty Ltd | $3,000,000 | 21 |
| Excellent Equipment Pty Ltd | $2,300,000 | 16.2 |
| Skilful Training Pty Ltd | $2,000,000 | 14.1 |
| Assistants-On-Call Pty Ltd | $1,500,000 | 10.6 |
| Genius Media Ltd | $900,000 | 6.3 |
| Total of the Largest Shares | $13,700,000 | 96.5 |
