Noting that we have had only a short amount of time to consult with members, below is an initial set of comments and concerns around the direction of implementation thus far.

As a general point, it must be noted that given the unequivocal Government response to Trusting Australia’s Ability: Review of the Australian Research Council Act 2001 (the Review) and the Minister’s public comments UA expects that the recommendations will be implemented in full and in good faith.

UA notes that, in several critical areas, the discussion document provides less detail than the Review recommendations and Government response. It is unclear in such cases if omissions/changes in phrasing represent changes in policy or are merely the result of summarising key themes – making it difficult to be precise in our feedback. A clear remedy for this would be for the Department to undertake to provide (at an appropriate time) an Exposure Draft of legislative amendments for the consideration of the sector.