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Audit approach

The objectives of the audit were to:

  • assess the effectiveness of the ongoing administration of the Australian Government’s campaign advertising framework; and
  • assess the effectiveness of the selected entities’ administration in developing advertising campaigns and implementing key processes against the requirements of the campaign advertising framework applying at the time, and relevant legal and government policy requirements.

To form a conclusion against the audit objective, the ANAO adopted the following high-level criteria:

  • the effectiveness of Finance’s overall administration of the campaign advertising framework, including its advice to entities on framework developments;
  • progress made towards addressing any outstanding recommendations from previous ANAO audit reports on government advertising;
  • compliance of the specified campaigns with the campaign advertising framework and applicable guidelines, and compliance with relevant procurement and legal requirements; and
  • where the campaign advertising guidelines did not apply, entity processes applying to specified campaigns promoted the achievement of value for money.


Between November 2013 and February 2015, the Australian Government’s campaign advertising framework was weaker than it could be, due to the suspension of the third-party advisory process. The process was re-established in early 2015 with the appointment of a reconstituted Independent Communications Committee, but the early timing of the committee’s review of campaigns means that it is not in a position to provide a high level of confidence to entity chief executives—and by extension the Parliament and community—regarding a campaign’s compliance with the guidelines. At present, the committee reports on whether a campaign is ‘capable’ of complying with the guidelines, as it does not review final campaign materials and other relevant information. The committee’s terms of reference should be amended to enable its review at any stage of a campaign’s development.

All of the campaigns selected for review in this audit were certified at key stages by the responsible chief executives as complying with the applicable guidelines. One element of one of the campaigns was exempted from the guidelines on the basis of extreme urgency relating to a change in government policy, as provided for in the guidelines. The chief executive certifications were supported by detailed advice from their respective departments. The ANAO’s review of the information supporting that advice indicated that there were some shortcomings in advice and departmental processes relating to:

  • the Department of the Treasury’s Intergenerational Report 2015 Community Engagement campaign—compliance with procurement policies and procedures;
  • the Department of Education and Training’s Higher Education Reforms Communication campaign—presenting campaign materials in an objective and fair manner; compliance with procurement policies and procedures; and not advising the Secretary of concerns raised in relation to compliance with relevant legal requirements; and
  • the Department of Immigration and Border Protection’s anti-people smuggling advertising campaigns—compliance with procurement policies and procedures.

Campaign expenditure increased in the periods prior to the 2013 and 2016 federal elections, continuing a long-term trend. Average Australian Government expenditure each financial year since 2008–09 on advertising campaigns has been $186 million.1 In 2013 and 2016 approximately $100 million and $95 million respectively, was spent on media placement alone in the three months leading up to the caretaker period.

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