Chartered Accountants Australia and New Zealand (CA ANZ) has submitted on Treasury’s review of tax and corporate whistleblowing in Australia. 

This review must now move beyond restating known problems. Australia has longstanding and critical deficiencies in its whistleblower framework that continue to weaken confidence, impede disclosures and leave people exposed when they act in the public interest. CA ANZ implores the Australian Government to treat this as critical reform and act with urgency. This is a consequential moment for the accounting profession and for the integrity architecture that supports the economy.

Two longstanding deficiencies that we have consistently raised over the years remain unresolved and require immediate attention:

• Partnerships and other unincorporated entities should be brought within the definition of regulated entities under the Corporations Act 2001 (Cth) (the Corporations Act), on a targeted and proportionate basis. This is critical because it ensures whistleblower protections are not denied solely because of a firm's legal structure, particularly where the entity performs functions of significant public interest.
• Where a member of an audit team receives a qualifying whistleblower disclosure, it should be treated as having been made to the audit entity, not solely to that individual. This is important because it enables information to be safely escalated within the audit team, helping ensure potential misconduct is properly considered, investigated and addressed.

CA ANZ also supports complementary reforms to address structural weaknesses in the regime, including establishing an independent whistleblower agency and clearer pathways for appropriate information sharing between regulatory authorities and professional bodies.

Whistleblowing is not peripheral to the accountancy profession; it sits close to our public interest purpose and to the ethical obligations of Chartered Accountants. Integrity is one of the five fundamental principles in the Accounting Professional & Ethical Standards Board (APESB) Code of Ethics for Professional Accountants, and the decision to speak up about serious wrongdoing is often a direct expression of that principle in practice. Time and again, accountants and other finance professionals have identified misconduct early, preserved evidence, asked difficult questions and helped expose conduct that harmed markets, taxpayers, investors, employees and the broader community.

In Australia and around the world, many of the most important advances in corporate accountability, tax integrity, audit quality and professional standards have been shaped, directly or indirectly, by people who were prepared to speak up. Often, those people did so at real personal cost. Public trust is shaped not only by how wrongdoing is sanctioned after the fact, but by whether people inside organisations believe they can raise concerns safely, lawfully and effectively when it matters most. A modern whistleblower framework should start from that reality and honour it with protections that work in practice, not just on paper.

We represent members who work every day at the point where ethics, judgement and public interest intersect. We know that speaking up can be isolating, and that it can place careers, relationships and wellbeing under strain. A credible system must recognise that reality and make clear that those who act with integrity in the public interest are not standing alone.

Our submission therefore supports reform that is practical, coherent and outcomes-focused. The current framework contains important protections, but it remains complex, fragmented and, in key respects, difficult to use. If the law is too hard to navigate, too uncertain in operation, or too weak in delivering remedies, it will not give confidence to those contemplating whether to come forward.
We also consider that effective whistleblower protection is part of a broader integrity ecosystem. It must sit alongside fit-for-purpose regulation, clear accountability, appropriate information sharing, strong professional and organisational cultures, and settings that reflect how modern firms and professional services structures operate. Standards matter, but culture and conduct matter just as much. Reform should focus on real-world function and risk, not outdated boundaries or technical silos.