Review of major ICT seller gifts and benefits to Australian Public Service employees

Overview

This report presents the results of the DTA’s ICT seller gifts and benefits data collection process for the period 1 April 2025 to 31 March 2026. The process compared data from 9 major ICT sellers with 113 entities’ published gifts and benefits registers to identify systemic gaps, omissions or inconsistencies.

The sellers in scope were AWS, IBM, Microsoft, Oracle, Rimini Street and SAP as whole-of-government providers; Salesforce and ServiceNow as model contract holders; and Data#3 as a major reseller and Microsoft’s dedicated distributor.

In aggregate, sellers reported 3,662 gifts and benefits offered to Australian Public Service (APS) / Senior Executive Service (SES) employees. Of these, 539 were accepted and 3,123 were declined.

The analysis of data collected for the reporting period found no significant divergence, systemic concern or information that would justify referring an APS/SES employee from another entity for investigation. A small number of offers would generally be unacceptable, such as sporting match tickets, but all reported cases in scope were declined.

The DTA’s findings and opportunities for improvement informed the APSC’s updated gifts and benefits guidance, expected to be released in the second half of 2026 with an implementation date of January 2027. The main impact of the work is practical: strengthening transparency, improving reporting consistency, clarifying expectations for entities, and raising awareness of buyer and seller obligations in digital and ICT procurements.

• Opportunities for improvement and next steps are up front. The DTA will continue to drive implementation through BuyICT.gov.au, targeted communication with entities and sellers, and ongoing engagement with the APSC.
• The $100 reporting threshold should be maintained. The data supports consistent public reporting above $100, while confirming that entities should manage lower value offers where risk, repetition or cumulative value warrants closer control.
• Entities should strengthen public reporting practices. Entities should publish relevant gifts and benefits policies, maintain access to current and previous registers, and clearly state who is covered by each register.
• Sellers should proactively disclose value. Sellers should state the value of gifts, benefits and hospitality when making offers to APS/SES employees so officials can make informed decisions before accepting or declining. 
• Supporting detail is in appendices. Detailed process material, data interpretation and broader analysis are included in appendices so readers can understand the result without working through lengthy background material.

Results

The DTA’s analysis produced 5 central results.

• No discrepancies of concern were identified. The DTA did not identify systemic gaps, omissions or inconsistencies that warranted further investigation.
• Most offers were declined. Across gifts and benefits valued above $100, 188 were accepted and 2,897 were declined.
• Accepted offers were mainly professional in nature. Accepted offers were mainly linked to conferences, industry events, training and other professional development activities.
• Bulk event invitations shaped the data. ServiceNow accounted for around 94% of the value of all offered gifts and benefits, reflecting its use of bulk distribution lists and frequent large conference-style events. It reported 3,153 offers, of which 148 were accepted and 3,005 were declined.
• Transparency influenced behaviour. The prospective collection process encouraged more deliberate consideration of offers by sellers and APS/SES employees.

Key findings

The findings point to a system that is generally working, but where clearer expectations and more consistent reporting would improve integrity, transparency and public confidence.

• Transparency changes behaviour. Prospective collection and scrutiny encouraged sellers and APS/SES employees to consider the appropriateness of offers before acceptance.
• Reporting practices need clearer minimum standards. Sellers and entities used different thresholds, systems and publication practices, reducing comparability and increasing manual review effort.
• Public registers require better maintenance. Some entities did not publish within expected timeframes, did not retain previous registers publicly, or did not clearly signal nil declarations.
• Shared vigilance remains essential. Sellers and buyers must continue to manage real and apparent conflicts of interest. APS employees must take reasonable steps to avoid conflicts, and sellers must declare and manage conflicts connected with Australian Government contracts and avoid bringing the government into disrepute.

Next steps

The DTA will focus next steps on practical implementation, seller behaviour and entity support. This includes:

• enhancing BuyICT.gov.au workflows with prompts reminding entities to review and update internal gifts and benefits registers during procurements in line transparency obligations, the $100 threshold for public reporting, and the risk, repetition, or cumulative impacts of gifts and benefits.
• publishing targeted BuyICT.gov.au content for entities and sellers around the offering and acceptance of gifts and benefits, including the estimated value and recording of offers, declines, and acceptances.
• maintaining engagement with the APSC on guidance and supporting resources.
• delivering engagement and education through the Digital Sourcing Network.
• requesting sellers to proactively disclose the value of gifts, benefits and hospitality when making offers to APS/SES employees through consultation, agreement, and contractual obligations.