OAIC publishes guidance for the automated decision-making transparency rule
The OAIC released its guidance for the automated decision-making transparency obligation (APP 1.7 to 1.9): a fact sheet, a flowchart, a government supplement and an updated APP 1 Guidelines chapter. The obligation commences 10 December 2026; the guidance treats spreadsheets and rules engines as computer programs, says human sign-off does not remove a tool from scope, and counts refusals as decisions.
On 30 September 2026 the privacy regulator released a fact sheet, a flowchart, a supplementary sheet for government agencies and an updated chapter of the APP 1 Guidelines, ten weeks before the obligation commences on 10 December 2026.
The guidance reads the rule broadly. “Computer program” includes spreadsheets and rules engines, not only AI. A person signing off on what the program recommends does not take the tool out of scope. A refusal counts as a decision. The guidance also confirms what the rule is not: it is a transparency obligation only, with no right for individuals to contest a decision or to be notified.
Our advice is unchanged: find the decisions your software makes about people, then write the three things the policy needs to say. We have written a plain-English guide to what counts as an automated decision.
Applies to: APP entities that use computer programs, including AI, to make or substantially inform decisions that significantly affect people
Related instrument: Privacy Act reform: automated decision-making transparency