Understanding the Commonwealth Grants Rules and Principles 2024
What They Actually Mean for People Who Run Grant Programs
A White Paper by Geoffrey Clow | Founder & Principal Consultant, EGA – An Expert Grant Program Advisory
Why This Guide Exists
The Commonwealth Grants Rules and Principles 2024 (CGRPs) is a 50-page document written by lawyers and policy officers for lawyers and policy officers. It protects the Commonwealth’s position, creates paper trails, and allows for flexibility that officials can use well or badly.
What it doesn’t do is help a grant program manager at a state agency, an assessment panel chair at a regional development commission, or a grants officer in a community foundation actually run a decent grant program.
This guide is different. It translates the CGRPs into operational language. It draws the line clearly between what’s mandatory and what’s merely encouraged. And it uses real examples from ANAO audits to show what happens when programs go wrong.
If you design grant programs, assess applications, brief ministers, or manage grant agreements, this guide is for you. It won’t make the CGRPs exciting. But it will make them useful.
What you'll find here
Part 1: The Framework at a Glance
What the CGRPs Actually Are
The CGRPs sit within a broader ecosystem. Understanding where they fit helps you know when they apply and when other rules take over.
The hierarchy works like this:
- The Constitution: Section 96 payments to states, lawful authority for spending
- The PGPA Act 2013: The overarching accountability framework for all Commonwealth entities
- The PGPA Rule 2014: Detailed requirements under the PGPA Act
- The CGRPs 2024: The grants-specific framework issued by the Finance Minister
- Entity-level policies: Your department’s internal grants administration procedures
- Program guidelines: The specific rules for each grant opportunity
The CGRPs apply to all non-corporate Commonwealth entities. Corporate Commonwealth entities (like Sport Australia) weren’t covered until Division 6A of the PGPA Rule extended ministerial requirements to them, a direct result of the Sports Grants scandal.
What the CGRPs don’t cover:
- Procurement (that’s the Commonwealth Procurement Rules)
- Section 96 payments to states
- Payments under the Federal Financial Relations Act
- Official development assistance
- Tax concessions
- Investments and loans
- Payments under specific legislation like the Higher Education Support Act
If you’re not sure whether something is a grant or procurement, the CGRPs require you to establish that first. The distinction matters: procurement is acquiring goods and services for the Commonwealth’s own use; grants are financial assistance to help someone else achieve their objectives while also achieving government policy outcomes.
Understanding the Commonwealth Grants Rules and Principles 2024
What They Actually Mean for People Who Run Grant Programs
A White Paper by Geoffrey Clow | Founder & Principal Consultant, EGA – An Expert Grant Program Advisory
Why This Guide Exists
The Commonwealth Grants Rules and Principles 2024 (CGRPs) is a 50-page document written by lawyers and policy officers for lawyers and policy officers. It protects the Commonwealth’s position, creates paper trails, and allows for flexibility that officials can use well or badly.
What it doesn’t do is help a grant program manager at a state agency, an assessment panel chair at a regional development commission, or a grants officer in a community foundation actually run a decent grant program.
This guide is different. It translates the CGRPs into operational language. It draws the line clearly between what’s mandatory and what’s merely encouraged. And it uses real examples from ANAO audits to show what happens when programs go wrong.
If you design grant programs, assess applications, brief ministers, or manage grant agreements, this guide is for you. It won’t make the CGRPs exciting. But it will make them useful.
What you'll find here
Part 1: The Framework at a Glance
What the CGRPs Actually Are
The CGRPs sit within a broader ecosystem. Understanding where they fit helps you know when they apply and when other rules take over.
The hierarchy works like this:
- The Constitution: Section 96 payments to states, lawful authority for spending
- The PGPA Act 2013: The overarching accountability framework for all Commonwealth entities
- The PGPA Rule 2014: Detailed requirements under the PGPA Act
- The CGRPs 2024: The grants-specific framework issued by the Finance Minister
- Entity-level policies: Your department’s internal grants administration procedures
- Program guidelines: The specific rules for each grant opportunity
The CGRPs apply to all non-corporate Commonwealth entities. Corporate Commonwealth entities (like Sport Australia) weren’t covered until Division 6A of the PGPA Rule extended ministerial requirements to them, a direct result of the Sports Grants scandal.
What the CGRPs don’t cover:
- Procurement (that’s the Commonwealth Procurement Rules)
- Section 96 payments to states
- Payments under the Federal Financial Relations Act
- Official development assistance
- Tax concessions
- Investments and loans
- Payments under specific legislation like the Higher Education Support Act
If you’re not sure whether something is a grant or procurement, the CGRPs require you to establish that first. The distinction matters: procurement is acquiring goods and services for the Commonwealth’s own use; grants are financial assistance to help someone else achieve their objectives while also achieving government policy outcomes.
The Nine Key Principles. In Plain English
The CGRPs contain nine principles that sound reasonable but are vague enough to drive a truck through. Here’s what they actually mean in practice:
1. Robust Planning and Design
What it says: High-quality planning underpins efficient, effective, economical and ethical grants administration.
What it means: Before you open a grant round, you should know what you’re trying to achieve, how you’ll measure success, what risks you’re managing, and why a grant (rather than procurement or regulation) is the right tool. You should have talked to potential applicants and stakeholders.
Where programs fail: They design guidelines in isolation, set eligibility criteria that exclude the organisations best placed to deliver, or create assessment processes that don’t actually measure what matters.
2. Collaboration and Partnership
What it says: Officials should work collaboratively with government and non-government stakeholders.
What it means: Talk to people before finalising your guidelines. Find out what’s already funded elsewhere. Don’t duplicate. Consider longer-term agreements that build genuine partnerships rather than one-off transactional grants.
Where programs fail: They treat applicants as supplicants rather than partners, ignore sector expertise in program design, and create unnecessary duplication across agencies.
3. Proportionality
What it says: Strike an appropriate balance between complexity, risks, outcomes, and transparency.
What it means: A $5,000 community grant shouldn’t require the same application process as a $5 million infrastructure project. Reporting requirements should match the risk and scale of the grant. Don’t ask small organisations to meet corporate governance standards.
Where programs fail: They apply one-size-fits-all templates regardless of scale, burden small grantees with disproportionate reporting, or (conversely) fail to apply adequate oversight to high-risk, high-value grants.
4. An Outcomes Orientation What it says: Focus on achieving government policy outcomes.
What it means: Design programs around what you want to change in the world, not just what activities you want to fund. Measure whether outcomes were achieved, not just whether money was spent.
Where programs fail: They measure outputs (number of grants made, dollars expended) rather than outcomes (employment created, services delivered, communities strengthened). They don’t build evaluation into program design.
5. Merit-Based Processes What it says: Competitive, merit-based selection processes should be used unless specifically agreed otherwise.
What it means: If you’re running a competitive process, the applications assessed as most meritorious should be the ones recommended for funding. If you’re not running a competitive process, you need to document why and ensure your guidelines make this clear.
Where programs fail: They run ostensibly competitive processes but then approve applications that weren’t recommended based on merit assessment. They use “other factors” to override documented assessment without adequate justification or transparency.
The quiet truth: Everyone in the building knows when a decision has been made before the assessment is complete. The CGRPs don’t prevent ministers from exercising discretion; but they do require that your assessment be genuine, your recommendations be documented, and the basis for any departure be recorded. Your job is to make the honest recommendation. What happens after that is above your pay grade, but it’s not above the framework’s reporting requirements.
6. Achieving Value with Relevant Money
What it says: Value with relevant money should be a prime consideration in all phases of grants administration.
What it means: The grant should achieve something worthwhile that wouldn’t have happened without it. The administration costs should be proportionate. You should be able to demonstrate why this use of public money represents good value compared to alternatives.
Where programs fail: They fund projects that would have happened anyway, impose administration costs that exceed the value delivered, or can’t demonstrate why funded projects represent better value than rejected ones.
7. Consistency with Grant Guidelines and Established Processes
What it says: Decisions to award grants should correspond to the guidelines and the published process.
What it means: If your guidelines say applications will be assessed against specific criteria, assess them against those criteria. If you’re going to approve something that doesn’t meet the criteria, document why and ensure you have authority to do so.
Where programs fail: They change the rules mid-process, apply unpublished criteria, or make decisions that can’t be reconciled with the published guidelines.
8. Governance and Accountability
What it says: Grants administration should be underpinned by solid governance structures and clear accountability.
What it means: Everyone involved should know their role. Decisions should be documented. Conflicts of interest should be declared and managed. There should be appropriate separation of duties.
Where programs fail: They blur the lines between assessment, advice, and decision-making. They don’t maintain adequate records. They allow conflicts of interest to compromise (or appear to compromise) decisions.
9. Probity and Transparency What it says: Establishing and maintaining probity involves applying and complying with public sector values and duties such as honesty, integrity, impartiality and accountability.
What it means: You should be able to explain and justify every decision. The process should be defensible under scrutiny. Information about grants awarded should be publicly available.
Where programs fail: They can’t explain why particular applications succeeded or failed. They don’t publish required information on GrantConnect. They allow political or personal considerations to influence decisions without transparency.
Now that you understand what the CGRPs say, the next question is what they actually require of you; and where you have room to move.
Part 2: What's Mandatory vs What's Encouraged
The CGRPs blur the line between requirements and recommendations. This section draws that line clearly.
Mandatory Requirements (The “Musts”)
These are non-negotiable. Failure to comply is a breach of the framework.
For all officials:
- Establish and document whether a proposed activity is a grant before applying the CGRPs (para 4.2)
- Develop grant opportunity guidelines for all new grant opportunities, including one-off ad hoc grants (para 4.4)
- Ensure grant opportunity guidelines are consistent with the CGRPs (para 4.4)
- Advise the relevant minister on requirements of the PGPA Act, Rule, and CGRPs where a minister is considering proposed expenditure (para 4.4)
- Record in writing the basis for approval when approving the proposed commitment of relevant money (para 4.5)
- Publish grant opportunity guidelines on GrantConnect (para 5.2)
- Report on GrantConnect within 21 calendar days of a grant agreement taking effect (para 5.4)
- Comply with the PGPA Act requirements on recording commitments, disclosing interests, and retaining records
For officials briefing ministers:
Written advice to ministers must, at minimum (para 4.6):
- Explicitly state the spending proposal is a ‘grant’
- Provide information on applicable requirements including legal authority
- Outline the application and selection process including selection criteria
- Provide clear advice on the merits relative to guidelines and value with money
When briefing on specific grants, officials must (para 4.7):
- Categorise applications as fully meeting, partially meeting, or not meeting selection criteria
- Indicate which applications can be supported within available funding
- Recommend that applications not meeting any criteria be rejected
For ministers:
When approving grants, ministers must (para 4.10):
- Receive written advice from officials before approving
- Record in writing the basis for approval relative to guidelines and value with money
- Record in writing the basis for not approving any grant officials recommended
- Record in writing the basis for approving any grant officials recommended be rejected
- Declare any conflicts of interest
Ministers must also (paras 4.11-4.13):
- Report to the Finance Minister when approving grants in their own electorate (House of Representatives members)
- Report to the Finance Minister on all instances where they approved grants that officials recommended be rejected
- The Finance Minister must table these reports quarterly
For accountable authorities:
- Ensure entity fraud and corruption procedures comply with PGPA Rule section 10 (para 3.6)
- Ensure third-party arrangements are in writing and promote proper use of money (para 4.8)
- Put in place practices and procedures consistent with the nine key principles (para 6.4)
Better Practice (The “Shoulds”)
These aren’t mandatory but failure to follow them will attract scrutiny, particularly from the ANAO. They represent what a well-run program looks like.
Program design:
- Work together with stakeholders to plan, design, and undertake grants administration
- Address all relevant planning and implementation issues before commencing
- Design grant opportunities to enable closure on successful completion
- Build risk identification and engagement into grants administration processes
Assessment and selection:
- Use competitive, merit-based selection processes unless there’s documented rationale for alternatives
- Ensure decisions correspond to published guidelines and processes
- Provide feedback to unsuccessful applicants
- Document any departure from approved selection processes
Grant agreements:
- Choose agreement form based on risk analysis and proportionality
- Ensure agreements support proper use and management of money
- Monitor performance and progress proportionate to risk
Reporting and acquittal:
- Determine reporting requirements proportional to risks and outcomes sought
- Consider reducing requirements for grantees with established compliance records
- Align grant reporting with grantees’ internal reporting cycles where possible
Part 3: The ANAO's Eight Lessons.And What They Mean for You
In November 2024, the ANAO published Audit Lessons: Grants Administration, synthesising findings from 16 performance audits conducted between July 2019 and June 2024. Those audits generated 57 recommendations across 10 themes. The ANAO distilled these into eight lessons mapped to the five stages of the grants lifecycle.
This section presents those lessons alongside the failure patterns we’ve seen in major audits. The ANAO’s framework provides the structure; the case studies show what happens when programs don’t follow it.
The Eight Lessons at a Glance
| Stage | ANAO Lesson | What It Means in Practice |
|---|---|---|
| Design | 1. Develop clear grant opportunity guidelines | Guidelines are your authoritative document. If it’s not in the guidelines, don’t assess against it. |
| Design | 2. Ensure legal authority exists | Know whether you’re relying on PGPA Act s23, FFSP Act, or specific legislation before you announce anything. |
| Assessment | 3. Assess applications soundly | Assessment must be against published criteria, properly documented, with quality assurance. |
| Decision | 4. Support decision-makers with clear advice | Briefs must categorise applications, recommend rejections, and explain value with money. |
| Decision | 5. Document decisions appropriately | At the time of decision, in writing, linked to guidelines and value with money. |
| Agreement | 6. Establish appropriate grant agreements | Proportionate to risk, clear on deliverables and reporting, understood by both parties. |
| Monitoring | 7. Monitor and manage grants effectively | Ongoing oversight proportionate to risk; don’t just sign and forget. |
| Evaluation | 8. Continually monitor and review | Evaluate before extending or repeating; learn from what worked and what didn’t. |
The ANAO’s core finding: Between July 2019 and June 2024, audits regularly found entities not meeting CGRPs requirements. The same problems recur because the same lessons go unlearned.
Part 4: When Things Go Wrong. Case Studies from ANAO Audits
The CGRPs are not theoretical. The Australian National Audit Office regularly examines grant programs, and their findings show what happens when the framework isn’t followed. These aren’t hypothetical failures, they’re documented cases that ended up in parliamentary reports, question time, and ministerial resignations.
Each case study follows the same pattern: what happened, what the ANAO found, which CGRPs principles and ANAO lessons failed, and what you should do differently.
Case Study 1: Community Sport Infrastructure Program (2020)
Auditor-General Report No. 23 of 2019–20
What happened: Sport Australia assessed 2,056 applications against published criteria and provided recommendations to the Minister. The Minister’s office conducted a parallel assessment using different considerations. Of 684 grants approved, 61% had assessment scores below the cut-off that would have applied if funding had been based on assessed merit. In rounds two and three, Sport Australia played no role in determining which applications should be funded.
What the ANAO found:
- The award of grant funding was not informed by an appropriate assessment process and sound advice
- The successful applications were not those assessed as most meritorious against published guidelines
- There was no evident legal authority documented for the Minister’s approval role
- A colour-coded spreadsheet tracking party affiliations of electorates was used in the Minister’s office assessment
Which CGRPs principles failed:
- Merit-based processes (principle 5), bypassed entirely by rounds two and three
- Consistency with guidelines (principle 7), decisions didn’t correspond to published process
- Governance and accountability (principle 8), ministerial departures from recommendations weren’t properly documented
- Probity and transparency (principle 9), parallel undocumented process
Which ANAO lessons were ignored:
- Lesson 3 (assess applications soundly), parallel assessment bypassed the published process
- Lesson 4 (support decision-makers with clear advice), advice was overridden without documented basis
- Lesson 5 (document decisions appropriately), ministerial decisions weren’t properly recorded
What you should do differently: If a minister or their office wants to conduct their own assessment, that’s their prerogative, but it must be documented, linked to published criteria or other factors in the guidelines, and reported appropriately. Never run a “parallel process” that creates two different versions of merit. One process, one set of records, full documentation.
Case Study 2: Commuter Car Park Projects (2021)
Auditor-General Report No. 47 of 2020–21
What happened: The $660 million National Commuter Car Park Fund was established to encourage public transport use. By March 2021, 44 projects across 47 sites had been announced. None were proposed by the department. Projects were identified by canvassing Coalition MPs and candidates, managed through the Minister’s office. The ANAO found 83% of projects were in Coalition or targeted marginal seats. Ten proposed sites were not attached to rail stations.
What the ANAO found:
- The approach to identifying and selecting projects was “limited in coverage and was not demonstrably merit-based”
- The assessment work underlying advice to award funding was “not to an appropriate standard”
- The department’s approach “was not designed to be open or transparent”
- The distribution of projects “reflected the geographic and political profile of those given the opportunity by the government to identify candidates”
Which CGRPs principles failed:
- Robust planning and design (principle 1), no proper program design process
- Merit-based processes (principle 5), no public application process at all
- Consistency with guidelines (principle 7), no meaningful guidelines existed
- Probity and transparency (principle 9), fundamental failures
Which ANAO lessons were ignored:
- Lesson 1 (develop clear grant opportunity guidelines), guidelines were effectively absent
- Lesson 2 (ensure legal authority exists), authority questions were not addressed upfront
- Lesson 3 (assess applications soundly), there was no assessment process
What you should do differently: If you’re establishing a new program, design it properly before announcing projects. Have a clear selection methodology. If you’re not running an open competitive process, document why and ensure your approach still delivers value with relevant money. Starting with electorates rather than program objectives inverts the entire framework.
Case Study 3: Building Better Regions Fund (2022)
Auditor-General Report No. 1 of 2022–23
What happened: BBRF was the largest open competitive grants program administered by Infrastructure, with $1.15 billion awarded to 1,293 projects across five rounds. A ministerial panel made funding decisions. The guidelines allowed the panel to consider “other factors” to override merit assessment results. By round three, the panel’s written decisions made no reference to merit assessment results at all.
What the ANAO found:
- “The decisions about the award of grant funding across each of the five funding rounds were not appropriately informed by departmental advice”
- On 164 occasions, the ministerial panel rejected recommended applications without documenting reasons
- “It was common… for the approved applications to not be those assessed as best meeting the published criteria”
- Nationals-held electorates received $104 million more funding than would have occurred based on merit assessment alone
Which CGRPs principles failed:
- Merit-based processes (principle 5), systematically overridden
- Consistency with guidelines (principle 7), “other factors” overwhelmed merit criteria
- Governance and accountability (principle 8), decisions to reject recommended applications weren’t documented
- Probity and transparency (principle 9), basis for decisions unclear
Which ANAO lessons were ignored:
- Lesson 4 (support decision-makers with clear advice), advice was provided but systematically disregarded
- Lesson 5 (document decisions appropriately), rejections of recommended applications went undocumented
- Lesson 8 (continually monitor and review), problems compounded across rounds without correction
What you should do differently: If your guidelines include “other factors” that can be considered alongside merit assessment, define them precisely. Apply them consistently across applications. Document how they influenced each decision. If “other factors” become a mechanism to override merit assessment entirely, you no longer have a merit-based process — and you should redesign the program or remove the pretence.
Warning sign: If your ministerial panel routinely approves applications that weren’t recommended and rejects applications that were, without documented reasons, your program is heading for an adverse audit finding.
Case Study 4: Regional Jobs and Investment Packages (2019)
Auditor-General Report No. 12 of 2019–20
What happened: The $222 million RJIP program outsourced application assessment to a contractor through the Business Grants Hub. A ministerial panel made funding decisions. The panel didn’t approve 28% of applications that officials had recommended and instead approved 17% that hadn’t been recommended. When the panel disagreed with assessment scores, it overrode them rather than requesting re-assessment.
What the ANAO found:
- Assessment processes were “not to the standard required by the grants administration framework”
- Appropriate checks and controls were not in place for eligibility and merit assessments
- The conflict of interest framework had weaknesses
- When decision-makers disagreed with scoring, applications were not re-scored
Which CGRPs principles failed:
- Governance and accountability (principle 8), inadequate oversight of outsourced assessment
- Merit-based processes (principle 5), overridden without proper re-assessment
- Probity and transparency (principle 9), conflict of interest management inadequate
Which ANAO lessons were ignored:
- Lesson 3 (assess applications soundly), outsourced assessment lacked quality assurance
- Lesson 4 (support decision-makers with clear advice), advice was clear but overridden without re-scoring
- Lesson 7 (monitor and manage grants effectively) , third-party arrangements weren’t adequately supervised
What you should do differently: Outsourcing assessment doesn’t outsource accountability. If you use a contractor or grants hub, you need robust quality assurance. If decision-makers believe assessors got it wrong, the response is to re-assess — not to simply substitute their own judgment without documented reasons.
Common Patterns Across Failed Programs
Reading ANAO audits over time, certain patterns emerge. Watch for these warning signs in your own programs:
| Pattern | Warning Sign | What To Do |
|---|---|---|
| “Other factors” creep | Guidelines allow discretionary factors; over time, these dominate merit assessment | Define factors precisely upfront; document application to each decision |
| The documentation gap | Decisions made but reasons not recorded; records created later | Document at time of decision, not afterwards |
| Parallel processes | Minister’s office runs separate assessment alongside departmental process | One process, one set of records, documented authority |
| Outsourcing without oversight | Third party assesses; no quality assurance or verification | Build QA into contracts; verify samples; retain accountability |
| Geographic correlation | Distribution of funding aligns with electoral geography | ANAO routinely analyses this; ensure merit drives distribution |
Part 5: Practical Guidance by Role
Find your role below. These sections give you specific, actionable guidance for what the CGRPs mean in your day-to-day work.
If You Design Grant Programs
Before you start:
- Confirm you actually need a grant program (not procurement, regulation, or direct delivery)
- Understand your legal authority to spend
- Check what’s already funded in this space — by Commonwealth, states, and philanthropic funders
- Talk to potential applicants and stakeholders about what would actually work
When drafting guidelines:
- Be specific about objectives, vague objectives lead to vague assessment
- Choose your selection process deliberately and document why
- If you include “other factors,” define them precisely
- Make eligibility criteria verifiable and objective
- Design assessment criteria that actually measure what matters
- Build in proportionality from the start, don’t apply infrastructure-scale requirements to community-scale grants
- Include the draft grant agreement with the guidelines
Before you open:
- Test the guidelines with stakeholders
- Ensure your GrantConnect listing is accurate
- Brief your minister on how the program works and what their role is
- Train your assessment team
If You Assess Applications
Before assessment:
- Understand the guidelines thoroughly
- Declare any conflicts of interest
- Know what documentation you’re expected to keep
During assessment:
- Assess against the published criteria, nothing else
- Document your reasoning, not just your scores
- If you rely on information not in the application, note that
- Be consistent across applications
- Don’t let early applications set benchmarks that disadvantage later ones (or vice versa)
After assessment:
- Quality assure your work before it goes further
- Maintain records that would survive audit scrutiny
- If you disagree with moderation outcomes, document that too
If You Brief Ministers
The brief must include:
- Explicit statement that this is a grant
- Legal authority for the grant
- How the selection process worked
- Clear categorisation: fully meets criteria, partially meets, doesn’t meet
- Which applications can be supported within budget
- Your recommendation on each application
- Advice on value with relevant money
You must recommend rejection of applications that don’t meet any selection criteria. This isn’t optional. It’s paragraph 4.7(c).
If you expect the minister might depart from your recommendations:
- Explain the reporting obligations that will apply (paras 4.11–4.13)
- Remind them of documentation requirements (para 4.10)
- Be clear about which applications were assessed as most meritorious
If You’re a Minister or Ministerial Adviser
You can:
- Approve grants in your own electorate (but you must report to Finance Minister)
- Approve grants that officials didn’t recommend (but you must document reasons and report to Finance Minister)
- Consider factors beyond the merit assessment (but they should be in the guidelines and your reasons should be documented)
You must:
- Receive written advice before approving
- Record in writing the basis for your decision relative to guidelines and value with money
- Record reasons for rejecting recommended applications
- Record reasons for approving applications recommended for rejection
- Declare conflicts of interest
- Accept that your decisions will be tabled in Parliament quarterly
You should understand:
- The ANAO may audit this program
- The JCPAA may review that audit
- Your documented reasons are the record that will be examined
- Reports to the Finance Minister are tabled in Parliament quarterly
A note on discretion: Ministers have discretion. That’s the system working as designed. The CGRPs don’t prevent you from making political judgments, they require those judgments to be documented and reported. The framework assumes you will sometimes disagree with officials. It just ensures there’s a record of when and why.
If You Manage Ongoing Grants
Throughout the grant:
- Monitor progress proportionate to risk
- Maintain regular contact with grantees
- Document variations and the reasons for them
- Don’t use variations to avoid running a new process
For acquittal:
- Requirements should be proportionate to grant size and risk
- Don’t ask for information available from other sources
- Align reporting with grantees’ existing cycles where possible
For evaluation:
- Measure outcomes, not just outputs
- Use evaluation findings to improve future rounds
- Consider whether the program should continue, change, or close
Part 6: Quick Reference
The GrantConnect Requirements
| Requirement | Reference | Timing |
|---|---|---|
| Publish grant opportunity guidelines | para 5.2 | Before opening |
| Publish forecast grant opportunities (if developed) | para 5.3 | When available |
| Report grants awarded | para 5.4 | Within 21 calendar days of agreement taking effect |
| Report variations | para 5.4 | Within 21 calendar days of variation taking effect |
| Record ministerial decisions | para 5.5 | As soon as practicable |
The Documentation Checklist
For every grant decision, you should be able to produce:
☐ Published grant opportunity guidelines
☐ Application as submitted
☐ Assessment against published criteria
☐ Record of any conflicts of interest and how managed
☐ Brief to decision-maker including required elements
☐ Record of decision and basis for approval
☐ If ministerial decision departing from advice: documented reasons
☐ Grant agreement
☐ GrantConnect reporting
When Ministers Must Report to Finance Minister
| Trigger | Who Reports | Reference | Consequence |
|---|---|---|---|
| Minister approves grant in own electorate | House of Reps members only | para 4.11 | Tabled quarterly |
| Minister approves grant officials recommended be rejected | All ministers including senators | para 4.12 | Tabled quarterly |
These reports become public record. They will be examined by journalists, opposition members, and the ANAO.
The “Proper Use” Test
Under the PGPA Act, “proper” use of public resources means:
- Efficient: achieving objectives with minimum resource use
- Effective: actually achieving the intended outcomes
- Economical: avoiding waste
- Ethical: consistent with public sector values
Every grant decision should be defensible against all four elements.
Conclusion: The Point of All This
The CGRPs exist because public money matters. When grants are administered well, they achieve genuine outcomes: regional communities strengthened, research advanced, services delivered to people who need them.
When grants are administered badly, money is wasted, trust is eroded, and the people who were supposed to benefit miss out while others benefit for the wrong reasons.
The framework isn’t perfect. It gives officials and ministers significant discretion, and that discretion can be used well or badly. But the framework does establish clear expectations: decisions should be merit-based, documented, transparent, and defensible.
If you’re involved in grants administration, you’re a steward of public resources. The CGRPs tell you how to do that job properly. This guide is meant to help you understand what that actually means in practice.
Do the work. Keep the records. Make decisions you can explain and defend.
And if you’re ever asked to do something that doesn’t sit right, remember: the framework exists precisely for moments like that. It tells you what’s required, what’s permitted, and what has to be documented. That’s not bureaucracy — that’s protection. Use it.
Final smell test: If your program ended up in an ANAO audit tomorrow, would you be comfortable with what the auditors would find? If not, you know what to fix.
I’m Geoffrey Clow EGA – Expert Grant Program Advisory. I work with government agencies and philanthropic organisations on grant program design, review, and improvement. I bring practical experience from both sides of the grants relationship; as program designers and as assessors who’ve seen thousands of applications and know what works and what doesn’t.
This guide was developed to honour the work of my partner in love and business, the late Georgie Bailey, who believed that grants administration should be rigorous, fair, and free of bullshit. In loving memory 1968-2022
For more information: Contact details here
Document version: 1.0
Last updated: January 2026
Framework reference: Commonwealth Grants Rules and Principles 2024 (F2024L00854)
Also in the EGA White Paper Series
An Open Protocol for Grantmaking: The Case for Shared Design →
The same community organisation fills out three applications for the same work, in three different formats, for three departments that have never spoken to each other about how they designed their programs.
Every grant program defines outcomes differently, measures impact differently, and reports differently. The result is burden for applicants, blindness for government, and a system that cannot answer the question: across all programs funding the same population, what are we getting for the money?
Geoffrey Clow argues that Australia’s major public funders should co-design the infrastructure layer of grants, shared standards, shared outcomes frameworks, shared evidence objects, and then compete on policy priorities and delivery models on top of that layer. Not a better form. A shared operating system underneath every form.
If this paper convinced you that the machine needs redesigning, the Open Protocol paper asks what should sit underneath it.
Appendix: Key References
ANAO Performance Audits Referenced
| Report | Title | Date |
|---|---|---|
| No. 23 of 2019–20 | Award of Funding under the Community Sport Infrastructure Program | January 2020 |
| No. 12 of 2019–20 | Award of Funding Under the Regional Jobs and Investment Packages | November 2019 |
| No. 47 of 2020–21 | Administration of Commuter Car Park Projects within the Urban Congestion Fund | June 2021 |
| No. 1 of 2022–23 | Award of Funding under the Building Better Regions Fund | July 2022 |
ANAO Insights and Guidance
| Document | Description |
|---|---|
| Audit Lessons: Grants Administration (November 2024) | Eight lessons from 16 audits across the grants lifecycle |
| Key Learnings: Grants | Ongoing collection of lessons from grants audits |
All ANAO reports and guidance are available at www.anao.gov.au
Department of Finance Resources
| Resource | Purpose |
|---|---|
| CGRPs 2024 (F2024L00854) | The authoritative grants framework document |
| GrantConnect | Mandatory reporting platform for grants |
| Finance guidance and templates | Supporting documentation for CGRPs implementation |
Available at www.finance.gov.au
