Background

1. The Australian Government’s campaign advertising framework (the framework) applies to non-corporate Commonwealth entities under the Public Governance, Performance and Accountability Act 2013 (PGPA Act).¹ The overarching aim of the framework, introduced in 2008, is to provide the Parliament and the community with confidence that public funds are used to meet the genuine information needs of the community.²

2. The government periodically issues guidance for entities undertaking information and advertising campaigns. The most recent version of the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities (the Guidelines) was released in December 2022 (2022 Guidelines)³, replacing the October 2020 Guidelines (2020 Guidelines). The Guidelines are administered by the Department of Finance (Finance) and state that they:

operate on the underpinning premise that:

1. members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations; and
2. governments may legitimately use public funds to explain government policies, programs or services, to inform members of the public of their obligations, rights and entitlements, to encourage informed consideration of issues or to change behaviour.⁴

3. The Guidelines apply to all information and advertising campaigns⁵ undertaken in Australia by non-corporate Commonwealth entities.⁶ Entities subject to them:

must be able to demonstrate compliance with the five overarching principles when planning, developing and implementing publicly-funded information and advertising campaigns. The principles require that campaigns are:

• relevant to government responsibilities
• presented in an objective, fair and accessible manner
• objective and not directed at promoting party political interests
• justified and undertaken in an efficient, effective and relevant manner, and
• compliant with legal requirements and procurement policies and procedures⁷

Rationale for undertaking the audit

4. This audit is part of an ongoing program of performance audits on Australian Government advertising. The rationale for undertaking this audit is to provide the Parliament with information on key developments in the framework since the period covered by the 2022 ANAO audit⁸, when the ANAO last reported on its operation.

5. The audit provides independent assurance on whole-of-government administration of the framework by the Department of Finance and selected entities’ compliance with the Guidelines and the wider framework requirements.

Audit objective and criteria

6. The objective of the audit was to assess the effectiveness of the Department of Finance’s and selected entities’ implementation of the Australian Government’s campaign advertising framework.

7. To form a conclusion against this objective, the following high-level criteria were adopted:

• Does the Department of Finance effectively administer the Australian Government’s campaign advertising framework?
• Were selected campaigns compliant with the Australian Government’s campaign advertising framework?

8. The audit examined developments in the administration of the framework from November 2021 to November 2024. Three campaigns were selected for review:

• One Talk at a Time campaign, conducted from October 2023 to April 2025, administered by the Attorney-General’s Department (AGD)⁹;
• Your Answer Matters campaign, conducted from August to October 2023, administered by Australian Electoral Commission (AEC)¹⁰; and
• Youth Vaping Education (phase one) campaign, conducted from February to June 2024, administered by the Department of Health and Aged Care (Health).¹¹

Conclusion

9. Finance has been effective at administering the framework. AGD and Health were largely compliant with the framework. The AEC largely complied with its internal requirements and the intent of the framework.

10. Finance has supported entities undertaking campaigns and has arrangements in place to manage brand safety risks relating to advertising on social media platforms. There are emerging gaps relating to the identification and management of risks, including to brand safety, associated with the use of artificial intelligence (AI) and emerging technologies in government advertising campaigns, and the changing nature of campaign activities, such as the use of media partnerships and influencers to reach target audiences in government campaigns. Finance extended the whole-of-government Master Media Agency contract after all extension options had been exercised. Finance has met its reporting requirements for expenditure on advertising campaigns.

11. AGD’s One Talk at a Time campaign largely complied with the review, certification and publication requirements of the framework. AGD complied with the requirements of Principles 1 to 3 and largely complied with Principles 4 and 5 of the 2020 Guidelines. Campaign effectiveness was reduced by the delayed implementation of pre-launch public relations activities. Not all campaign materials contained appropriate attribution of Australian Government involvement and two procurements were not accurately reported on AusTender. The advertising component of the campaign was evaluated, with the evaluation report finding that the campaign ‘achieved’ one objective and ‘partially achieved’ two objectives. At November 2024, an evaluation addressing other aspects of the campaign had not been undertaken as public relations activities were still underway.

12. Since 2009, the AEC has had an exemption from most aspects of the framework and has committed to complying with the intent of the 2022 Guidelines. Documentation capturing the AEC’s requirements for campaign development and certification, known as ‘AEC communication campaigns: Guidelines and mandatory checklist’ (AEC Guidelines), was in draft and there was no documented approval. The AEC’s Your Answer Matters campaign largely complied with the review and publication requirements. Publication requirements were met, although AEC did not publish campaign research reports, did not document consideration of whether doing so was appropriate and there were inaccuracies in the reporting of campaign expenditure figures in the AEC annual report and subsequent reporting to the Department of Finance. The AEC complied with Principles 1 to 4 of the 2022 Guidelines and largely complied with Principle 5. Legal advice addressing all legal requirements of Principle 5 was finalised after the campaign had commenced. The AEC’s requirements for attribution of AEC contribution to media partnerships and public relations materials was not documented. The AEC evaluated the campaign with the evaluation report finding that of the total 23 objectives, 16 were ‘met’, six were ‘partly met’ and one was ‘not met’.

13. Health largely complied with the review, certification and publication requirements of the framework. Health complied with the requirements of Principles 1, 3 and 4 of the 2022 Guidelines and largely complied with Principles 2 and 5 of the 2022 Guidelines. Health did not document how campaign imagery reflected a diverse range of Australians. Not all campaign materials contained attribution of Australian Government involvement. Health evaluated the Youth Vaping Education (phase one) campaign to determine its effectiveness. The evaluation report consolidated the campaign’s original seven objectives into four objectives. The evaluation found that two objectives were achieved and two objectives were partially achieved.

Supporting findings

Administration of the Australian Government campaign advertising framework — Finance

14. Finance maintains a suite of guidance documents on a clearly signposted section of its website and manages a campaign community through its GovTEAMS site to support entities undertaking campaigns throughout the campaign advertising development process. Finance facilitates the Independent Communications Committee’s review process and provides advice to government regarding requests for exemption from the Guidelines. Finance has established arrangements to receive feedback from suppliers and entities through evaluations undertaken at the end of campaigns, with annual reviews providing a whole-of-government view across all campaigns. (See paragraphs 2.3 to 2.21)

15. Finance has arrangements to manage risks relating to brand safety on social media platforms. Given the changing nature of campaign activities there are emerging gaps in relation to the use of media partnerships, public relations and influencers. Gaps relate to the appropriateness of the level of information relating to these activities provided for final government review and the attribution of campaign materials. There is an absence of guidance around emerging risks, including to brand safety, relating to the potential use of AI and emerging technologies in advertising and information campaigns. Finance extended the whole-of-government Master Media Agency contract after all extension options had been exercised. ( See paragraphs 2.22 to 2.80)

16. Finance has reported to the Parliament on annual media placement and associated campaign development expenditure by non-corporate Commonwealth entities, for campaigns with expenditure greater than $250,000 (exclusive of GST), in its annual report on Campaign Advertising by Australian Government Departments and Entities. Details of expenditure relating to Finance’s contracts with the Master Media Agency and Independent Communications Committee (ICC) members have not been included in these reports. Finance guidance does not address the publication of advertising campaign research reports which, under the 2022 Guidelines, must be published on entity websites ‘where it is appropriate to do so’ for campaigns with an expenditure of $250,000 (exclusive of GST) or more. (See paragraphs 2.81 to 2.93)

One Talk at a Time campaign

17. AGD’s One Talk at a Time campaign received government approvals in accordance with the framework requirements applying at the time it was considered.

18. The Secretary of the Attorney-General’s Department (Secretary of AGD), as the accountable authority, certified that the campaign complied with all five principles of the 2020 Guidelines and the certification was published on AGD’s website, as required. The Secretary’s certification was informed by a third-party certification from the ICC, as required by the 2020 Guidelines, and AGD advice on compliance. AGD provided the Attorney-General with the signed Secretary’s certification.

19. AGD complied with publication requirements, except for those relating to the statement in its 2023–24 annual report. AGD published its developmental research report on the One Talk at a Time campaign website. (See paragraphs 3.14 to 3.24)

20. AGD complied with Principles 1 to 3 of the 2020 Guidelines and largely complied with Principles 4 and 5.

21. For Principle 4, campaign effectiveness was reduced by the delayed execution of pre-launch public relations activities. For Principle 5, 17 of the 21 media partnership materials had appropriate attribution statements noting Australian Government involvement and two of the campaign procurements were not accurately reported on AusTender. (See paragraphs 3.25 to 3.62)

22. Advertising components of the One Talk at a Time campaign were evaluated to determine their effectiveness. This evaluation identified that the advertising component of the campaign ‘achieved’ one objective and ‘partially achieved’ two objectives. At November 2024, the planned integrated evaluation of all campaign components, including media partnerships and public relations, had not been completed.

23. The performance of the campaign was monitored against media metrics, including key performance indicators (KPIs). AGD received in-flight monitoring of the campaign’s performance, including a mid-campaign report and a final media performance report. (See paragraphs 3.63 to 3.71)

Your Answer Matters campaign

24. Due to its exemption, the AEC was not subject to review by the ICC or government review and approval processes. The AEC had documented requirements for campaign development and certification in the form of the AEC Guidelines. The version of the AEC Guidelines used for the Your Answer Matters campaign was in draft and there was no documented approval.

25. Under the AEC Guidelines, the AEC has committed to complying with the intent of the 2022 Guidelines. The AEC Guidelines did not establish a requirement for legal advice confirming compliance with Principle 5 of the 2022 Guidelines to be provided to the Electoral Commissioner prior to campaign certification.

26. The AEC followed an internal review process that involved the Electoral Commissioner providing approval for key campaign development milestones. The Electoral Commissioner signed two certifications for the campaign, which were both published on the AEC’s website in accordance with the AEC Guidelines. The AEC did not publish campaign research reports on its website and did not document consideration of whether publication of the research reports was appropriate and there were inaccuracies in the reporting of campaign expenditure figures in the AEC annual report and subsequent reporting to the Department of Finance. (See paragraphs 4.18 to 4.40)

27. The AEC complied with the intent of Principles 1 to 4 of the 2022 Guidelines and largely complied with Principle 5. Legal advice addressing all legal requirements of Principle 5 was finalised after the campaign had commenced. The AEC had not documented attribution requirements for media partnerships or public relations materials. Details of one procurement were not accurately reported on AusTender. (See paragraphs 4.41 to 4.78)

28. The Your Answer Matters campaign was evaluated to determine its effectiveness. Of the 23 objectives across the five phases of the campaign, 16 were assessed as ‘met’, six were assessed as ‘partly met’ and one was assessed as ‘not met’.

29. The performance of the campaign was monitored against media metrics, including KPIs. The AEC received weekly reporting on the performance of media channels. (See paragraphs 4.79 to 4.85)

Youth Vaping Education (phase one) campaign

30. Health’s Youth Vaping Education (phase one) campaign received government approvals in accordance with the framework requirements applying at the time it was considered.

31. The accountable authority, the Secretary of the Department of Health and Aged Care (Secretary of Health and Aged Care), certified that the campaign complied with the five ‘overarching principles’ of the 2022 Guidelines and the certification was published on Health’s website, as required. The Secretary’s certification was informed by a third-party review from the ICC, as required by the 2022 Guidelines, and Health advice on compliance. Health provided the Secretary’s certification to the Minister for Health and Aged Care on 3 May 2024, approximately three months after the campaign commenced, which was not compliant with the 2022 Guidelines.

32. Health complied with publication requirements. Health published the campaign developmental research report on its website. (See paragraphs 5.12 to 5.23)

33. Health complied with Principles 1, 3 and 4 and largely complied with Principles 2 and 5 of the 2022 Guidelines.

34. For Principle 2, Health did not document how campaign imagery reflected a diverse range of Australians. Legal advice provided in support of compliance with Principle 5 addressed the media partnerships component of the campaign but not the influencer component. Seventeen of the 28 media partnership materials did not contain attribution of Australian Government contribution to the materials. Health’s audit trail of procurement decision-making was mostly complete. (See paragraphs 5.24 to 5.74)

35. Health evaluated the Youth Vaping Education (phase one) campaign to determine its effectiveness. The evaluation report consolidated the campaign’s original seven objectives into four objectives. The evaluation found that two objectives were achieved and two objectives were partially achieved.

36. Campaign performance was monitored against media metrics, including KPIs. Health received in-flight monitoring of the campaign’s performance, including a report on the performance of influencers, a mid-campaign report and a final media performance report. (See paragraphs 5.75 to 5.82)

Recommendations

Summary of entity responses

37. The proposed audit report was provided to Finance, AGD, AEC and Health, with an extract being provided to the Independent Communications Committee. The entities’ summary responses are provided below, and their full responses are included at Appendix 1. Improvements observed by the ANAO during the course of this audit are listed in Appendix 2.

Department of Finance

The Department of Finance welcomes the conclusion that the Department has been effective in the whole-of-government administration of the Government’s campaign advertising framework, including Finance’s role in supporting entities, providing secretariat support to the Independent Communications Committee, meeting its requirements for reporting on campaign advertising expenditure by non-corporate Commonwealth entities, and having arrangements in place to manage brand safety risks relating to advertising on social media platforms.

Finance agrees the two recommendations directed to the Department and will take appropriate action to address the matters raised.

Attorney-General’s Department

The Attorney-General’s Department (the department) welcomes the Australian National Audit Office’s (ANAO) report on Australian Government Advertising: November 2021 to November 2024, in particular the findings for the department’s “One Talk at a Time” campaign.

The department agrees with the recommendations and acknowledges the opportunity for administrative improvements in relation to record keeping, attribution of Australian Government involvement in campaign activity and reporting on AusTender.

The department acknowledges the ANAO’s finding that the campaign successfully achieved one objective and “partially achieved” two others. However, the full evaluation of the campaign’s effectiveness is yet to be completed and is expected to conclude in 2025, following the completion of below-the-line activities.

The department is committed to continuous improvement and will use the ANAO’s findings and recommendations to further refine our campaign processes and guidance.

Australian Electoral Commission

The Australian Electoral Commission (AEC) welcomes the ANAO report.

The AEC notes it is exempt from the Australian Government Guidelines on Information and Advertising Campaigns by non-corporate Commonwealth entities, including exemption from review and approval of AEC campaigns by government. This is due to the need for campaigns on electoral events to be independent of government. Instead, the AEC has its own Guidelines and certification process.

The AEC agrees with the one recommendation relating to improvement of our own Guidelines; and acknowledges the areas for improvement. We have reviewed and are addressing the highlighted administrative processes, noting they do not compromise compliance with our Guidelines.

The AEC remains committed to continuous improvement, and to our ongoing conformance with the intent of the Australian Government Guidelines.

Department of Health and Aged Care

The Department of Health and Aged Care (the department) acknowledges the findings in this report. The department is committed to responding to the opportunities for improvement identified by the Australian National Audit Office.

It is pleasing to note the finding the department was largely compliant with the Australian Government’s campaign advertising framework, including the review, certification and publication requirements.

The department also welcomes the finding the department complied with the requirements of Principles 1, 3 and 4 of the 2022 Australian Government Guidelines on Information and Advertising Campaigns and largely complied with Principles 2 and 5 of the Guidelines. The department also appreciates the report’s recognition the department established arrangements and processes to meet the objectivity requirements of Principle 2 of the Guidelines and mitigate the risks associated with engaging with influencers.

The audit identified two opportunities to improve the documentation of how a diverse range of Australians are reflected in campaign imagery and ensuring campaign materials contain appropriate attribution of the department’s involvement. To address these findings, the department will continue to strengthen its administrative processes when implementing government advertising campaigns.