This submission argues for a more comprehensive regulatory framework for automated decision-making (ADM) in the public sector, one that goes beyond existing administrative law and is not limited to AI-based systems.

The submission argues that the current consultation paper focuses too heavily on legislation and regulation, neglecting enforcement and accountability. It calls for a more comprehensive approach to ADM that addresses systemic issues, not just individual cases. The submission emphasises that the government should be an exemplar of safe and responsible technology use, arguing that the focus should be on what governments do with technical systems, rather than the particular kinds of technical system involved.

Key recommendations

• The ADM framework should include enforcement and accountability mechanisms.
• Systemic and preventative measures, including ex-ante control and active monitoring, are needed.
• An independent oversight body should monitor and enforce standards across government.
• Qualified transparency mechanisms should be adopted.
• Key transparency requirements should be incorporated into the acquisition of ADM systems.