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    Compliance

    Prepare the evidence before the disclosure deadline.

    The new APP 1 automated-decision disclosure provisions commence on 10 December 2026. For covered organisations and arrangements, preparation requires more than a generic AI sentence in the privacy policy. For the detailed scope test, read [what APP 1.7 requires](/what-app-1-7-requires-australian-organisations-to-disclose).

    Confirm scope early

    Assign responsibility for assessing entity coverage and relevant arrangements. Identify programs involved in decisions about people, including systems not marketed as AI.

    Do not assume every automated task requires disclosure. Significance, program involvement and use of personal information must be assessed together.

    Work backwards from publication

    Allow for operational confirmation, vendor responses, legal review, drafting and the publication process. A short final paragraph may depend on evidence across several teams.

    Use the organisation's actual review and decision dates. There is no universal number of weeks that guarantees a complete assessment.

    Define four preparation outcomes

    A defined population shows what has been examined and excluded.

    A documented assessment distinguishes supported findings from uncertainties, with owners for resolution.

    Reviewed wording describes the assessed arrangements and fits the wider privacy policy.

    A maintenance process connects future changes to the policy owner.

    These are operational outcomes, not four separate documents mandated by APP 1.7.

    Avoid shortcuts

    Vendor assurance does not establish your disclosure. A staff AI policy does not automatically meet privacy-policy requirements. A human click does not settle whether the program's involvement is relevant.

    Treat those facts as inputs to assessment rather than slogans that end it.

    Be precise about urgency

    The commencement date is real. Claims about automatic penalties, special audit campaigns or inevitable enforcement need their own evidence and legal context.

    The practical reason to act is to give the organisation time to establish facts and resolve important questions. Fear-based estimates do not improve that work.

    After commencement, keep wording aligned with actual practices. Changes in purpose, information or program involvement may require reassessment.

    The 10 December 2026 deadline does not move. Request a Rapid Review to map the decisions your software already makes about people.

    Request a Rapid Review

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