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The Information Publication Scheme (IPS), marked by proactive release and publication of government information, continues to be an important element in ensuring information held by Australian government agencies is managed for public purposes and is treated as a national resource.
Compliance with the IPS is an ongoing statutory responsibility for agencies subject to the Freedom of Information Act 1982 (FOI Act). Agencies must publish an IPS Plan, select information for publication, ensure that information is accessible and useable by the community, establish internal governance arrangements to support the IPS, align the agency’s information assets with IPS objectives and regularly review the agency’s performance.
The Office of the Australian Information Commissioner (OAIC) undertook an initial survey of agencies’ compliance with IPS obligations in June 2012, one year after the scheme was adopted. The 2012 survey results demonstrated a strong commitment across government to comply with the new IPS requirements and principles.
In 2018, the OAIC commissioned ORIMA Research to conduct a second survey of Australian Government agencies’ compliance with their IPS obligations. The focus of the 2018 survey was similar to the 2012 survey to facilitate a comparison of results between the two surveys and to measure changes in agency compliance levels over time.
A total of 190 agencies participated in the survey out of 232 agencies that were invited to take part, representing a solid response rate of 82%, above the 2012 response rate of 78%.
The results confirmed a continued commitment across government to IPS requirements and principles. However, a decline was observed in each of the four key areas of compliance measured by the survey in 2012 and 2018. Larger agencies generally reported higher levels of compliance with IPS requirements and better practice principles, compared with micro, extra small and small agencies.
The results of the survey help both the OAIC and agencies identify areas where improvements can be made to support the proactive publication of information held by Australian government agencies. The involvement of senior leaders in agencies will be key to promoting the value of the IPS in enabling a proactive approach to releasing information into the future.
Both the volume of information handled by agencies and the manner in which the public accesses information has changed since the first survey was conducted in 2012. The OAIC will review its guidance and other resources to assist with agency compliance and support better practice, taking into account changes in the operating environment.
I look forward to working together with agencies as we continue to promote a proactive approach to publishing government information by further strengthening the IPS.
Australian Information Commissioner
2. Executive summary
In April 2018, ORIMA Research was commissioned by the Office of the Australian Information Commissioner (OAIC) to conduct a survey of Australian Government agencies compliance with the Information Publication Scheme (IPS) under the Freedom of Information Act 1982 (FOI Act). A total of 190 agencies participated in the survey out of 232 agencies that were invited to take part, representing a strong response rate of 82 per cent.
In June 2012 the OAIC conducted the initial survey of agencies’ compliance with IPS obligations and management and publication of public sector information by agencies . The 2018 IPS survey aligns with the 2012 survey to allow tracking of changes in agency compliance levels over time.
2.2. IPS compliance
Agency IPS operation review
82% of agencies have now completed a review of the operation of the IPS in their agency
Eighty two per cent of agencies completed the 2018 IPS survey, and are now considered by the Information Commissioner to have reviewed the IPS in their agency.
Fourteen per cent of agencies had completed a review of the operation of the IPS in their agency prior to participating in the survey.
Among agencies that completed an IPS Operation Review before the survey, 44 per cent completed this review in the last 12 months and 41 per cent did so more than two years ago.
At least 90 per cent of agencies who completed an IPS review before completing the survey covered each of the five key elements of IPS compliance set out in Part 13 of the FOI Guidelines (see Figure 1):
- almost all agencies reviewed their IPS document holdings (96 per cent), agency plan (96 per cent) and IPS information architecture (96 per cent)
- ninety-three per cent indicated that their reviews included coverage of their agency compliance review and governance and administration.
Figure 1: Coverage of the five key elements of IPS compliance in review of the operation of agencies’ IPS
Base: Agencies that completed a review of the operation of the IPS
Figure 1: Long text description
The agency IPS plan
88% of agencies have published an Agency IPS plan
The proportion of agencies that had published an Agency IPS Plan in 2018 was 88 per cent, compared to 94 per cent in 2012. Reasons provided by agencies for not publishing an IPS plan included the plan currently being in development, having insufficient resources to do so, not being aware of the requirement or the plan not being considered relevant.
Of those agencies with a published IPS agency plan, 89 per cent used some or all of the standard headings recommended by the OAIC. This is lower than the 96 per cent recorded for the same measure in 2012. The proportion using all five standard headings declined from 76 per cent in 2012 to 62 per cent in 2018 (see Figure 2). Most agencies that did not use the standard headings indicated that they used similar headings and language that reflected the intended content and which were, for some agencies, considered more user friendly. The OAIC will consider this feedback when updating the FOI Guidelines.
Figure 2: The extent to which agencies use the five standard recommended headings in their Agency IPS Plan
Base: Agencies who have published an Agency IPS Plan
Figure 2: Long text description
In 2018, coverage of recommended content in IPS agency plans was lower than in 2012. At least two-thirds of agencies included most of the matters specified in the FOI guidelines. However, only 37 per cent of agencies indicated that their plan specified whether an internal IPS information register had been developed (down from 50 per cent in 2012). Twenty two per cent specified the measures (if any) being taken to improve the agency’s information asset management framework to support its IPS compliance down from 53 per cent in 2012.
The survey also found that the practice of updating agency IPS plans was inconsistent.
As shown in Figure 3, while 32 per cent of agencies had updated their Agency IPS Plan within the last year, 29 per cent had updated their plan more than two years ago and 34 per cent had not updated their plan since it was first published (which was most commonly either over five years ago (68 per cent) or three to five years ago (16 per cent)).
Sixty-two per cent of agencies indicated they have a timetable for formally reviewing their Agency IPS Plan—compared with 84 per cent recorded in 2012. Among agencies that have a timetable, 59 per cent planned to review the plan at least every 12 months, and five per cent planned to review it every six months.
IPS governance and administration
76% of agencies have appointed a senior executive officer to lead the agency’s work on IPS compliance
Seventy-six per cent of agencies indicated they have appointed a senior executive officer to lead the agency’s work on IPS compliance. This result is lower than the 93 per cent recorded in 2012.
As shown in Figure 4, only 27 per cent of agencies indicated they have a formal IPS governance structure, down from 47 per cent in 2012. The most common reasons noted for not having a formal IPS governance structure were related to agency size and resourcing constraints.
Figure 5 shows that among those with a formal IPS governance structure, this was most likely to be some ‘other’ governance structure (55 per cent). These ‘other’ governance structures included IPS-related project teams, FOI contact officers or units and Boards, such as a Corporate Governance Board. A relatively smaller proportion of agencies identified that their formal IPS governance structure(s) consisted of a working group (37 per cent) and/or steering committee (14 per cent).
54% of agencies have assigned responsibility for the management or coordination of staff training and awareness of IPS obligations
Fifty-four per cent of agencies have assigned responsibility for the management or coordination of staff training and awareness of IPS obligations – below 73 per cent in 2012. Sixteen per cent of agencies indicated that induction training for new staff includes information on the IPS (compared to 23 per cent in 2012), while 25 per cent indicated they provide staff with other specific training on IPS obligations (lower than the 49 per cent recorded in 2012).
Over 70% of agencies publish each of the required types of information on their website
In 2018, over 70 per cent of agencies indicated they publish each of the required types of information on their website. Information relating to annual reports, organisation structures, agency’s functions and decision making powers, and contact details for FOI information or documents were most commonly published (by at least 95 per cent of agencies in 2018, which remains broadly similar to the results recorded in 2012). However, the proportion of agencies publishing other types of information has declined since 2012. The types of information that were least likely to be published and also had the greatest rate of decline since 2012 included:
- information in documents to which agencies routinely give access in response to requests under Part III of the FOI Act – s 8(2)(g) (79 per cent, down from 86 per cent in 2012)
- consultation arrangements for members of the public to comment on specific policy proposals for which the agency is responsible (72 per cent, down from 86 per cent in 2012).
Forty-two per cent of agencies indicated they have made a decision not to publish information under the IPS due to the personal or business information exception in s 11C of the FOI Act, higher than the 36 per cent recorded in 2012.
Thirty-eight per cent of agencies indicated that they maintain an IPS information register (see Figure 6). Fifty-three per cent of agencies without an IPS information register indicated that they plan to develop one in the next 12 months.
A minority of agencies with IPS information registers indicated that they reviewed their registers every six (14 per cent) or every 12 months (22 per cent), with a larger share indicating that they reviewed their registers only when significant IPS changes occur (36 per cent) or that they did not know when the review occurred (28 per cent).
Figure 7: Frequency at which agencies review their IPS information register
Base: Agencies that maintain an IPS information register
Figure 7: Long text description
More agencies (73 per cent) indicated that they do not charge for information required or permitted to be published under the IPS in 2018, up from 68 per cent in 2012.
IPS information architecture
More than 70% of agencies use six out of the 10 recommended standardised headings and structure
While most agencies present their IPS information using the 10 recommended headings specified in the FOI Guidelines, there has been a reduction in usage of each of these headings since 2012. More than 70 per cent of agencies used six out of the 10 recommended headings, compared with more than three-quarters of agencies that used seven out the 10 recommended headings in 2012. Agencies were most likely to use headings such as ‘Contact us’ (85 per cent) and ‘What we do’ (79 per cent) in 2018. However, less than half of agencies indicated that they presented their information under the headings ‘Our priorities’ (49 per cent), ‘Our finances’ (46 per cent) and ‘Our lists’ (39 per cent).
There was a substantial improvement in the accessibility of IPS documents in 2018. In particular, 69 per cent of agencies indicated that all or most documents they have published under the IPS are in a format (or multiple formats) which conform to Web Content Accessibility Guidelines (WCAG) 2.0 requirements, which is considerably more than 50 per cent in 2012.
The survey also found considerable variation in the proportion of agencies that provide access to website features that assist in the discoverability and understanding of information published under the IPS.
- sixty-three per cent of agencies reported they have a search function that can access information published within an agency’s IPS entry, down from 81 per cent in 2012
- twenty-five per cent of agencies indicated that the OAIC IPS Icon is visible on the homepage of their website, less than half the proportion recorded in 2012 (59 per cent).
2.3. Management and publication of public sector information
Open access to information
35% of agencies have adopted a strategy for increasing open access to public sector information
Thirty-five per cent of agencies indicated that they have adopted a strategy for increasing open access to public sector information held by their agency, in addition to the information required to be published in the IPS and Disclosure Log (up from 27 per cent in 2012). The proportion of agencies indicating that this strategy is under development in 2018 declined from 2012 (26 per cent, down from 48 per cent). The proportion who indicated that they have not adopted this strategy has increased (from 25 per cent to 39 per cent).
Sixty-seven per cent of agencies indicated that they used social media sites to publish or promote access to public sector information (including linking to information published on their agency’s website). They were most likely to use Twitter (62 per cent), followed by YouTube (47 per cent) and Facebook (46 per cent).
In 2018, the majority of agencies indicated that most (36 per cent) or all (24 per cent) of the public sector information that they have published was in an open and standards based format—notably higher than the proportions recorded in 2012 (37 per cent).
In 2018, 46 per cent of agencies indicated they routinely apply metadata to public sector information they publish on the internet (compared to 49 per cent in 2012) and that they were most likely to only use the Australian Government Locator Service (AGLS) metadata standard (57 per cent) when doing this.
Challenges publishing public sector information
77% of agencies identified open access to information as the most significant challenge faced when publishing public sector information
When agencies were asked to identify the top four challenges they face when publishing public sector information (apart from publishing information in the IPS and Disclosure Log), the aspects most commonly identified were:
- open access to information (77 per cent) including obtaining sufficient budgetary resources to enable open access; identifying information, in addition to the IPS and Disclosure Log, that can be published; and ensuring compliance with privacy and secrecy requirements
- robust information asset management (48 per cent) including establishment and maintenance of an information asset register and providing up-to-date staff training in information management
- effective information governance (35 per cent) including instigating strategic planning about information resource management and establishing an appropriate focal point, officer, or centralised department responsible for furthering access to public sector information
- facilitating discoverable and useable information (33 per cent) including ensuring compliance with WCAG 2.0 and agency costs (including staff time) associated with compliance with WCAG 2.0.
 A report of the 2012 IPS Survey results is published on the OAIC website at https://www.oaic.gov.au/freedom-of-information/foi-resources/foi-reports/information-publication-scheme-survey-of-australian-government-agencies
A separate report on agency implementation of the Principles on open public sector information was published in February 2013 on the OAIC website at https://www.oaic.gov.au/information-policy/information-policy-resources/open-public-sector-information-from-principles-to-practice
 Section 9(1) of the FOI Act requires agencies to complete a review of the operation of the IPS within their agency, as appropriate from time to time and within five years of the commencement of the IPS (by 1 May 2016), in conjunction with the Information Commissioner. The Information Commissioner considered that the completion and submission of the 2018 IPS agency survey satisfied agencies’ requirement to complete a review of the operation of the IPS.
 Calculated from the last day of the extended fieldwork period (17 August 2018).
Long text descriptions
Figure 1 – Coverage of the five key elements of IPS compliance in review of the operation of agencies’ IPS
Figure 1 is a stacked bar chart showing the proportion of agencies whose review included each of the five key elements of IPS compliance.
Base: Agencies that completed a review of the operation of the IPS
|Element||% yes||% no||N|
|IPS document holdings
|IPS information architecture
|Agency compliance review
|Governance and administration
Back to Figure 1
Figure 2 – The extent to which agencies use the five standard recommended headings in their Agency IPS Plan
Figure 2 is a stacked bar chart comparing the extent to which agencies used the five standard recommended headings in their Agency IPS Plan in 2018 and in 2012.
Base: Agencies who have published an Agency IPS Plan
||Yes – all %
||Yes – some %
||No – we do not use any of the five standard headings %
||Did not answer %
Back to Figure 2
Figure 3 – Time since last update of Agency IPS Plan
Figure 3 is a pie chart showing the length of time since agencies have last updated their Agency IPS Plan.
Base: Agencies who have published an agency IPS Plan (n=167).
|Time since last update of APS plan||% of agencies|
|Less than 1 year ago
|1-2 years ago
|More than 2 years ago
|We have not updated our Agency IPS Plan since it was first published
Back to Figure 3
Figure 4 – Extent of formal IPS governance structure in agencies
Figure 4 is a pie chart showing the proportion of agencies with formal IPS governance structures.
Base: All agencies (n=190)
| ||% yes||% no|
|Agency has formal IPS Governance Structure
Back to Figure 4
Figure 5 – Types of formal IPS governance structure(s)
Figure 5 is a bar chart showing the types of formal IPS governance structures agencies had in 2012 (n=90) and 2018 (n=51).
Base: agencies with a formal IPS governance structure.
|Governance Structure||% of agencies in 2018||% of agencies in 2012|
Back to Figure 5
Figure 6 – Extent to which agencies maintain an IPS information register
Figure 6 is a stacked bar chart showing the proportion of agencies that reported maintaining an IPS information register in 2012 (n=191) and in 2018 (n=190).
Base: All agencies
|Extent to which agencies maintain an IPS information register||% yes||% no|
Back to Figure 6
Figure 7 – Frequency at which agencies review their IPS information register
Figure 7 is a pie chart showing the frequency at which agencies review their IPS information register.
Base: Agencies that maintain an IPS information register.
|Frequency at which agency reviews its IPS information register||% agencies|
|At least every 6 months
|At least every 12 months
|Only where significant IPS changes occur
|Don’t know/ can’t say
Back to Figure 7
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