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Corruption and Integrity Update – July 2025

25 July 2025
Daniel Maroske, Partner, Brisbane

In this edition of the Queensland Corruption and Integrity Update we consider various updates related to the Crime and Corruption Commission (CCC), developments from the Councillor Conduct Tribunal (CCT), relevant updates arising from the 2025-26 Queensland Budget, and an update from the Electoral Commission Queensland (ECQ) about the 2024 State general election. We also consider updates from the Office of the Information Commissioner and the Queensland Integrity Commissioner.

Crime and Corruption Commission updates

CCC updated strategic plan

On 1 July 2025, the CCC released an updated 2023 to 2027 Strategic Plan, outlining its objectives and strategies over the coming years.

The core objectives, set out in the plan previously (and highlighted in the August 2024 edition of the Gadens Corruption and Integrity Update) remain:

  • to deliver efficient and effective outcomes in order to reduce major crime and corruption, and result in improved integrity in the Queensland public sector;
  • to develop the capability and ensure safety and wellbeing of team members by ensuring access to high-quality information and appropriate systems;
  • to be accessible to community in a way that exhibits accountability and promotes continued collaboration and confidence in the functions of the CCC; and
  • to facilitate continuous improvement by anticipating and responding to a challenging operating environment.

The strategic risks highlighted by the CCC continue to include increased use of technology and cybersecurity risks, new forms of digital technology that may influence intelligence, talent shortages and the changing nature of the workforce, regulation, changes within the CCC, public confidence in the CCC, and economic instability.

Finally, the CCC set out a number of performance metrics for 2025-26, including:

  • percentage of corruption investigations that result in significant outcomes;
  • corruption investigation clearance rate, and those that are finalised and commenced; and
  • the average cost per assessment of corrupt conduct or police misconduct complaints.

Review into CCC activities

The Parliamentary Crime and Corruption Committee (PCCC) has commenced its latest five-year review of the activities of the CCC (the Review) in accordance with section 292(f) of the Crime and Corruption Act 2001. In conducting the Review, the PCCC will examine the CCC’s performance over the course of the last five years, as well as considering its jurisdiction, responsibilities, functions and powers, as well as issues raised in its previous review and inquires.  The PCCC will examine the CCC’s performance in relation to various functions, including:

  • corporate governance and organisational structure;
  • investigative powers and hearings;
  • research and intelligence functions; and
  • oversight arrangements (including the role of the responsible Minister, committee, Parliamentary Crime and Corruption Commissioner and Public Interest Monitor).

Submissions are open until 3 October 2025, with public hearings to follow the review of submissions and the final report expected to be tabled by 30 June 2026.

CCC issues advice for public sector employees on public records

On 30 May 2025, the CCC and Queensland State Archives released guidance on the requirements and benefits of recordkeeping for employees of public authorities.

Key observations from the guide include:

  • a reminder to public authorities of their obligations under the Public Records Act 2023 (Qld) that records are made and kept of activities, public records are appropriately managed, and only disposed of when authorised;
  • While some types of public records are obvious, records will include information connected to a public record to contextualise the record, such as logs or meta data, and may include video footage, text messages, social media interactions, and messages in messaging applications;
  • Recordkeeping helps to ensure that public authorities make good decisions, have evidence of decisions made and actions taken, promotes confidence in the public service, protects against complaints and allegations of wrongdoing, and reduces the risk of corruption;
  • The CCC has identified that poor recordkeeping can enable corruption, or hinder or prolong corruption investigations; and
  • a checklist for employees covering public records and their lifecycle including capture and creation, storage and management, and disposal. In particular with disposal, regard must be had to whether the public records are subject to an access application under the Right to Information Act 2009 (Qld) or may be required in legal proceedings.

Quarterly update on Commission of Inquiry recommendation implementation

On 9 July 2025, the CCC released its tenth quarterly report on the ‘Implementation and delivery of COI recommendations’. The CCC continues progressing its implementation of the recommendations since the last report, with only the following recommendations still in progress:

  • Recommendations 7 and 9: the CCC is progressing its transition to a predominately civilianised model for its Corruption Division. Specifically, the CCC is due to complete the recommendations by 30 June 2026, when 70 per cent of the corruption investigator cohort will be civilians, with the remaining 30 per cent being seconded police officers;
  • Recommendation 21: the CCC continues its review of operational policies and procedures in accordance with legislative and operational changes. Given the recent passage of the Crime and Corruption Amendment Act 2024 (Qld), which made significant amendments to the Crime and Corruption Act 2001 (Qld), updates will need to be made to the CCC’s operational policies;
  • Recommendation 24: the CCC, in consultation with the Office of the Director of Public Prosecutions, has developed a draft post-prosecution review process, which includes policies and procedures to guide the process for conducting reviews; and
  • Recommendation 29: the CCC has noted, but not yet commenced, reviewing and examining the effectiveness and utility of the Memorandum of Understanding which establishes an arrangement whereby the Director of Public Prosecutions can provide advice to the CCC.

Budget update

On 24 June 2025, the Queensland Government handed down its 2025-26 budget.

Key budget highlights for some of Queensland’s integrity bodies include:

  • CCC: Key deliverables for 2025-26 highlighted included investigating and shaping effective responses to serious and organised crime through the utilisation of hearing powers, investigation of complaints relating to conduct that is serious or systemic, the completion of implementation of recommendations from the COI, and engagement with key stakeholders and the community.
  • Office of the Queensland Integrity Commissioner:
    • an additional $7.1 million in funding over 4 years, and $1.9 million annually to assist the OQIC to operate effectively, meet increased demand for services and ensure its statutory functions are properly discharged; and
    • Key deliverables for 2025-26 highlighted included completion of the transition to an independent statutory body, finalisation of the review of the Queensland Registered Lobbyists Code of Conduct and implementation of enhancements to the Lobbying Register, and delivery of mandatory lobbyist training.
  • Office of the Queensland Ombudsman: Key deliverables for 2025-26 highlighted included delivery of services assisting people to know how to make a complaint, provision of an independent investigation service reviewing administrative actions of government departments, and assisting agencies with decision-making, administrative practices and Public Interest Disclosures.

The budget also includes an additional $19.7 million over two years for the Commission of Inquiry into the Child Safety System, and an additional $1 million in funding over two years for an independent review of Queensland’s DNA testing operations and reform progress, which follows the 2022 Commission of Inquiry into Forensic DNA Testing in Queensland and the 2023 Commission of Inquiry to examine DNA Project 13 concerns.

Office of the Information Commissioner

Report relating to implementation of recommendations through staff education

On 11 June 2025, the Queensland Information Commissioner tabled its report entitled ‘Follow-up of Report No. 1 for 2022-23 – Mitigating the risks of privacy breach through staff education’ (the Follow-up Report). The Follow-up Report is the third in a series that examines how agencies educate and train their employees about their obligations under the Information Privacy Act 2009 (Qld).

In November 2022, the Information Commissioners had made ten recommendations to the Department of Transport and Main Roads, WorkCover Queensland and the Queensland Rural and Industry Development Authority (QRIDA) which broadly can be summarised as including:

  • six recommendations relating to information privacy and information security training content;
  • recommendations were made to each agency to ensure employees completed training when it was due; and
  • at the time the recommendations were made, QRIDA demonstrated the most room for improvement in ensuring that training materials were accurate, appropriate, and tailored to the workforce.

In June 2024, the OIC commenced a follow-up audit to assess the progress of the relevant agencies in the implementation of the recommendations. The audit revealed significant progress in the implementation of recommendations, with five being fully implemented.

Key observations of the Follow-up Report included:

  • while mandatory training was required of QRIDA employees in information privacy and security, the obligations to complete training had not been explicitly mandated in relevant policies and procedures;
  • each agency made progress in ensuring employees completed information privacy and security training, with 96 percent of employees in the respective agencies completing training;
  • QRIDA tailored training content to the agency’s specific functions, but it was observed that there were gaps within the training that could create risk for QRIDA employees; and
  • WorkCover updated information privacy training to ensure materials were comprehensive and detailed.

Public briefing with Department of Local Government, Water and Volunteers

On 11 June 2025, a public briefing was held with the Department of Local Government, Water and Volunteers. The Department provided an update relating to upcoming priorities including the parliamentary review of:

  • the Local Government (Councillor Conduct) and Other Legislation Amendment Bill; and
  • the operations of the Office of the Independent Assessor and Councillor Conduct Tribunal.

It was noted that a commitment of the Department was a review of the complaints framework for councillors, including the operations of the Independent Assessor and the Councillor Conduct Tribunal. The Department noted that the initial determination of complaints, which includes an assessment of whether a complaint is ‘frivolous’ is undertaken by the Office of the Independent Assessor, and that the Office of the Independent Assessor necessarily is separated from the Department.

The Department supports 77 councils and 578 councillors throughout Queensland, including providing formal training and advice, which was particularly relevant in the aftermath of the 2024 local government elections that resulted in significant turnover in the councillor cohort. Of the mandatory councillor training that is administered by the Department, one module of the Local Government Leaders Program specifically focuses on conflicts of interest, registers of interest, and the code of conduct, with required completion within six months of a councillor’s election.

Electoral Commission Queensland Report on 2024 State Election

On 23 June 2025, the ECQ tabled its report entitled ‘2024 State general election report’. The ECQ is required to report on the operation of part 7 of the Electoral Act 1992 in relation to the State general election, which most recently was held in October 2024.

During the election period, ECQ compliance activities were focused on the proper authorisation of election material, compliance with signage requirements at polling places and increasing awareness of electoral laws in relation to these matters.

During the State general election, the ECQ dealt with 55 notifications of potential non-compliance as follows:

  • 41 matters were assessed as not breaching authorisation requirements;
  • one matter was found to be the fault of the publisher, not the electoral participant;
  • ten matters were rectified by the electoral participant upon being contacted by the ECQ and no further action was required;
  • two matters were finalised by issuing penalty infringement notices; and
  • two matters were unable to be resolved as the author of the election matter was unable to be identified.

To uphold electoral integrity and counter disinformation, the ECQ adopted a proactive strategy by making accurate information about the electoral process readily available to Queenslanders through its website and social media platforms. The ECQ also collaborated with the Australian Government’s Electoral Integrity Assurance Taskforce to support the ECQ in monitoring threats of potential interference at the election.

Office of the Queensland Integrity Commissioner

Directive issued to lobbyists

On 19 June 2025, a directive made by the Queensland Integrity Commissioner, entitled ‘Mandatory Foundational Training for Registered Lobbyists’ took effect. The directive was made under section 57(1)(a) and (c) of the Integrity Act 2009 and specified that registered lobbyists were required to undertake an approved foundational training course. All lobbyists registered on or before 1 June 2025 are required to complete the approved training course on or before the 31 July 2025, whereas lobbyist registered after 1 June have two months from the date of their registration as a lobbyist. Failure to comply with the directive is a ground for taking regulatory action or imposing sanctions under the Integrity Act 2009.

Councillor Conduct Tribunal Decision

On 23 June 2025, the Councillor Conduct Tribunal (CCT) published its decision and reasons relating to alleged misconduct of two Councillors from Ipswich City Council (Council).

The decision considered five allegations against the one councillor (the First Councillor) and one allegation against another councillor (the Second Councillor) pursuant to section 150L(1)(a) of the Local Government Act 2009 (Qld) (LG Act). The allegations arose following disruption within Council that followed the dismissal of the entire Council due to allegations of impropriety (and subsequent criminal convictions) that involved former Mayor Paul Pisasale.

The allegations relating to both councillors arose from decisions to appear on several media platforms where the councillors made statements regarding the decision of Council and the preparation of a Community Engagement Report that the First Councillor and Second Councillor formed the view that it did not reflect the feedback of all community members that participated. Both councillors initially raised their concerns with the Council CEO unsuccessfully, after which time the councillors made various public statements, to which the allegations related:

  • three radio interviews undertaken by the First Councillor on 1 and 2 July 2022 (three allegations);
  • a Facebook post made on the First Councillor’s official Facebook page on 7 July 2022 (one allegation);
  • a joint press conference between the First Councillor and the Second Councillor on 7 July 2022 (two allegations).

The CCT found that neither the First Councillor nor the Second Councillor engaged in dishonesty, and raised their concerns under their obligations under sections 4(2) and 12(3) of the LG Act, and that their actions in making various public statements stemmed from their “obligation to ensure the ratepayers of the Council’s jurisdiction were aware of the concerns”.  The CCT determined that neither the First Councillor nor the Second Councillor engaged in misconduct under section 150AQ(1)(a)(ii) of the LG Act, and no recommendations were made.

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Authored by:
Daniel Maroske, Partner
Anna Fanelli, Senior Associate
Jacinta Beecher, Lawyer
Caitlin Holmes, Lawyer
Jonathan Kumar, Legal Assistant

This update does not constitute legal advice and should not be relied upon as such. It is intended only to provide a summary and general overview on matters of interest and it is not intended to be comprehensive. You should seek legal or other professional advice before acting or relying on any of the content.

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