The NACC effect: what Australia’s anti-corruption commission means for public sector professionals   

Wednesday, 26 August 2026

Since passing its second anniversary in mid-2025, the National Anti-Corruption Commission (NACC) has steadily progressed its caseload, maintaining dozens of active corruption investigations and progressing multiple complex matters through the courts. Notably, joint operations alongside the Australian Federal Police and the Department of Defence demonstrated the agency’s growing enforcement footprint. The NACC is no longer a new institution finding its feet. It is an active, well-resourced regulator with defined priorities, published case studies, and a growing body of completed investigative work. Concurrently, the NACC is also navigating a leadership transition with resigning inaugural Commissioner Paul Brereton and Deputy Commissioner Nicole Rose both departed following their resignations in May 2026, and a new recruitment process commencing shortly after. The incoming leadership will inherit an institution with a substantial caseload but also a significant operational transition. What that means for public sector professionals beyond the legal and audit functions has not yet been widely understood.

What the NACC has identified as its priorities

The NACC’s Corporate Plan 2025-29 establishes six strategic corruption priorities. These include targeting corruption in senior executive decision-making, corruption involving contractors and consultants, corruption affecting vulnerable people or the environment, border-related corruption, and corruption in complex procurement. These are not aspirational categories. They are the thematic areas the Commission has identified as offering the greatest opportunity to add value in combating corruption across the public sector, and a matter that falls within these priorities is more likely to attract investigative attention, all else being equal.

The decision to prioritise complex procurement is significant. The NACC has defined “complex” procurement as high-value, requiring niche expertise, relying on a limited number of providers, or having complexity in funding or governance arrangements. That definition covers a substantial proportion of ICT, defence, infrastructure, and professional services spend. It also describes the conditions under which most significant corruption risk in government procurement actually arises: where competition is thin, where expertise is concentrated, and where the oversight structures struggle to keep pace with the technical complexity of what is being procured.

In Operation Rottnest in December 2025, the arrest of four individuals in the Northern Territory over alleged fraud in Defence contract awards was a public demonstration of that priority in action. The NACC confirmed that detecting and investigating alleged corruption in complex procurement activities is one of its strategic priorities, and that the public sector’s procurement spend makes corruption in these activities a source of substantial potential loss and waste.

The broader enforcement environment

The NACC does not operate in isolation. The enforcement landscape around it has intensified considerably. In the first six months of 2025, ASIC commenced 132 new investigations, more than double the 63 commenced in the same period the previous year. The new “failure to prevent foreign bribery” corporate offence, which came into effect in September 2024, extends liability to companies that fail to implement adequate procedures to prevent bribery by associates, including agents and contractors operating on their behalf overseas.

For public sector professionals, the relevance of these developments is not merely background context. They reflect a shift in how regulators across Australia are approaching accountability for organisational culture and individual conduct. The question being asked is no longer only whether wrongdoing occurred. It is whether the systems, policies, and capabilities that should have prevented or detected it were in place and functioning. That question applies to public sector entities as directly as it applies to corporations.

What corruption looks like in practice

The NACC’s 2024 Review was explicit about what it is seeing. The three main domains of perceived and actual corrupt conduct are procurement, recruitment and promotion, and the interface of the public sector with the private sector. In all three areas, the mechanisms are typically the preferring of family, friends and associates, and the misuse of official information to gain an advantage.

These are not the exotic forms of corruption that feature in foreign jurisdictions. They are structural risks that arise from the ordinary conditions of public sector work: long-term supplier relationships, personal networks that predate a role, access to tender information before it is publicly released, and the small decisions that accumulate into a pattern. They are also the forms of corruption that are most likely to be visible to colleagues before they are visible to investigators.

That observation matters for how public sector organisations think about corruption capability. The 2024 NACC’s Commonwealth Integrity Survey found that 96 per cent of public sector respondents felt confident they could identify corruption in their area of responsibility. The same survey, through hypothetical scenario questions, found evidence of significant gaps in applied comprehension. Confidence and capability are not the same thing, and the forms of corruption the NACC is actually seeing are precisely the ones that require applied judgement to identify, not just familiarity with a definition.

Why this extends beyond legal and audit functions

The Australian National Audit Office (ANAO)’s 2024-25 program continued its focus on integrity matters, including fraud control arrangements across multiple Commonwealth entities. The ANAO found that 32 per cent of responding entities had not tested the effectiveness of their fraud controls within the last two years, and that the most common audit recommendations related to revising fraud policies, testing control effectiveness, and improving capability. That last category is the one most directly relevant to non-specialist professionals.

Procurement officers, contract managers, grants administrators, and executive advisers are all regularly in positions where they encounter the conditions the NACC has identified as corruption-prone. They may not be the people who commit corrupt conduct. But they are often the people who observe it first, who have the information needed to document it, and who are responsible for the controls that either constrain or enable it. Whether they know how to respond when they see it depends on whether they have developed the capability to identify what they are looking at.

The NACC’s published case studies on Operations Angelo, Overbeek, and Roe, alongside the Operation Kingscliff findings, provide concrete illustrations of how corruption arises in familiar public sector settings. They are designed precisely to build this kind of recognition: not to turn procurement officers into investigators, but to equip them to understand what investigative relevance looks like so they can escalate appropriately when it appears.

Building the capability the environment now requires

The shift underway in Australia’s anti-corruption and enforcement environment is not temporary. The NACC is a permanent institution with growing casework and defined priorities. The foreign bribery regime has been fundamentally strengthened. The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms extend regulatory reach further into professional services from 2026 onward. Each of these changes raises the bar for what it means to work with integrity in the Australian public sector, and for what the organisations in which public sector professionals work are expected to ensure.

For professionals who want to meet that bar, the capability requirement is practical and applied, not theoretical. AcademyGlobal’s CIPFA International Certificate in Corruption Investigation provides that foundation: structured, practitioner-focused development in corruption identification, investigative frameworks, and the applied judgement that allows public sector professionals to recognise, document, and respond to integrity risks in the settings where their work actually takes place.

The NACC effect is real, and it is expanding. The professionals who will navigate it well are those who understand what corruption looks like in practice, not just in principle.

About the Author

Paul Vorbach is the Managing Director of AcademyGlobal, a Sydney-based capability development firm established in 2004 and the CIPS Centre of Excellence for ANZ. Since 2005, Paul has trained contract management, procurement and supply chain professionals across over twenty centuries in five continents. He is Vice President of the Institute of Strategic Risk Management (ISRM) ANZ, Treasurer of the Society of Risk Analysis (SRA) ANZ, and Adjunct Faculty at the Australian Graduate School of Management (AGSM) at the University of New South Wales.

AcademyGlobal partners with public sector, private sector, and not-for-profit organisations to build the capability that underpins sustainable delivery performance, and is the Chartered Institute of Procurement and Supply (CIPS) Centre of Excellence for Australia, New Zealand and Asia.