- CA ANZ initially submitted to the Department of Foreign Affairs and Trade
- Following the tabling of the Agreement, CA ANZ then submitted to the Joint Standing Committee on Treaties
- CA ANZ broadly supports the Agreement and its overarching purpose.
Submission to Department of Foreign Affairs and Trade
The Department of Foreign Affairs and Trade (DFAT) called for submissions to inform the way forward as a part of the progression (and negotiations) on the Australia and Singapore Digital Economy Agreement (the Agreement).
At the time of the submission, the Agreement was anticipated to cover modern digital trade rules and facilitate bilateral cooperation on areas including digital trade facilitation, e‑invoicing, e-payments, FinTech and cooperation on the digitisation of trade documents, artificial intelligence, digital identities, and e-certification for exports. Australia and Singapore would seek to establish modern rules on the regulation of cross-border data flows and localisation of computing facilities, and establish benchmarks for improving safety and consumer experiences online.
Key points from that submission include:
- The Government should consider practical support for small to medium entities (SMEs) as they adapt their business infrastructure to the changing nature of payment practices through digital technologies.
- We suggest DFAT considers the inclusion of provisions safeguarding consumer and SME access to internet communications and minimising the risk of anti-competitive behaviour by dominant players. This could be achieved through a commitment to net neutrality.
- We consider privacy and data protection safeguards that balance privacy rights and encourage innovation in the use of data sets are important and should be considered. We recommend that the Agreement ensures there are appropriate privacy and data protection standards in Australia and Singapore.
- We suggest the eight AI Ethics Principles from the Department of Industry, Innovation and Science for AI use and development are considered as part of the Agreement.
Submission to the Joint Standing Committee on Treaties
The Joint Standing Committee on Treaties (JSCOT) called for submissions on the Agreement following its signing and tabling in Parliament.
CA ANZ’s submission to the JSCOT focused on key areas where we could add the most value, and in addition to the comments we made as part of our previous submission to the DFAT.
CA ANZ continues to broadly support the Agreement and its overarching purpose. We commend the Government on its efforts to include commitments to open data, privacy safeguards, e-payment frameworks, and the protection of a level playing field online.
We continue to recommend that Government considers practical support for SMEs, in particular to those transitioning to the use of digital technologies for the first time. This includes providing guidance with respect to e-invoicing and the PEPPOL framework which is already in use in Singapore and in other countries across Europe, Asia and North America.