Australian Tenders Blog

Policies and Frameworks You Should Know About If You’re Using AI For Tendering

Written by Chloe Breach | 30/06/26 07:01

The policy landscape around AI in ANZ procurement has moved quickly in the last 12 to 18 months. Both Australia and New Zealand have introduced or updated major frameworks governing how AI can be used in government procurement, and they have direct implications for Suppliers. They shape how agencies evaluate Suppliers, what Buyers will expect you to understand about your own AI use, and increasingly, what you may be required to disclose.

Here's a rundown of the main policies and frameworks that matter and what they mean in practice.

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Australia: The Key Frameworks and Policies

1. Policy for the Responsible Use of AI in Government

The Policy for the Responsible Use of AI in Government was updated and came into effect on 15 December 2025. The policy strengthens governance requirements across the Australian Public Service (APS) and introduces new mechanisms to ensure that AI use is properly assessed before deployment. These include use case-level impact assessments, stronger accountability arrangements, and guidance on procurement and contract management when AI technologies are involved.

Key requirements under this policy include:

  • Agencies must conduct an AI Impact Assessment before deploying AI in government operations
  • AI systems must align with Australia's AI Ethics Principles
  • Accountability for AI decisions must be clearly assigned to human officials
  • Agencies must ensure that AI use does not undermine due process, transparency, or equal treatment in procurement

What you should know: accountability for AI-assisted decisions must be assigned to a human official. This means fully automated tender evaluation isn't happening anytime soon. Human oversight stays in the loop.

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2. APS AI Plan 2025

The Australian Public Service AI Plan 2025 is the roadmap behind the responsible use policy. Among other things, it's establishing AI-specific subcategories within procurement panels like BuyICT and the Digital Marketplace, and creating a central register of generative AI assessments from December 2025.

Key requirements under this plan include:

  • Expanding the responsible use of AI across government services
  • Improving data integration across critical government systems
  • Developing AI specific subcategories within procurement panels including BuyICT and the Digital Marketplace
  • Creating a central register of generative AI assessments from December 2025
  • Developing a standardised AI Impact Assessment Tool
  • Supporting procurement of AI tools through coordinated panel arrangements

The practical upshot for suppliers: if you're selling or delivering AI-powered services, government procurement pathways for those services are being formalised. Getting onto the right panels early is worth thinking about.

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3. Model AI Procurement Clauses

To support responsible procurement of AI technologies, the Australian Government has also published Model AI Contract Clauses designed to help agencies manage risks when procuring AI-enabled systems and services.

These clauses provide a structured approach for incorporating AI governance requirements into procurement contracts.

They address areas including:

  • Fairness and non-discrimination in AI systems
  • Privacy protections and data handling obligations
  • Transparency and explainability requirements for AI outputs
  • Accountability and audit rights for AI-assisted decision making
  • Safety requirements and incident reporting obligations

These clauses help ensure that government agencies can monitor vendor compliance and manage risks associated with AI technologies throughout the contract lifecycle.

 

4. Commonwealth Procurement Rules

The CPRs remain the primary legal framework for federal procurement, and they apply whenever AI tools touch the process. Value for money, fair and open competition, ethical decision making, and equal treatment of suppliers are non-negotiable. When an agency uses AI in evaluation, they're still required to uphold all of these.

An update worth noting: from late 2025, the CPRs are expected to increase SME procurement targets and give greater weighting to Australian-owned businesses. If you're a smaller or locally owned supplier, that's relevant context for how you position your bids.

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5. National Framework for the Assurance of AI in Government

Released in June 2024, the National Framework for the Assurance of Artificial Intelligence in Government covers Commonwealth, state, and territory governments, supporting a consistent national approach to AI governance. The framework outlines the key cornerstones of AI assurance, helping agencies assess and manage AI risks throughout the lifecycle of AI systems.

The framework emphasises:

  • Risk-based assurance processes
  • Transparency and explainability
  • Ongoing monitoring of AI systems
  • Governance structures that support responsible AI deployment

If you're building AI capabilities into your service delivery and pitching to government, expect to be asked about your own governance practices against frameworks like this one.

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6. DTA AI Procurement Guidance

The Digital Transformation Agency has published guidance on procuring AI products and services, structured around the Digital Sourcing Framework Lifecycle (Plan, Source, Manage). In practical terms, this means agencies are now expected to ask vendors how they'll manage AI-specific risks including bias, transparency, and data governance, and to ensure vendors support auditing and ongoing monitoring.

If a Buyer asks you those questions, you need good answers.

 

Plan Phase

  • Defining procurement objectives focused on outcomes rather than prescribing specific technical solutions
  • Developing a business case that justifies the use of AI and assesses potential benefits and risks
  • Reviewing relevant policies, legislation, and frameworks before approaching the market
  • Engaging multidisciplinary teams including technical, legal, procurement, and governance specialists

Source Phase

  • Using market engagement to explore whether AI may form part of proposed solutions
  • Asking vendors how they will manage AI specific risks such as bias, transparency, and data governance
  • Evaluating risks associated with AI-enabled systems and assessing proposed mitigation strategies
  • Considering responsible AI principles, security requirements, and compliance during supplier evaluation

Manage Phase

  • Monitoring AI system performance and outcomes across the contract lifecycle
  • Ensuring vendors support auditing and ongoing monitoring of AI outputs
  • Maintaining appropriate human oversight and accountability for AI-assisted decisions

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7. Public Service AI Framework

The Australian Public Service AI Plan 2025 sets out a roadmap for the responsible adoption of AI by the Australian Government. The plan identifies AI as a strategic capability for government and focuses on improving coordination, governance, and procurement of AI technologies.

Key requirements under this policy include:

  • Expanding the responsible use of AI across government services
  • Improving data integration across critical government systems
  • Developing AI specific subcategories within procurement panels including BuyICT and the Digital Marketplace
  • Creating a central register of generative AI assessments from December 2025
  • Developing a standardised AI Impact Assessment Tool
  • Supporting procurement of AI tools through coordinated panel arrangements

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8. Ethics and Probity in Procurement

The Department of Finance provides guidance on ethics and probity in Commonwealth procurement, which also applies when AI tools are used to support evaluation or decision

making.

Core requirements include:

  • Procurement decisions must be based on merit and objective evaluation criteria
  • Conflicts of interest must be identified, disclosed, and appropriately managed
  • Procurement processes must remain transparent, defensible, and auditable
  • AI tools used in procurement must not introduce bias or undermine equal treatment of tenderers

Maintaining strong probity controls is particularly important when using AI-assisted evaluation tools to ensure procurement outcomes remain fair and accountable.

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New Zealand: The Key Frameworks

1. New Zealand National AI Strategy

Released July 2025 by MBIE, New Zealand's National AI Strategy takes a deliberately light-touch, principles-based approach aligned with the OECD AI Principles. The focus is on AI adoption rather than development, with a strong push to realise productivity benefits across the economy quickly.

The strategy comes with Responsible AI Guidance for Businesses, which is worth reading if you're operating across the Tasman or tendering into NZ government. It sets expectations around safe and ethical AI use that will increasingly flow through into procurement requirements.

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2. Government Procurement Rules (NZ)

New Zealand's procurement framework emphasises transparency, accountability, and delivering public value. Most opportunities are published through the Government Electronic Tenders Service (GETS), and in 2025 NZ launched Procure Connect, a new platform designed to improve efficiency and access.

For AI governance specifically, NZ is aligned with OECD principles and procurement practice is expected to evolve in step with the National AI Strategy.

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The Ethics and Compliance Questions Every Supplier Should Think About

Policy frameworks aside, using AI in tender preparation comes with its own practical risks: data confidentiality, AI disclosure requirements, hallucinations in generated content, and the growing problem of responses that all start to look the same. These aren't edge cases, they're common pitfalls that can cost you a bid or create a probity issue.

For a full breakdown of what to watch for and how to avoid it, read The Hidden Risks of Using AI to Write Tender Responses (And How to Avoid Them).

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What This Means If You're Tendering Right Now

The policy environment isn't a reason to avoid AI in tendering. It's a reason to use it thoughtfully. Here's what matters in practice:

  • Use AI to draft and structure responses, but apply expert review before submission
  • Check every fact, statistic, and claim, especially anything AI-generated
  • Use secure, enterprise-grade tools for anything involving sensitive information
  • Be prepared to disclose AI use if asked, and check tender documentation for any specific requirements
  • If you're selling AI-enabled services to government, understand what assessors will be looking for against the frameworks above

The businesses that will compete well as AI becomes standard practice in tendering are the ones that combine the efficiency AI offers with the domain knowledge and judgment that only comes from people who know the sector.

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Want the Full Picture?

This post covers the policy landscape at a high level. For a deeper look at how AI is transforming tendering and procurement across Australia and New Zealand, including data on adoption rates, practical guidance for both suppliers and government buyers, and what the next three to five years looks like, download our free guide:

A Guide to Procurement and AI Use in Tendering in ANZ (2026)

It covers the full ANZ procurement landscape, AI use in bid writing and evaluation, government policy and frameworks for both Australia and New Zealand, ethics and compliance risks, and a practical step-by-step process for using AI effectively in your tender responses.