AI compliance your agency can actually evidence.
The Policy for the Responsible Use of AI in Government came into force on 15 December 2025. Its first new mandatory requirement commenced 15 June 2026, with the remaining requirements commencing December 2026. We help Accountable Officials produce the registers, assessments, evidence and training the policy requires — and stand behind them when they are examined.
Two roles, two different problems
Commonwealth guidance separates governance from adoption, and expects them to be held by different people where possible. Most of what follows is owned by the Accountable Official; the training and capability work is usually the Chief AI Officer’s.
AI Accountable Officials
Accountable for implementing the AI policy inside the agency, responsible for higher-risk use cases, and the person who has to be able to evidence all of it.
Chief AI Officers
Appointed from existing senior leadership by July 2026 to drive adoption and champion strategic change — a distinct role from the Accountable Official.
Where agencies are getting stuck
Each of these is a published requirement or standard, not our interpretation of one. They are ordered by where agencies are actually getting stuck rather than by where they sit in the policy. Follow any of them through for what the policy says, why it is harder than it looks, and what an engagement produces.
AI impact assessments
Assess each in-scope use case before deployment, against the DTA tool and Australia's AI Ethics Principles.
What this involvesAI technical standard conformance
Evidence the Evaluate and Monitor phases of the AI technical standard — including adversarial testing.
What this involvesAI use-case register
Find every in-scope AI use across the agency and record it, with an accountable officer against each one.
What this involvesFoundational AI training
Mandatory foundational AI training for all staff, differentiated by what each role actually does with AI.
What this involvesGovAI gives you the platform. The solution is still yours to build.
The Department of Finance built GovAI as a centralised, Australian-hosted service so agencies can — in the National AI Plan’s own words — “develop customised AI solutions at low cost”. That sentence is worth reading closely. The platform provides secure hosting and whole-of-government tooling. The customised solution is still the agency’s to specify, build, assess and defend.
That layer is where we work, and we are not competing with the platform. A use case hosted on GovAI carries exactly the same obligations as one hosted anywhere else: it belongs on your use-case register, it needs its impact assessment, and it has to evidence the Evaluate and Monitor phases of the technical standard. Secure hosting satisfies none of those on its own — it just means the thing you still have to evidence is running somewhere defensible.
When the data can’t leave the country
Where the orchestration runs and which model serves the inference are two different questions, and a platform answers only the first. Some agency workloads can’t run on a US-hosted frontier API — the data can’t cross the border, or the provider can be gated or switched off by another government overnight. That decides whether a use case can run at all, and it is an architecture question, not one of the compliance obligations above.
We map which workloads can’t leave the jurisdiction and design the sovereign, private inference to run them — frontier-grade open-weight models on infrastructure you control, in your jurisdiction, with a full audit trail. Inference you can put in front of a regulator, for the work that can’t be sent offshore.
A procurement pathway that already exists
Commonwealth agencies do not need to run a tender or find us on a panel to work with us. The rules already provide a direct route for engaging an Australian SME, and the facts your procurement delegate needs are set out below.
We meet the CPRs definition of an SME
Comware is an Australian business (ABN 69 054 484 347) based in Melbourne. The Commonwealth Procurement Rules define an SME as an Australian or New Zealand business with fewer than 200 full-time equivalent employees, counted across associated entities. We qualify.
You can engage us directly under Exemption 17
Appendix A, Exemption 17 of the Commonwealth Procurement Rules lets an entity directly engage an SME for procurements valued below $500,000 including GST, provided value for money can be demonstrated. No open approach to market is required, and no panel membership is needed.
We contract on the Commonwealth Contracting Suite
Use of the Commonwealth Contracting Suite is mandated for procurements under $200,000. We work to it as standard, which keeps the contracting overhead proportionate to engagements of this size.
Scoped to close before the deadline, not after it
Engagements are fixed in scope and sequenced so the artefacts your Accountable Official needs exist before the requirement bites — rather than a programme that is still running when the date passes.
Before applying Exemption 17: where the Indigenous Procurement Policy’s Mandatory Set Aside applies — procurements delivered in remote Australia, and other procurements wholly delivered in Australia valued between $80,000 and $200,000 including GST — an Indigenous business must first be given the opportunity to demonstrate value for money.
This page describes the procurement rules as published by the Department of Finance and is provided as a convenience, not as procurement advice. Your delegate remains responsible for the procurement decision and for demonstrating value for money.