The TCF is a serious failure of public administration
In this blog, @simonecasey highlights key issues recently exposed in the compliance framework used in employment services. As regular readers will know, @simonecasey has been examining the Targeted Compliance Framework (TCF) and related automation since 2019, driven by her academic and policy interests in employment services and welfare conditionality. This blog draws attention to recent issues that have gained media attention and were scrutinised in parliamentary hearings last week. The Senate Estimates transcripts provide valuable insights into the ideological battles surrounding welfare policy. Recent sessions revealed both ongoing technical failures within the TCF and the broader "culture war" over welfare policies.
The Targeted Compliance Framework (TCF), introduced in 2018, was designed to enforce "mutual obligations" for jobseekers receiving social security payments. Critics have long suspected it mirrors the punitive approach of Robodebt, relying on automation to make decisions once handled by public servants. Since its implementation, payment suspensions have increased, largely because individuals are unable to report compliance with points-based targets, or because providers have marked them as noncompliant for missing appointments or failing to complete tasks.
The TCF was developed without input from affected individuals, instead relying on behavioral insights consultants and reflecting the Abbott-era Coalition government’s "tough on welfare dependence" rhetoric. As it turns out, the prescient words of Terry Carney on Robodebt—"its rushed design and the promise of reducing welfare expenditure trumped regard for design standards"—apply equally to the TCF. New revelations highlight systemic IT failures and poor adherence to legislative requirements for discretionary considerations in payment cancellations, further compounding economic insecurity for vulnerable individuals.
System Failures Revealed
During Senate Estimates on 26 February 2025, the Department of Employment and Workplace Relations (DEWR) faced intense scrutiny over the administration of mutual obligations under the TCF. Secretary Natalie James provided the first official account of several serious issues, after many details had already surfaced through media reports and a Freedom of Information (FOI) request initiated by welfare advocate @jeremypoxon.
Key findings include:
Three major IT failures between 2018 and 2024 resulted in incorrect reductions and cancellations of payments for 1,326 jobseekers, with 1,280 receiving compensation totaling $1.23 million.
A legal review determined that 964 additional jobseekers may have had their payments unlawfully cancelled between April 2022 and July 2024, prompting the department to pause all payment cancellations pending further review.
The Secretary’s statement confirmed that 55 IT defects have been identified, some known since 2020. Deloitte has been appointed to investigate the TCF’s IT codification, with a report due in May 2025.
These revelations have further eroded confidence in the TCF, particularly given the government’s evasive approach to transparency, as revealed by the FOI process.
Parliamentary Debate
Senate Estimates also provided a stage for the ongoing ideological battle over welfare policy.
Greens Senator Penny Allman-Payne called for an immediate halt to the entire compliance framework, arguing it is fundamentally flawed and disproportionately harms vulnerable jobseekers. Citing FOI documents, she questioned why the system remains operational despite known failures:
"We've got an IT system that isn’t responsive. The concerns are so significant that daily assurance activities are required," she said. "Why is this system still running?"
Referring to the FOI, the Senator highlighted that "the Minister was told not to pause penalties because it would impact providers' payments and viability, but there was no discussion whatsoever about the impact on jobseekers." The FOI documents also revealed potential legal risks, including possible class action lawsuits over public statements regarding the compliance framework.
Under questioning, Secretary James issued an unreserved apology—an admission absent from her opening statement, which also omitted any reference to the 10 deaths reported in the media following their revelation in the FOI.
Senator Allman-Payne pressed further: "Has DEWR taken steps to establish whether any of the 10 individuals died after their payments were cancelled, and whether suicide was a factor?" The same question was posed the following day in a Community Affairs committee hearing, but no further investigation into the circumstances of these deaths has been undertaken.
Minister Murray Watt acknowledged concerns but rejected calls to suspend the framework entirely:
"I do have concerns about this system and how it operates. That’s why I requested an external review," he stated.
He defended mutual obligations while differentiating Labor’s approach from the Coalition’s: "We don’t want the system to be punitive. The way the Coalition ran it was unnecessarily harsh, and we are reforming it. But mutual obligations remain an important part of employment services."
Meanwhile, Coalition Senator O'Sullivan argued that mutual obligations encourage jobseeker engagement and expressed concern that pausing payment cancellations might reduce participation. Secretary James, however, disputed this claim, stating that early data indicated a 23% increase in jobseeker referrals to services following a temporary pause at the start of 2025.
The claim that payment penalties improve engagement or employment outcomes is demonstrably false. In reality, these penalties undermine participation by exacerbating financial hardship, deteriorating health, and increasing psychological distress—factors reflected in the high suicide rates among unemployment payment recipients.
Compensation and Legal Concerns
The compensation process for affected individuals remains a contentious issue. While many impacted by IT failures have been repaid, the process for the 964 jobseekers whose payments were unlawfully cancelled remains unresolved. There are concerns that affected individuals may struggle to engage with repayment processes, particularly given that half of them are known to be First Nations people.
Senator Allman-Payne criticized the government for failing to proactively inform affected individuals of their right to additional compensation: "These are some of the most vulnerable people in the country. Why are we forcing them through complicated legal processes to access what they’re entitled to?"
Next Steps
With Deloitte’s IT review due in May 2025 and legal reviews ongoing, the government faces mounting pressure to prove that the compliance framework operates lawfully and fairly—let alone whether it has any legitimacy beyond serving as a tool for mass punitive sanctions.
The window for reform is closing fast, with the upcoming federal election potentially shifting policy direction. A Coalition government would likely revert to harsher policies, undoing the limited progress made under the current government.
Should Labor retain power, there will be strong expectations that policy moves beyond ideological battles and towards genuinely enabling employment. It remains questionable whether automation and so-called "self-activation" mechanisms genuinely assist jobseekers or simply serve as cost-efficient tools for unnecessary surveillance and punitive control.
The last seven years have demonstrated that the TCF represents a serious failure of public administration.
Posted by @simonecasey as this week’s moderator, with views reflecting her academic scholarship as a RMIT Research Associate.