Revenue NSW is a division within the Department of Customer Service responsible for collecting fines and taxes, administering grants and recovering debts on behalf of state government agencies. In 2023–24, it collected an estimated $43 billion, representing over 35% of the State’s total revenue.

In addition to its core role as the revenue collection agency for the State, Revenue NSW also has a responsibility under the State Debt Recovery Guidelines to ensure fines and debt recovery processes for state debts do not have a disproportionate impact on vulnerable people.

Revenue NSW has a Hardship Policy to assist vulnerable people with a fine or a debt or those who are experiencing economic hardship.¹ The intent of the policy is to ensure that if a person is experiencing hardship, they are treated in accordance with the ‘Customer Commitments’. The Customer Commitments outline expectations for ease of access, empathy, respect, clear explanations, situation resolution and community engagement. These also form part of Revenue NSW’s corporate and customer strategies.

Under the Hardship Policy, Revenue NSW has established a range of payment options to provide hardship assistance. The policy also sets expectations for the fair and transparent review of hardship circumstances and applications for assistance, and a commitment to continuous improvement. Payment options include a write-off of the fine, a reduction in the fine amount through participating in unpaid work, programs or treatment under the Work and Development Order (WDO) Scheme, an adjustment to the payment timeframe or due date, or a combination of these options.²

Most decisions on whether to provide hardship assistance are made by Revenue NSW. In circumstances where an application for hardship assistance has been refused, an individual can appeal to the Hardship Review Board. The Hardship Review Board is a statutory body which provides an avenue for review and acts as the appeal mechanism for hardship decisions by Revenue NSW.

¹ This report refers to ‘people experiencing hardship’ as outlined in the Hardship Policy. Revenue NSW uses this term interchangeably with the term ‘customers’.

² Revenue NSW uses the terms ‘hardship options’ and ‘payment options’ when describing the different types of hardship assistance.

This audit assessed the effectiveness of Revenue NSW in delivering hardship assistance in compliance with relevant legislation, policies and guidelines. The audit considered whether Revenue NSW takes reasonable measures to ensure that its decision-making is fair, consistent and transparent. The audit focused on hardship assistance decisions relating to fines and debts.

Revenue NSW delivers assistance to people experiencing hardship, using the range of payment options available under its Hardship Policy. It has established a governance framework to support effective implementation, including processes, procedures and delegations for assessing applications and making decisions on hardship assistance for fines and debts. However, Revenue NSW is not effectively monitoring, evaluating and reporting on the outcomes of the hardship assistance it provides under the Hardship Policy. This includes whether it is achieving the policy’s intent.

Some of the processes that support Revenue NSW to make fair, consistent and transparent decisions can be improved, including documentation supporting its use of artificial intelligence and automation, as well as its implementation of quality assurance measures. In addition, Revenue NSW can improve how effectively it communicates its decisions to people who have applied for hardship assistance to ensure it is meeting its Customer Commitments.

Revenue NSW has established and implemented a governance framework to guide staff in making decisions on hardship assistance

Revenue NSW has established clearly defined roles, responsibilities and delegations for all staff involved in providing hardship assistance. It has a governance framework that includes business rules and processes, instruments of delegation, guidelines and agreements with other partner organisations.

There is clear and documented project governance and reporting for hardship initiatives, including pilots for fine diversion projects. Revenue NSW has also established, and participates in, governance arrangements that enable cross-agency collaboration and efficiency for some payment options, including fine write-offs and WDOs.

Revenue NSW has piloted several diversion programs and initiatives to promote specialised solutions for some vulnerable customers

In addition to the payment options available to people under the Hardship Policy, Revenue NSW has developed pilot programs and initiatives for some cohorts of vulnerable people to resolve their fines and receive support.³ These programs and initiatives include diversion from the fines system, dedicated pathways to respond to financial abuse, community engagement and reducing debt.

Since 2020, Revenue NSW has developed a program of initiatives to provide hardship support. This was developed in consultation with partner government agencies, non-government organisations and peak bodies. This work was integrated into Revenue NSW’s Fines and Debt strategy, which was finalised in June 2025.

Revenue NSW has also implemented initiatives such as the Advocacy Program and the First Nations Outreach Team to improve communication with people who have difficulties paying their fines. The Advocacy Program provides support to vulnerable people, and the First Nations Outreach Team provides support to First Nations peoples and communities. However, Revenue NSW has not conducted an evaluation of these initiatives.

Revenue NSW has not evaluated whether its administration of hardship assistance, including the implementation of the Hardship Policy, is efficient or effective

Revenue NSW has not evaluated whether hardship assistance is being delivered to people efficiently and effectively, and in a manner that achieves the intent of the Hardship Policy. It has not defined and measured the outcomes and benefits it seeks to achieve by having this policy.

While Revenue NSW aims to provide a range of payment options to support customers, it is not monitoring:

• whether the range of payment options is effectively facilitating tailored hardship assistance
• whether levels of hardship applications are consistent with demand
• whether key population subgroups are being adequately supported in line with expected characteristics of vulnerability and access
• whether there is consistency in decisions being made by Revenue NSW to approve hardship assistance.

Revenue NSW advised that defining good performance in the provision of hardship assistance is difficult as outcomes are not always quantifiable.

Revenue NSW has not established key performance indicators (KPIs) at a program or policy level to assess its performance in the delivery of hardship assistance. Revenue NSW has developed KPIs for staff that administer hardship assistance to measure outputs, volumes and timeliness of work in relation to fines and debts, such as the time taken to answer and handle customer phone calls. Some of these KPIs relate to how effectively staff are delivering hardship assistance. For example, Revenue NSW has established a KPI to have fewer than ten per cent of hardship assistance applications overturned by the Hardship Review Board. However, while data is available, these KPIs are not being monitored or reported against. This limits Revenue NSW’s ability to understand how well it is administering hardship assistance and to support continuous improvement.

Revenue NSW is undertaking quality assurance for processes and decisions relating to fines and debt recovery, but it is not doing so systematically, and in line with its quality framework

Quality assurance is important to ensure that decisions, including decisions about hardship assistance, have been made fairly, consistently and in compliance with legislative and policy requirements. Revenue NSW undertakes quality assurance for processes and decisions relating to fines and debt recovery and has developed a Fines and Debt Quality Framework to guide this work.

However, this framework has not yet been embedded in all teams within the business unit, and it does not provide guidance on identifying non-conformance or sampling techniques. This creates gaps in Revenue NSW’s quality assurance activities, including:

• varied processes across its teams
• no organisational benchmarks to assure and compare quality across hardship options
• no standardised approach to sampling and accepted quality outcomes.

Revenue NSW’s quality assurance insights do not guide continuous improvement, such as process improvement or staff training opportunities, nor do they measure whether people experiencing hardship are being treated in accordance with the Customer Commitments, which is the purpose of the Hardship Policy.

Revenue NSW does not have a formal mechanism in place for using Hardship Review Board decisions to inform continuous improvement. A decision that is varied or overturned by the Hardship Review Board may indicate problems with Revenue NSW’s processes for considering hardship. By not using Hardship Review Board decisions to guide continuous improvement, Revenue NSW is missing the opportunity to use important precedents to guide future decision-making.

Revenue NSW can improve its communication with people requesting hardship assistance

Revenue NSW’s processes, business rules and work instructions for hardship assistance have not been updated to incorporate the Customer Commitments, or to guide staff in how to assess applications. Its standard communication templates for customers experiencing hardship do not reference the Customer Commitments.

For example, Revenue NSW has a Customer Commitment to ‘act with empathy’. During the course of this audit, Revenue NSW staff demonstrated understanding of the needs and circumstances of people experiencing hardship. However, Revenue NSW’s business processes do not provide guidance to staff on how to act with empathy, such as the types of questions to ask, language to use and follow up communication, especially when the decision is not positive for the customer.

Revenue NSW does not assess whether its correspondence meets the needs of people experiencing hardship. The audit reviewed a sample of correspondence with people experiencing hardship and found that while the outcomes of the applications were clearly stated, Revenue NSW’s written communications are not tailored to the applicant’s circumstances and needs. Across the sample, there were gaps in the content of written communication with only:

• 64% providing clear reasons for the decision, such as assessments of an applicant’s capacity to pay a fine or debt and eligibility for payment options
• 34% demonstrating empathy by acknowledging the hardship faced by applicants
• 54% providing information on other support services in the event an application was refused
• 21% providing details on Hardship Review Board appeal options in letters refusing or cancelling a WDO.

None of the sampled correspondence gave recipients information on how to make a complaint about the service received from Revenue NSW.

It is incorrect to describe the Hardship Review Board as independent of Revenue NSW

The Hardship Review Board is a statutory body responsible for reviewing certain decisions made by Revenue NSW, including decisions about fines, fees, taxes and duties. Under legislation, the Board’s composition comprises the Secretaries of the Department of Customer Service, NSW Treasury and the Department of Communities and Justice, or their delegates. The three Secretaries have delegated their functions to executive staff within their respective departments, which is allowable and consistent with comparable delegations across the sector.

The Board’s website describes it as an independent appeal mechanism to Revenue NSW decisions, although the legislation does not require the Hardship Review Board to be independent. The Board’s Charter, and the instruments of delegation that establish its membership, do not reference independence. The description of the Board as independent as outlined on the website is incorrect.

Revenue NSW uses automation and artificial intelligence to identify vulnerable people and remove them from enforcement action, but there are some gaps in the documentation of relevant risks and expectations for model accuracy

Automated decision-making, machine learning and artificial intelligence (automation and artificial intelligence) are used to aid some of Revenue NSW’s fine and debt collection activities. The key tool relevant to administration of hardship assistance is Revenue NSW’s vulnerability detection model. Revenue NSW also uses automation to process fine notification activities and to schedule enforcement activities for staff to action. It does not use automation or artificial intelligence to undertake hardship assessments or automate fine enforcement.

Revenue NSW has advised its executive leadership team on the benefits and risks of automation and artificial intelligence. However, some risk assessments relevant to the use of automation and artificial intelligence tools in fines and debt operations are incomplete or have not been recently updated.

Revenue NSW regularly assesses the accuracy of the vulnerability detection model and reports this to its Fines and Debt Technical Discussion Group on changes and assumptions to the model. The model aims to support the efficient management of hardship assistance and fine enforcement activities, as it enables and informs batch processes and it identifies vulnerable persons before they would otherwise self-identify. However, Revenue NSW’s expectations for the model’s accuracy and performance have not been defined and documented.

Revenue NSW staff advised that the automation and artificial intelligence tools and models were designed and implemented in 2018, before introduction of the ethical assessment requirements in the NSW Artificial Intelligence Assurance Framework. Revenue NSW has provided evidence of ethics assessments undertaken in 2021 for the vulnerability detection model. However, it has not reassessed the risks and benefits of the model’s use since then against ethical considerations, as recommended in the Framework.

Revenue NSW is implementing a response to recommended actions from a proactively commissioned 2024 review of its governance of automation and artificial intelligence. An interim approach to establish governance arrangements, including a dedicated steering committee, was implemented in July 2025.

There is limited transparency about the provision of hardship assistance by Revenue NSW and the Hardship Review Board

Revenue NSW reports on its activities in relation to administering fines and debts through annual reports, open data dashboards and its website. It publishes information on the volume of fines, the number of overdue fines, fine reductions, and the number and types of WDOs granted and participants. However, Revenue NSW does not report on its activity and performance in delivering other types of hardship assistance. There is no public information about the value and type of financial assistance provided to people experiencing hardship, including fine write-offs, payment plans and garnishee order⁴ refunds.

A decision on hardship assistance is only eligible to be reviewed by the Hardship Review Board if Revenue NSW has first decided to decline the application. The Board generally considers cases of ‘serious hardship’. There is no public reporting on the Hardship Review Board’s activities. There are no published reports on the Department of Customer Service’s website, nor on the Board’s website, that would demonstrate the number of applications it has considered, or outcomes and trends in decisions over time.

Transparent reporting would support accountability and provide insights to eligible individuals regarding the range of hardship assistance and volume of decisions that may be relevant to their circumstances.

³ This audit has not assessed the effectiveness of these pilot programs and initiatives.

⁴ Under the Fines Act 1996 and the State Debt Recovery Act 2018, Revenue NSW may issue garnishee orders to recover unpaid debts. Garnishee orders can be issued to a debtor’s employer, property agent or bank to repay the debt.

By October 2026, the Department of Customer Service should:

1. evaluate and publicly report on the implementation of the Hardship Policy, including whether assistance provided under the policy is meeting Revenue NSW’s intent and achieving desired outcomes
2. improve quality assurance across its fines and debt business unit to systematically monitor whether decisions and communications about hardship assistance are accurate and consistent
3. improve correspondence to people seeking hardship assistance to achieve its Customer Commitments, by:
   1. providing clear and meaningful reasons for its decisions
   2. demonstrating empathy
   3. ensuring appeals options for eligible customers are clearly stated
   4. providing details of other support services and how to make a complaint
4. improve the documentation of governance, risk management and ethics in artificial intelligence and automation used in fines and debt operations by:
   1. ensuring each tool used has a current risk assessment
   2. documenting key expectations for accuracy and performance
5. communicate more clearly the role of the Hardship Review Board by:
   1. providing public and transparent reporting on the activity of the Hardship Review Board
   2. removing any description of independence of the Hardship Review Board.

Revenue NSW management of fines and debts 

In 2024, Revenue NSW had a total workforce of approximately 1,776 full time equivalent staff, spread across multiple locations in NSW. Revenue NSW’s Fines and Debt business unit has around 610 full time equivalent staff and undertakes most work related to hardship assistance. 

Hardship assistance for state debts, which are unpaid fees owed by a customer to a government agency or state-owned corporation, are managed by a dedicated team within Revenue NSW’s Fines and Debt business unit. Options for the resolution of state debts, including eligibility criteria for hardship assistance, are determined by the authority issuing the fine rather than by Revenue NSW. This is because the issuing authorities, not Revenue NSW, are owed the debt. Revenue NSW advises that the authorities that have issued the largest amount of state debt include TAFE NSW, Sydney Water and NSW Ambulance. 

Number and value of fines administered by Revenue NSW

In the four years to 2024–25, Revenue NSW administered around 13.3 million fines which represented over 3.2 million fines per year (Exhibit 1). Revenue NSW reports that in 2024–25 there were 1.51 million fines overdue, and these had a total value of $744 million.

Revenue NSW estimates that the cost to administer each fine in 2024–25 was an average of $20.20. It does not report on the detailed costs of administering hardship assistance.

Source: Audit Office analysis of Revenue NSW data (unpublished).

Revenue NSW’s Hardship Policy (February 2023)

Revenue NSW first developed its Hardship Policy in May 2019, following a review by the NSW Ombudsman of its use of garnishee orders to bring together the options to mitigate debts on the grounds of hardship across all Revenue NSW branches that manage debt, including taxes, state debt and fines. The Hardship Policy was reviewed in 2023 to harmonise two policies relating to hardship and garnishee orders, and to respond to an internal audit requirement to review its policies.

The policy states that:

Revenue NSW’s Customer Commitments

The Hardship Policy commits Revenue NSW to helping people experiencing hardship, and people who are vulnerable, and treating them in accordance with its Customer Commitments (see Exhibit 2). Revenue NSW has also incorporated the NSW Government Customer Commitments into its corporate and customer strategies.

The impact of fines on vulnerable people

Fine impacts

The fines system is intended to promote lawful behaviour and public safety, while addressing low-level offending. Fines are also intended to prevent re-offending.

Revenue NSW has stated that the fines system can have a detrimental impact on people experiencing hardship, exceeding the intended impact of the fine itself. In some circumstances, this may compound experiences of hardship. This may be because a person’s circumstances make it difficult to comply, or because resolving the fines debt is done at the risk of not resolving the original non-conformity. Customers with complex needs may place lower priority on resolving the debt compared with other issues they are experiencing.

Some customers, such as those from culturally and linguistically diverse communities or those with literacy difficulties, may have limited understanding of fine documents or the fines system.

Further, some customers may have limited physical or digital access to Service NSW, Revenue NSW or other relevant organisations to seek assistance with resolving a fine and obtaining necessary evidence to verify their circumstances. This may be due to homelessness, being from a regional, rural or remote area or having limited access to technology.

Cost of living pressures

Since 2022, cost of living pressures have increased, affecting people across NSW, including those already in economic hardship. In September 2023, NSW Treasury reported that NSW experienced the highest rate of inflation in the last 30 years and that the costs of essential goods and services such as gas, electricity, insurance, travel fares, childcare and food had increased significantly.

In September 2024, the NSW Council of Social Service found that most low-income households in NSW could not meet their basic needs. Its survey of such households found that 65% could not pay an essential service on time and 74% spent nothing on health essentials. Around the same time the Commonwealth Bank found that the growth rate for essential spending had more than halved between the September quarter of 2023 and that of 2024, with large reductions in spending on utilities (three per cent) and household goods (two per cent). Revenue NSW has identified cost of living impacts as a risk to debt recovery for 2025.

Trends in overdue fines and fine revenue

Revenue NSW cannot enforce payment of a fine or process a fine resolution until it becomes overdue. Generally, this is 21 days after the fine was first issued.

Over the past four financial years, the overall volume of overdue fines has increased by 44% and the overall value of overdue fines has increased by 28% (Exhibit 4).

Receiving a fine

A fine is issued by an agency as a penalty for breaching a law. Generally, a fine recipient will be issued a fine notice and have 21 days to pay. If payment is not processed within this time, a fine reminder notice will be issued, which will provide a customer with 28 days to pay. Should the fine not be finalised within this period, Revenue NSW will process the fine as overdue, add a $65 overdue fee ($25 for customers under 18 years old), and may proceed to enforcement activity. Enforcement activity can include:

• suspending a driver licence or cancelling registration
• making an order to seize property and sell at auction
• garnishing money from a person’s bank account, wages or salary under a garnishee order
• referring debt to a debt collection agency.

Customers can request a review of their fine by Revenue NSW or apply to have the fine heard in court.

Resolving a fine

Exhibit 8 provides an overview of the pathways from fine issuance to fine resolution and possible recovery action.

Hardship Review Board functions

The Hardship Review Board is a statutory body responsible for reviewing certain decisions made by Revenue NSW, including decisions about fines, fees, taxes and duties. The Hardship Review Board is established under the State Debt Recovery Act 2018 and consists of the Secretary of the Department of Customer Service, the Secretary of NSW Treasury and the Secretary of the Department of Communities and Justice or their delegates. The functions of the Board are set out in legislation.

The Hardship Review Board is promoted on its website as an independent mechanism, but the legislation does not require it to be independent of Revenue NSW. Revenue NSW provides secretariat support to the Board.

The Hardship Review Board considers cases of ‘serious hardship’. The Board’s Charter and other explanatory material outline that this is where a customer’s payment of a fine or debt may leave them unable to provide for their immediate family with necessities of food, shelter, clothing, medical expenses and/or other basic requirements.

A decision on hardship assistance is only eligible to be reviewed by the Hardship Review Board if Revenue NSW has first decided to decline the application. Before applying to the Board, individuals must ask Revenue NSW for a payment plan, WDO or write-off. Refusal by Revenue NSW to reduce a fine amount is not subject to review by Board.

Most decisions on hardship outcomes are determined by Revenue NSW. A small number proportion (0.01%) of the total overall hardship assistance determinations for fines and state debt are considered by the Hardship Review Board. The Board’s Charter provides that applicants do not have a right of objection or appeal to a decision made by the Board.

Revenue NSW has established and implemented clearly defined roles, responsibilities and delegations for all staff involved in providing hardship assistance

A governance framework has been implemented by Revenue NSW to guide decision-making and assessments of applications made under hardship assistance programs and legislation.¹⁰ The governance framework includes business rules and processes, delegation instruments that are system enforced, guidelines, and agreements with other state government agencies and partner organisations.

Revenue NSW has also established a Fines and Debt Technical Discussion Group, which is a governance forum that considers legislative issues impacting the administration of fines and debt recovery. The Group considers matters relevant to hardship, including proposed legislative amendments and changes to business rules. It also receives reports on the accuracy of artificial intelligence, machine learning and automated decision-making and any proposed changes to Revenue NSW’s automated debt profile report. This report prioritises and schedules some fine and debt enforcement activity for staff processing (see section 2.5 below). The Group meets regularly, and most actions are assigned and closed.

Some options, such as payment plans, can be provided by all teams across Revenue NSW responding to requests from people experiencing hardship. Other options, such as fine write-offs, may require staff within its Fines and Debt business unit to make decisions within their delegation. Dedicated teams have been established to manage some hardship options and support people in hardship to resolve their fines debt.

Revenue NSW has established dedicated business rules for administering payment options, and decisions to provide assistance are subject to delegation matrices that escalate approvals based on the requested amount for a write-off. These governance arrangements support Revenue NSW to make decisions under delegations and meet its obligations in administering fines and debts, including those relevant to hardship.

Revenue NSW has established and participates in governance arrangements that enable cross-agency collaboration for some payment options

Revenue NSW has established, and participates in, cross-agency collaboration for some hardship options. Revenue NSW co-administers the Work and Development Order (WDO) Scheme with the Department of Communities and Justice and Legal Aid NSW. The WDO Scheme is supported by a governance framework that specifies roles and responsibilities for each scheme agency.

Under a mutual recognition agreement (signed in 2021) with the legal assistance sector, write-offs under $5,000 that have been assessed by legal assistance organisations such as Legal Aid NSW, the Aboriginal Legal Service and Community Legal Centres are mutually recognised and approved by Revenue NSW. Between 2020–21 and 2024–25, 6,594 fines were written off under the write-off mutual recognition scheme. Cross-agency arrangements can promote efficiency and improve customer experience by ensuring that vulnerable customers and people experiencing hardship only have to provide information about their circumstances to one point of contact to access the service.

Revenue NSW has recently finalised a Fines and Debt Strategy that indicates an increased focus on addressing hardship

Revenue NSW advises that its core responsibility is to collect revenue as outlined in the Fines Act 1996 and the State Debt Recovery Act 2018. Under the State Debt Recovery Guidelines 2018, Revenue NSW also has a core responsibility to address the disproportionate consequences of the fines and debt system.

Revenue NSW has established strategic priorities to provide innovative and customer-centric service. Under its ASPIRE 2032 long-term corporate strategy, Revenue NSW aims ‘to be the world’s most innovative and customer-centric revenue agency contributing to a fairer, safer and stronger NSW’. In addition, the Revenue NSW Customer Strategy 2022–2032 states that Revenue NSW has 46,000 vulnerable customers and some customers experience hardship due to financial, social or environmental factors. Revenue NSW has also recently finalised its Fines and Debt 2030 strategy, which supports ASPIRE 2032 by balancing core goals of equity, fairness, effectiveness and accountability.

The delivery plan for ASPIRE 2032 includes two hardship-specific initiatives under a strategic program called Supporting Diverse Customers. These initiatives include the expansion of the WDO Scheme in regional areas and changes to the fairer fines program. While some progress was made towards progressing these initiatives, these were not implemented by Revenue NSW due to gaps in funding or refocusing of priorities, and the ASPIRE delivery plan indicates these have been cancelled or put ‘on hold’. Revenue NSW advised that it is reliant on other areas of government funding to be able to implement these initiatives.

Revenue NSW’s Fines and Debt 2030 Strategy has more emphasis on supporting people who are experiencing hardship. This strategy acknowledges various scenarios faced by customers experiencing hardship and has proposed initiatives that include improved quality assurance, better information campaigns, and modernisation of systems, structures and processes. Revenue NSW received $28 million over four years in the 2024–25 NSW Budget for enhancements to its information technology to deliver modern, secure and customer-centric systems that will support the strategy but may require four years to implement. Other initiatives have not started, will need to be funded internally and are not due for delivery until 2027.

To support its Fines and Debt Strategy, Revenue NSW developed a program of hardship support initiatives since 2020 which focused on diverting customers from the fines system, community engagement and reducing debt. As part of this program, Revenue NSW implemented several key initiatives including:

• establishing data sharing arrangements with the Department of Communities and Justice to identify youth in out of home care and directly assist individuals with resolving their fines
• a specialised response for people experiencing financial abuse within the fines system
• partnering with NSW Police to trial a diversion program for individuals who had received fines for child car restraint offences
• partnering with NSW Police to trial a Youth Traffic Offenders Diversion Initiative
• developing a Youth Transport Diversion Initiative to be trialled with the intent of reducing fare evasion fines and increasing access to public transport for youth experiencing hardship.

This audit has not assessed the effectiveness of these initiatives.

Revenue NSW has audit and risk management processes that support the identification and management of risk, but some improvements could be made

The Hardship Policy states a commitment to continuous improvement. Risk management, internal audit and managing conflicts of interest are key to informing continuous improvement efforts, and to aligning decision-making to risk appetite while ensuring compliance.

Revenue NSW’s risk management framework establishes its risk appetite, assessment and documentation requirements. The framework aligns decision-making with its risk appetite.

Specific risks need to be managed as part of the administration of fines, debt and the management of applications for hardship assistance, including risks to finance, compliance, reputation and use of data. For example, there are legislative requirements for Revenue NSW not to pursue enforcement against minors.

Revenue NSW has identified relevant risks, the risk ratings, controls and mitigating actions in an online risk management system. The documentation of these risks in risk registers includes relevant risks relating to administration of fines and hardship assistance, including ageing legacy systems, resourcing, and non-compliance with legislation, policy and customer expectations. However, there are some gaps in the risk registers, as some risks to be managed by the fines and debt business unit are listed as ‘placeholder’ risks, with no evidence of controls or mitigating actions.

Revenue NSW uses internal audit processes that are led by the Department of Customer Service and has undertaken several reviews relevant to fines and debt administration. Revenue NSW reports to the Department on the status of recommendations identified from internal audits and has documentation that guides how it will implement the Department’s Risk Management Framework. Revenue NSW has reported that most actions from relevant internal audits and reviews have been closed out and actions in response to recommendations have been completed.

Revenue NSW has implemented governance and audit processes to ensure the integrity of its payment options and services, including hardship options, and to reduce possible misuse or fraud. For example, it conducts audits of WDO sponsors and advocates to ensure their compliance, and it has a specialised team that investigates suspected customer fraud.

Revenue NSW staff are required to report conflicts of interest. Conflicts of interest documentation for 2022–23 and 2023–24 revealed that most staff in the Fines and Debt business unit had an attestation on file. This helps to ensure compliance with Department of Customer Service policy. However, Revenue NSW advised that conflicts of interest are not flagged by Revenue NSW systems. This limits its ability to monitor and manage conflicts of interest should they arise in hardship cases, for example where an assessor has an existing relationship with an applicant.

The Hardship Review Board has governance arrangements in place and meets regularly

The Hardship Review Board is governed by a Charter that details the Board’s scope and how it will maintain confidentiality and operate effectively and efficiently. All work of the Board must be documented and abide by the principles of the Privacy and Personal Information Protection Act 1998 and Health Records and Information Privacy Act 2002.

The Charter provides that the Board meets on an ‘as required’ basis. Special meetings may be called in urgent situations as determined by the Secretary of the Board. The Board’s meeting minutes from September 2023 to February 2025 detailed that that the Board met every two to three months, and the minutes contained details on decisions made by the Board and the reasons for decision.

The Hardship Review Board is supported by a secretariat team within Revenue NSW. The secretariat manages and maintains a register of all applications and contact with the Board. It also prepares agendas and minutes for each Board meeting.

It is incorrect to describe the Hardship Review Board as independent of Revenue NSW

The Hardship Review Board has statutory powers to overturn or vary certain decisions made by Revenue NSW. While the Board’s website promotes its independence from Revenue NSW, this is not a statutory requirement and the Board has not been established, through its governance arrangements, nor in practice, as independent of Revenue NSW.

The Hardship Review Board’s meeting minutes from September 2023 to February 2025 identify the three Secretaries (of the Department of Customer Service, NSW Treasury and the Department of Communities and Justice) had delegated their functions to staff within their respective departments. They also identified that the Secretary of the Department of Customer Service had delegated their role on the Board to Revenue NSW. Delegations of this nature are allowable and consistent with comparable delegations across the NSW public service.

The Board’s Charter, and the instruments of delegation that establish its membership, do not reference independence. The description of the Board as independent as outlined on the website is incorrect.

¹⁰ Appendix 2 outlines relevant legislation and guidelines for administering fines and debt.

Revenue NSW has business rules, work instructions and support processes to guide staff consistency in considering customer fines and debts, including hardship assistance

Policies, procedures, work instructions and business rules help standardise approaches to tasks and promote compliance. Revenue NSW has documented agreements, guidelines, processes, business rules and work instructions available to staff and third-party assessors¹¹, and provides guidance on how to consider customers’ fines and debt, including administering hardship assistance under the policy.

Most of these business rules and work instructions have been recently updated, including following financial abuse diversion pilot projects and the subsequent roll out of Revenue NSW’s financial abuse squad. Staff from Revenue NSW also have access to specialised training to support them in providing hardship assistance to eligible customers, and the agency has processes in place for monitoring and training new staff in its Fines and Debt business unit.

Revenue NSW can improve the transparency of payment options or alternatives that are available to customers under the Hardship Policy

The Hardship Policy was approved by the Commissioner of Fines Administration in February 2023 and is publicly available on Revenue NSW’s website. It provides information on the types of hardship assistance available to customers and directs customers to separate webpages to apply for these options. Customers can also call Revenue NSW’s fines hotline for help with fines.

However, Revenue NSW can improve the transparency of options available under the Hardship Policy. Revenue NSW’s fine notices do not directly reference the Hardship Policy and only list payment plans as an option for individuals who cannot pay the fine by the due date. Overdue fine notices also do not directly reference the Hardship Policy but present some payment options such as payment plans and WDOs for individuals who are unable to pay the overdue fine by the due date. Fine notices and overdue fine notices do not provide details of how to apply for a fine write-off or fine reduction, and do not make clear that a combination of payment options may be offered by Revenue NSW to resolve the debt.

By not including details of the Hardship Policy on fine and debt notices, there is a risk that customers, particularly those without access to the internet or who are not computer literate, may not have knowledge or visibility of the policy. Without the ability to access the Hardship Policy online, these customers may rely on the First Nations Outreach Team, advocates, government agencies and community legal organisations for help with resolving their debt. Opportunities to address these gaps were noted by stakeholders and staff from Revenue NSW.

Some hardship options and services, such as fine reductions, the advocacy program and resolution options for state debts, are not detailed under the Hardship Policy. Instead, Revenue NSW’s website directs people to separate NSW Government webpages for these hardship options and services. There is also limited public information available regarding the timeframes Revenue NSW will take to process hardship applications, and the rules for how Revenue NSW assesses claims of hardship for each option. This could result in some eligible customers not being aware of available support or not having a clear understanding of how Revenue NSW considers their circumstances.

To facilitate procedural fairness, customers need to be aware of the appeals options available to them if they wish to dispute a decision by Revenue NSW. The Hardship Policy includes a section that directs unsuccessful applicants to the Hardship Review Board’s website to appeal decisions made by Revenue NSW. The Board’s website includes the types of reviews it conducts, how to apply for a review, how it considers hardship and eligibility criteria.

Revenue NSW has piloted diversion programs to promote specialised solutions for some vulnerable customers

Since Revenue NSW is not the issuing authority for fines, it does not have full control over the fines system. This limits its ability to proactively prevent fines being issued to vulnerable people. To respond to this challenge, Revenue NSW has piloted and rolled out several services, diversion programs and projects targeting provision of assistance to some cohorts of vulnerable people who are disproportionately impacted by the fines system, including a dedicated advocacy hotline and outreach service for First Nations communities.

The First Nations Outreach team was established in response to the Department of Customer Service Aboriginal Customer Engagement Strategy 2021–2025. These services aim to deliver culturally safe support to First Nations peoples with fines and debt. Other specialised solutions that have been rolled out by Revenue NSW include specialised resolution pathways for victim-survivors of financial abuse, diversion programs targeting vulnerable young people and people who have committed low-level drug offences.

Revenue NSW also has a dedicated Advocacy Hotline, where advocates can access information and advice, as well as perform a range of transactions on the behalf of customers, including setting up payment plans, asking for a fine to be placed on hold or asking for a licence or registration restriction to be lifted. Revenue NSW has not conducted an evaluation of these initiatives. Some staff from Revenue NSW advised the audit that the Advocacy Program could be better supported with a dedicated online portal, as advocates are often under-resourced and time poor.

Definitions of ‘hardship' and ‘vulnerable’ in the Hardship Policy are inconsistent with the definitions used by assessors to determine a customer’s eligibility across hardship options

The Hardship Policy establishes that assistance is available for those experiencing economic hardship and those who are vulnerable. However, these terms in the Hardship Policy differ from the definitions used by Revenue NSW staff to determine a customer’s eligibility across different hardship assistance options. While some definitions of hardship and vulnerability are defined in legislation, or are determined by external agencies, the Hardship Policy does not outline these differences.

The Hardship Policy also does not clarify that a combination of hardship options may be offered by Revenue NSW to a customer to resolve their fine, nor does it set out how this combination would be determined by staff.

Differences in eligibility criteria across hardship options may mean that customers are not sufficiently informed about their eligibility, or how their application may be assessed. Appendix 3 details different definitions of hardship and vulnerability across guidance used by Revenue NSW.

Revenue NSW has not provided evidence that it has sought input from people experiencing hardship or advocates about the Hardship Policy’s accuracy and effectiveness in outlining options and steps customers are required to take in seeking hardship assistance.

There are some gaps in the detailed guidance Revenue NSW uses for different hardship assistance options under the Hardship Policy

Revenue NSW has detailed guidance for the different options it provides under the Hardship Policy, as outlined in Exhibit 3, but there are some gaps in this guidance:

• there is no reference to fine reductions in the Hardship Policy and in business rules
• there is no reference to the Customer Commitments
• there is no detail on how and when to communicate with customers over complex matters such as eligibility requirements, requests for complex financial information and payment plans
• there is no guidance for determining discretionary spending or assessing the impact of a customer’s spouse or de facto partner’s income when determining a customer’s capacity to pay.

Some guidance, such as the Guidelines for Writing Off Fines and the State Debt Recovery Guidelines, had not been updated in accordance with their periods of review. Additionally, the Hardship Policy has not been reviewed in line with Revenue NSW’s intended timeframes for annual review.

Revenue NSW may offer customers a combination of hardship assistance payment options (combined resolution options) to resolve their overdue fine balance. For example, it may decide to write-off a portion of a customer’s debt and then ask the customer to complete a WDO or enter a payment plan to repay the remaining balance. Internal business rules for fine write-offs state that an assessor should determine whether a combined resolution option is more ‘appropriate’ for the customer. However, Revenue NSW does not have any documented guidance on how to assess whether a combined resolution option would be more appropriate for a customer, nor how to determine which combination of hardship options would be appropriate for a customer’s circumstances. These gaps raise the risk of inconsistent decision-making for determining eligibility for hardship assistance and the options made available to the customer.

There are opportunities for Revenue NSW to improve how it documents important elements of its decision-making on hardship assistance to ensure there is an audit trail and consistency

The audit reviewed a sample of 30 hardship applications determined by Revenue NSW across the audit period. This included applications for fine write-offs, payment plans, fine reductions and WDOs.

The sample review focused on whether decisions were made in compliance with relevant legislation, policy and business rules. The sample review found gaps in the completeness and accuracy of system produced data on hardship applications, including demographic information.

The sample review also found gaps in the completeness of the documentation. Documentation did not consistently include: detailed reasons for decision; whether and why discretion was used; how business rules were applied; documentation of decisions to provide certain payment options; how combined resolutions had been reached; and, information about the determination of customer eligibility for hardship assistance. Across the sample, the audit also found gaps in documentation as to whether Revenue NSW staff had complied with delegations. Documentation supporting some payment options, such as write-offs, was clearer and better supported by evidence than for others, such as fine reductions.

Revenue NSW has provided further context in response to the sample review, and explanations that demonstrate that many of these issues are known issues, are factors of system limitations to produce documentation to the audit, or were otherwise controlled, such as through system enforced delegations.

¹¹ Third-party assessments refer to assessments conducted by legal assistance organisations and WDO sponsors for fines to be written off under the mutual recognition scheme as well as eligibility for the WDO Scheme.

Revenue NSW undertakes quality assurance for its processes and decisions relating to fines and debt, but it is not doing so systematically and in line with its Fines and Debt Quality Framework

Quality assurance is an important process for ensuring that decisions, including decisions about hardship, have been made fairly, consistently and in compliance with legislative and policy requirements. As at 30 June 2025, Revenue NSW had around 610 full time equivalent staff that may be involved in assessing hardship applications and making discretionary decisions. Without adequate processes to provide assurance that decisions have been made accurately and consistently, customers may experience further disadvantage, or may be approved for a hardship assistance option for which they are not eligible.

Revenue NSW undertakes quality assurance of its processes, transactions and decisions made by staff in its Fines and Debt business unit, including across its hardship functions. The Fines and Debt business unit has a quality assurance framework which was developed with the purpose of ensuring that all the teams within the business unit provide a consistent and integrated approach to delivering quality, compliant and continuously improved services. The Fines and Debt Quality Framework outlines a focus on customer experience, compliance with business rules, legislation and procedures, effective and efficient use of resources and systems as well as record keeping and data security. Revenue NSW advised the audit that the Fines and Debt Quality Framework has been embedded in call-related work and is in the process of being operationalised in other areas of its Fines and Debt business unit.

However, the Fines and Debt Quality Framework does not provide guidance on identifying non-conformance, or how to apply standardised sampling techniques. As a result, Revenue NSW is not applying systematic quality assessment processes across teams in the Fines and Debt business unit. This limits its ability to assure and compare quality across payment options and services. Revenue NSW advised the audit that quality assurance processes vary across its Fines and Debt business unit, and across the broader organisation, due to the range of services and payment options they provide, which have different legislative and procedural requirements.

Since the Quality Framework has yet to be embedded across all areas of the Fines and Debt business unit, there is a risk of inconsistency in quality assurance application across teams and hardship assistance functions, which may result in poor outcomes for customers. There is also a risk that without clear guidance on sampling, the number of cases reviewed by Revenue NSW for quality assurance purposes is not meaningful or sufficiently representative.

Revenue NSW is not undertaking quality assurance for all processes and decisions relating to hardship assistance

Revenue NSW’s Fines and Debt business unit undertakes quality assurance activities for fine write-offs as well as WDOs and financial abuse action log audits. These quality assurance activities are supported by documented methodology. Other quality assurance activities, such as case management reviews (including reviews of care provided to survivors of financial abuse), correspondence assessments and phone call assessments, are informed by self-guided evaluation forms. These forms incorporate quality assurance relating to customer experience.

During phone call quality assessments, team leaders across the Fines and Debt business unit monitor whether payment options such as payment plans, WDOs or fine reductions are offered to individuals to resolve their outstanding fine balance. However, quality assurance is not undertaken for all processes and decisions relating to hardship assistance, such as payment plans that are approved by staff, the approval of fine reductions, or decisions where a combination of options were approved for an individual to resolve their debt. By not undertaking quality assurance consistently across all decisions made to provide hardship assistance, including under the Hardship Policy, there is a risk that systemic errors are not addressed or that processes are changed without being informed by quality assurance insights.

Staff from Revenue NSW advised that the application of quality assurance by frontline managers varies, including the timing of reviews and the number of cases that are sampled. Staff also reported that some quality assessments, such as phone call monitoring, are not guided by scores or benchmarks.

Revenue NSW is measuring performance against the Customer Commitments, but it does not know how this is applied to its provision of hardship assistance

The Hardship Policy provides that people experiencing hardship are to be treated in accordance with the Customer Commitments.

Revenue NSW conducts post-interaction surveys where each of the six Customer Commitments are broken down into a series of statements. Customers are then asked to provide a score for each of these statements. The survey provides insights for the whole of Revenue NSW regarding its performance against the Customer Commitments. Revenue NSW further compares survey results across fines, ambulance fees, state debts (excluding ambulance debts), land tax, payroll tax, transfer duties and unclaimed money. However, survey reporting does not provide specific insights into customer experiences of seeking assistance under the Hardship Policy.

Revenue NSW conducts quality assessments of phone calls and correspondence to customers in the Fines and Debt business unit. These forms incorporate some questions relating to customer experience. However, Revenue NSW is not using insights from these quality assurance activities to monitor whether it is providing services in line with its Customer Commitments. As a result, it cannot demonstrate whether customers seeking assistance under the Hardship Policy are being treated in accordance with the Customer Commitments. In addition, Revenue NSW is not using quality assurance insights to guide continuous improvement such as process improvement or staff training opportunities.

Revenue NSW does not have a systematic process for considering the outcomes of Hardship Review Board decisions to inform continuous improvement

The Hardship Policy identifies Revenue NSW’s commitment to continuous improvement and states that the policy and programs are continually being reviewed and revised to ensure that they remain relevant and useful. Additionally, continuous improvement is a core principle underpinning Revenue NSW’s Fines and Debt Quality Framework. Understanding the reasons why the Hardship Review Board varied or overturned decisions, could inform process improvement such as updates to business rules.

Across fines and state debts, around 500 applications for review have been received by the Board since 2021–22 in total, compared with approximately 13.3 million fines issued over the same period. Around 300 of these applications did not progress to the Board for consideration due to eligibility requirements, withdrawals following further review by Revenue NSW or insufficient information to proceed. Exhibit 9 demonstrates the number of Hardship Review Board determinations relevant to fines and debt from 2021–22 to 2024–25.

Source: Audit Office analysis of Revenue NSW data (unpublished).

Since 2021–22, the percentage of Revenue NSW decisions that the Hardship Review Board has confirmed has decreased from 72% to 23% in 2024–25. Over the same period, the percentage of decisions made by Revenue NSW that the Hardship Review Board has varied increased from 22% in 2021–22 to 73% in 2024–25. The most common reason for the Hardship Review Board varying the decisions made by Revenue NSW is to update a customer’s payment plan or issue a new payment plan.

The secretariat for the Hardship Review Board shares information with Revenue NSW about how the board has considered decisions for fines, state debt and taxes. However, Revenue NSW does not have a systematic process to consider the outcomes of decisions made by the Board to promote continuous improvement. Revenue NSW advised that informal discussions are held with operational teams in relation to issues and trends observed by the Board.

By not using Hardship Review Board feedback to guide continuous improvement, Revenue NSW is missing the opportunity to consider important precedents to guide future decision-making, such as differences in assessments of eligibility for certain programs or payment options, or differences between it and the Board’s judgements of customers’ capacity to pay.

Revenue NSW uses automated decision-making, machine learning and artificial intelligence (automation and artificial intelligence) to aid some of its fine and debt collection activities. This includes identifying people who may be at risk of negative impacts from the fines system and preventing action being undertaken against them. Revenue NSW also uses automated decision-making to process fine notification activities based on customer preferences, and to schedule fine enforcement activities for action by human assessors. Exhibit 10 summarises Revenue NSW’s automation and artificial intelligence tools and their purpose and use.

Source: Audit Office analysis of Revenue NSW documentation 2025.

Revenue NSW’s use of automation and artificial intelligence has been subject to management oversight, but there are some gaps in the documentation of risks associated with key tools

While it has a high risk-appetite for technological innovation, Revenue NSW’s appetite for risk within data decisions and ethics is low. Consistent with this risk appetite, there is a need for up to date and complete risk assessments for digital tools and the use of data. Revenue NSW’s enterprise and operational risk assessments identify artificial intelligence and automation as an organisational risk.

Revenue NSW has provided evidence of senior management review and acceptance of key risks associated with its use of automation and artificial intelligence in fines and debt. It undertook work to develop a detailed risk assessment in 2023 for its use of automation in garnishee orders¹², following external reviews by the NSW Ombudsman, and a review it proactively commissioned in 2022. Revenue NSW also recently developed a risk and opportunity assessment for the use of automation and artificial intelligence across the organisation in July 2025.

However, there are gaps in some of these risk assessments for the use of automation and artificial intelligence in fines and debt operations, which have incomplete risk ratings and detail about the controls and mitigating actions.

For example, Revenue NSW’s risk assessment for the use of the garnishee order system has not been revisited since 2023, and there is no evidence this has been kept up to date. The risk assessment Revenue NSW provided has not been reflected in its enterprise and operational risk documentation.

Revenue NSW uses automation and artificial intelligence to identify vulnerable people and remove them from enforcement action, but there are gaps in how it has documented expectations for the accuracy of this work

Revenue NSW uses automation and artificial intelligence to identify the likelihood of a person being vulnerable using a set of business rules. Although the outputs of the model are not a final assessment of vulnerability, nor the sole determinant of enforcement decisions, they can be used to remove individuals from enforcement action processes, such as removal from orders to garnish money from wages or salaries, or from bank accounts.

Project documentation from when the model was introduced, and interviews with Revenue NSW staff conducted as part of this audit, outlined that the model supports the efficient management of hardship assistance and fine enforcement activities, as it enables and informs batch processes, and identifies vulnerable persons before they would otherwise self-identify. For example, the model assists in removing people from queues for garnishee orders and would reduce administration costs associated with processing refunds for incorrectly issued orders.

Revenue NSW regularly tests the accuracy of the model and reports on changes and assumptions to the model to the Fines and Debt Technical Discussion Group. However, it has not defined key success outcomes, nor whether the model is meeting expectations for accuracy, efficiency and effectiveness.

Revenue NSW’s accuracy tests review how effectively the vulnerability detection model predicts whether a customer is likely to be vulnerable and require diversion from usual fine enforcement activity. Model testing documentation indicates the model’s overall accuracy rate for predicting a person’s vulnerability was 83% as at April 2025, as compared with a reported 97% in July 2021. In the absence of key success outcomes and accuracy targets, there is no evidence as to whether this performance is meeting Revenue NSW’s expectations. Revenue NSW’s testing does not compare the model’s performance against assessments made by staff, nor assessments of vulnerability made by issuing authorities and partner agencies.

Revenue NSW has not yet reassessed whether its use of automation and artificial intelligence meets the NSW Artificial Intelligence Assurance Framework’s ethical requirements

Revenue NSW’s automation and artificial intelligence tools used in its fines and debt operations were designed and implemented in 2018, before formal ethical framework assessment requirements were established by the Department of Customer Service in September 2020. Revenue NSW has provided evidence of assessments against the Mandatory Ethical Principles for the use of artificial intelligence in April 2021.

Revenue NSW has not yet reassessed its use of automation and artificial intelligence tools against the NSW Artificial Intelligence Assurance Framework principles. While there is no mandatory requirement to reassess the tools against the Framework, key considerations under the NSW Government’s Artificial Intelligence Ethics Policy outline that ‘it is imperative that AI (artificial intelligence) solutions are designed with and monitored against explicit standards for performance, reliability, robustness and auditability, and that they align with the Ethical AI principles.’ The policy also suggests that the Framework should be used periodically to review services that use artificial intelligence systems. Further, expectations and considerations for the use of artificial intelligence outlined in the Framework have changed since 2021.

Revenue NSW proactively undertook an internal review of its automation and artificial intelligence governance in 2024. The review identified improvement opportunities relating to the adoption of artificial intelligence ethics principles more broadly across Revenue NSW, embedding ethics into risk management practices and limited governance mechanisms and inventories of in-development and deployed tools and uses. Revenue NSW is implementing a response to the review’s management actions, supported by a governance framework and steering committee, with an interim approach implemented in July 2025.

Addressing these recommendations would support Revenue NSW to have an enterprise wide understanding of the use of artificial intelligence and ethical principles, as well as informing an assessment of current NSW Artificial Intelligence Assurance Framework Requirements.

Revenue NSW has identified risks to the quality of its data, and advises it has implemented controls and processes to address gaps in systems used to manage fines and debts

Revenue NSW uses several information systems to manage fines and state debts. These systems manage all aspects of the fine from issuance to resolution. Revenue NSW has a system for receiving penalty notices, and another system for processing fine recovery options. The flow of data between these systems depends on whether the fine is overdue and on timeframes for response by staff and fine recipients.

There are some gaps in data produced by these systems. For example, in listings provided to the audit with data covering a range of payment options provided to customers under the Hardship Policy, the audit found gaps in completeness and accuracy, including gaps in demographic information that would guide actions taken by Revenue NSW staff, and vulnerability detection undertaken under automation and artificial intelligence.

Revenue NSW attributed these gaps in data to a number of factors, including:

• gaps in data supplied to Revenue NSW from issuing agencies or WDO sponsors
• manual entry of paper-based infringement notices
• system limitations stemming from ageing systems that do not easily allow for amendments in response to policy changes, and limited business knowledge of process changes
• data being captured in notes attached to the system, rather than system outputs.

Revenue NSW has documented risks associated with data entry errors in its operational risk registers. It advised that it has implemented controls and processes to overcome gaps in data or information. For example, some quality control is undertaken to validate addresses and other information, based on existing customers or matches in agency databases (such as Service NSW or Transport for NSW), and there are data entry quality checks performed on instances of manual entry. It has applied business rules to enforcement activity for young people and those aged over 65 years. This is also applied for inputs into the vulnerability detection model.

There are memoranda of understanding and information sharing arrangements in place with several state government agencies and divisions, including Corrective Services NSW, NSW Trustee and Guardian, and the Department of Communities and Justice, which provide arrangements for how Revenue NSW will assist these customers with their fines or debt. Revenue NSW uses this data to facilitate machine learning to provide better identification of customers details, addresses and other demographic information.

Revenue NSW’s fine enforcement system has recently been updated to provide a ‘single view of customer’. However, it has not yet evaluated the impacts of this functionality update.

¹² Under the Fines Act 1996 and the State Debt Recovery Act 2018, Revenue NSW may issue garnishee orders to recover unpaid debts. Garnishee orders can be issued to a debtor’s employer, property agent or bank to repay the debt.

Revenue NSW’s written communication with people experiencing hardship is not tailored to their circumstances and needs

Research commissioned by Revenue NSW has raised several risks regarding the effectiveness of the approach to its written communication with customers. There is no evidence that Revenue NSW has designed or updated correspondence templates to incorporate customer requirements or behavioural insights. This gap may increase the risk of customers ignoring communication, risking enforcement action, and not receiving support because of poor understanding of Revenue NSW’s written communication.

For example, Revenue NSW has a Customer Commitment to ‘act with empathy’. Across case notes reviewed as part of the audit sample, and discussions with staff during the course of the audit, Revenue NSW staff demonstrated genuine understanding of the needs and circumstances of customers facing hardship. However, Revenue NSW’s business processes do not provide staff with guidance for how to act with care and empathy, including the types of questions to ask, language to use and follow up communications, especially when the decision is not positive for the customer.

Revenue NSW’s public policies, information guidelines and letters to customers experiencing hardship are prepared in formal, legalistic language. The information does not appear to be suited to people from culturally and linguistically diverse communities, people with learning difficulties, or people without experience in dealing with legal and complex financial matters.

For example, an excerpt from one letter from Revenue NSW to an applicant listed as being ‘culturally and linguistically diverse’ provides an example of the legalistic tone and the absence of a clear reason for why the application was declined (Exhibit 11).

Source: Revenue NSW correspondence to a customer.

Revenue NSW has a Customer Commitment to be ‘easy to understand’. Revenue NSW’s public information on how it assesses applications or eligibility criteria does not appear to be designed to be easy to understand for the customer. Its resources are often lengthy and do not explain things in plain English. Work instructions and business rules do not provide the Revenue NSW workforce with clear guidance on how to communicate in writing with customers seeking hardship assistance, including those who are unsuccessful. Staff advised that drafting of correspondence is largely left to assessors who draft letters based on the outcome of an application using templates. Revenue NSW advised that its decisions on discretionary spending or capacity to pay are only communicated in general terms to hardship assistance applicants.

The audit reviewed a case where a customer resubmitted an application for hardship assistance. The initial application had been rejected because the customer had not responded to a request and follow-up reminder for additional information, including payslips and statements for all savings, investment and superannuation accounts. Because the applicant did not respond to written requests for further information the case was closed. The applicant resubmitted the application, the same request for further information was repeated, there was no response to the written request/follow up reminder and the case was closed.

The assessor largely followed Revenue NSW’s process for requesting further information:

• ‘If you do not have enough evidence for your assessment, you should send/call the person who lodged the application and ask them for further documents.
• If you are unable to contact the person via phone, you may send correspondence requesting the required information within 28 days.
• If no information has been provided within 28 days, continue through this process with the information on file.
• You can elect to decline an application due to insufficient information and leave the option open for the client to reapply later with new documents.’

The processes did not guide the assessor to seek other ways of following up the request, especially in the case of a resubmitted application. The process does not include the potential to use Revenue NSW’s network of advocates or to leverage translation services in case of language difficulties.

The audit’s review of a sample of written correspondence from Revenue NSW identified gaps in clarity and transparency

A review of a sample of written correspondence issued by Revenue NSW as part of this audit identified opportunities to increase clarity and transparency in decision-making, and to demonstrate empathy and understanding of the experiences of applicants.

The audit reviewed a sample of 39 letters communicating Revenue NSW’s decisions to an applicant’s request for hardship assistance. The sample included decisions that were approved and decisions that were refused for fine write-offs, Work and Development Orders (WDOs) and 50% fine reductions.

Across the sample of correspondence for fine write-offs refused, all outcome letters provided details to the applicant on how to appeal the decision to the Hardship Review Board. However, only 64% provided a reason or explanation for how or why the decision was made by Revenue NSW. Such reasons could include lack of eligibility for write-off assistance due to employment status or deemed capacity to pay, exceeding income thresholds for the WDO Scheme, or patterns of expenditure.

Revenue NSW advised that its decisions on discretionary spending or capacity to pay are only communicated in general terms to hardship assistance applicants. It did not explain the rationale for this approach, or whether it has measured customers’ understanding of the reasons provided and satisfaction with the outcome. Gaps in providing clear reasons or explanations may limit an applicant’s ability to meaningfully understand the grounds on which they may appeal or provide additional information to achieve a different outcome.

Applicants may also appeal Revenue NSW’s decision to refuse or cancel a WDO. Only 21% of WDO outcome letters for refused or cancelled WDOs reviewed as part of this audit provided information to the applicant about how to appeal Revenue NSWs decision to the Hardship Review Board.

The sample review also found that only 34% of all correspondence to applicants acknowledged the applicant’s difficult circumstances or demonstrated empathy for the applicant’s situation. This is despite one of Revenue NSW’s Customer Commitments being to ‘act with empathy’. Additionally, only 54% of outcome correspondence from Revenue NSW to hardship assistance applicants included information about other support services that may be useful for those experiencing hardship, such as the National Debt Helpline or cost of living rebates offered by Service NSW.

None of the correspondence provided information to applicants about how and where they could make a complaint about the application process or about the service received from Revenue NSW.

In addition, the audit reviewed correspondence issued by the Hardship Review Board. Across a sample of 15 outcome letters sent to applicants by the Hardship Review Board, all contained a clearly stated decision, and most contained clear reasons for decision. However, no letters contained information about support services. Similar to correspondence issued by Revenue NSW, there were opportunities to provide greater empathy to applicants, in recognition of the challenging circumstances experienced.

Revenue NSW advised the audit that there are further avenues applicants can pursue in dealing with hardship, such as requests to a Member of Parliament or the NSW Ombudsman. However, the Hardship Review Board’s website and Charter provide that its decisions cannot be appealed further. Revenue NSW’s website and the Hardship Policy do not refer to these additional avenues of advocacy and complaint. Therefore, the Board provides an important, if not final decision for applicants. Consequently, the Board’s correspondence could provide more details on support services to demonstrate care and empathy.

The details of the sample analysis are outlined in Exhibit 12.

* Note: The results listed in this exhibit represent the proportion of the sample in which this test would be applicable, such as requirements for details on appeals in refused decisions only.

Source: Audit Office analysis of hardship case correspondence provided by Revenue NSW, 2023–24 to 2024–25 (to 31 March 2025).

The audit team did not review phone contact made by assessors with applicants or their advocates. This contact is noted in individual case files and may have addressed the gaps identified in correspondence. Revenue NSW advised the audit that most inbound and outbound phone calls are recorded and retained in accordance with recording and data retention policies, except for some, such as calls with issuing authorities regarding Requests for Review.

Revenue NSW monitors and reports internally on organisational activity and compliance

Revenue NSW’s monitoring and reporting includes some hardship-focused outputs such as performance for fine diversion projects, as well as the uptake of Work and Development Orders (WDO)s and fine reductions. Revenue NSW provides a range of dashboards, reports and other information that demonstrate activity and outputs to its senior management, business unit directors and line management. This supports governance by ensuring that all levels of management are receiving tailored performance and activity information.

Revenue NSW undertakes regular reporting on compliance against legislative requirements through annual attestations. For example, its Fines and Debt business unit Compliance Attestation for 2024 identified several compliance risks relevant to the State Debt Recovery Act 2018, including the risk that Revenue NSW may be undertaking enforcement action against minors. The documentation detailed that a project team was established to undertake a pilot program as an action to address these issues. However, Revenue NSW is not monitoring the implementation of recommended actions to address compliance raised in attestations. Senior staff could not provide the audit team with an update on these recommended actions to address compliance risks.

Revenue NSW has not evaluated whether its administration of hardship assistance, including the implementation of the Hardship Policy, is efficient or effective

Revenue NSW has not defined or developed measures that could be used to evaluate the outcomes of hardship assistance administered and whether the Hardship Policy is achieving its purpose. The purpose of the policy is to ensure that people experiencing hardship are treated in accordance with Revenue NSW’s Customer Commitments. However, Revenue NSW has not defined measures such as Key Performance Indicators (KPIs) relevant to its provision of hardship assistance to assess this.

Revenue NSW aims to provide a range of payment options to support customers under the Hardship Policy, but it is not monitoring measures that would demonstrate, for example:

• whether the range of payment options is effectively facilitating tailored hardship assistance
• whether levels of hardship applications are consistent with demand
• whether key population subgroups are being adequately supported in line with expected characteristics of vulnerability and access
• whether there is consistency in decisions being made by Revenue NSW to approve hardship assistance.

Developing performance measures and measuring outcomes would enable Revenue NSW to evaluate whether its administration of hardship assistance is efficient and effective, and meeting the purpose of the Hardship Policy. It would also help inform Revenue NSW’s continuous improvement approach, which is committed to in the Hardship Policy.

Although Revenue NSW has not evaluated the effectiveness and efficiency in its implementation of hardship assistance, it has evaluated the outcomes of some of its piloted diversion programs targeted at subgroups that it considers are vulnerable. Revenue NSW has provided evidence that it has evaluated the effectiveness of these programs by reporting, for example, lessons learned and by completing benefit realisation reviews. This audit did not assess the effectiveness of these pilot diversion programs.

Revenue NSW is not systematically monitoring trends that would indicate demand for hardship assistance

Revenue NSW advised that it has identified some factors that impact on the demand for hardship assistance, such as the availability of digital solutions in regional areas, regional Work and Development Order (WDO) sponsor availability and the lack of services and programs to address the needs of people from culturally and linguistically diverse backgrounds.

However, Revenue NSW is not systematically monitoring broader risk factors or financial trends that could lead to an increase in demand for hardship assistance. For example, Revenue NSW did not provide evidence that it is monitoring trends in mortgage defaults, unemployment rates, or rates related to the inability to pay for essential services. This limits Revenue NSW’s ability to understand how changes in broader risks and trends impact on the demand for hardship assistance and tailor resourcing and responses accordingly.

Revenue NSW does not have benchmarks or targets for assessing its performance in the delivery of hardship assistance

Revenue NSW advised the audit that there are no benchmarks or targets for performance in the administration of hardship assistance, because it is difficult to define what good performance looks like as customer outcomes from delivering assistance are not always quantifiable.

Revenue NSW does monitor and report on the aggregated volumes and values of hardship assistance options that have been approved. Some examples of this reporting include:

• the number of write-off applications and the aggregate dollar value of those applications for write-offs
• the number of WDOs and the approved dollar amount relating to those WDOs
• the number of fine reductions approved, along with the corresponding dollar value of debt.

However, there are no benchmarks or targets for these values. Revenue NSW advised that this is because hardship may vary depending on economic circumstances, so it is difficult to identify a specific number or value to target.

Revenue NSW advised that complaints data and aggregated data on the number of hardship options approved for customers (such as write-offs and WDOs) were used to assess performance in delivering hardship assistance. For 2024–25, around six percent of all complaints to the Fines and Debt business unit were related to hardship. However, Revenue NSW is not systematically monitoring complaints relating to hardship assistance, and it does not have a mechanism to automatically tag complaints as relevant to hardship.

Revenue NSW has few KPIs that measure its performance in delivering hardship assistance

Revenue NSW has not established KPIs at a program or policy level to assess its performance in the delivery of hardship assistance. Revenue NSW has developed KPIs that relate to individual staff performance, including the time taken to answer calls and the average handling time of calls, timeliness of correspondence, and following work instructions.

Although there are no specific program or policy level KPIs, there are some staff level KPIs that relate to the effectiveness of staff delivery of hardship assistance. Some of these KPIs include:

• 20% or more of approved WDOs are for First Nations customers
• completing fine write-offs in less than 14 days
• 95% of sampled WDO sponsors are compliant with WDO guidelines
• 100% of WDOs are set up according to customer circumstances and/or combined resolution options offered
• less than ten per cent of hardship assistance applications overturned by the Hardship Review Board.

In some instances, Revenue NSW has, but is not using, available data to report against the staff KPIs that are directly related to the provision of hardship, and in some others it does not have data to report against these. For example, Revenue NSW provided the audit with a list containing the number of decisions related to fines that were confirmed, overturned, or varied by the Hardship Review Board since 2021–22, but did not provide KPI reporting on whether less than ten per cent of hardship assistance applications were overturned by the Board. Similarly, Revenue NSW was able to provide a listing of approved WDO applications that included whether the applicant identified as First Nations but did not provide KPI reporting on the percentage of approved WDOs for First Nations customers.

Revenue NSW does not publicly report about its performance in delivering the Hardship Policy

To support accountability and improve outcomes, it is important that Revenue NSW measures and reports on the outcomes of its implementation of the Hardship Policy. Transparent reporting would provide insights to eligible individuals regarding the range of hardship assistance and volume of decisions that may be relevant to their circumstances.

Revenue NSW currently reports on its activity through the Department of Customer Service’s annual reports. This reporting sets out its activities in facilitating WDOs, progress in delivering pilot diversion programs and its community engagement and outreach. Revenue NSW also provides reporting of fines, overdue fines, fine reductions and WDOs on its publicly available open data dashboard. However, there is no public information about its processing of fine write-offs, garnishee order refunds or payment plans (Exhibit 13).

Revenue NSW has not met its requirements under fine write-off guidelines to publicly report on decisions related to fine write-offs in its annual reports.

Revenue NSW does not publicly report on the costs associated with administering hardship applications. Consequently, it is difficult to determine whether its assessment and processing of applications is efficient.

Exhibit 13: Public reporting on the activities of Revenue NSW and the Hardship Review Board

	Currently reported
Activity	DCS Annual Report (2023–24)	Revenue NSW website
Fines
Overdue fines
Hardship support – WDOs
Hardship support – fine write-offs
Hardship support – fine reductions
Hardship support – garnishee order refunds
Hardship support – payment plans
Diversion programs
Community engagement and outreach
Hardship Review Board
Use of consultants

Source: Audit Office summary of current public reporting on the activities of Revenue NSW.

There is no public transparency in relation to the Hardship Review Board’s activity

Revenue NSW provides secretariat support to the Hardship Review Board. Transparency relating to the Board’s activity is important for promoting public accountability and ensuring that it is an effective appeal mechanism for people experiencing hardship. There is no public reporting on the Hardship Review Board’s activity on the Board’s website, nor within the Department of Customer Service’s annual reports. There is also no public information about the Board’s operations, including its delegated membership, meeting attendance, number of applications received and considered by the Board, and trends in the outcomes of its decisions.

This limits the ability of the public to understand how often the Hardship Review Board considers applications and how effectively Revenue NSW assesses hardship assistance applications, given the proportion of decisions that are varied or overturned by the Board.