Appendix F: International comparisons
United States of America
Key points
- Given its size, the US Government has an approach to shared services that is based on the influence and will of individuals.
- The large sellers have limited interest in helping with any change as they benefit from the current lack of transparency.
- The underpinnings to future success for the US Government to move towards a posture where it could better leverage its ICT buying power begins with:
- Better data on where money is currently being spent.
- Upgrading legacy ICT such that future ICT can provide a stable foundation on which to build shared services that deliver for the public and agencies' missions.
- Clear authority in a single person to mandate change and for this to succeed that person requires control of the money.
- The issues which did drive changed behaviour in the US Government in the last few years were cybersecurity, and in future years the shift to cloud services and artificial intelligence will continue to drive further changes in behaviour.
- The Government itself must maintain sufficient ICT expertise in its workforce in order to have the capability to validate proposals from the private sector for ICT.
- The Government needs to be prepared to invest money perhaps to the point of temporarily doubling its costs to build digital twins rather than try to cobble together improvements on top of infrastructure - in order to ultimately save money especially through automation.
Context
12.1 Created via the passage of the E-Government Act in 2002, the Federal CIO is a role within the US Government's Office of Management and Budget (OMB) in the Executive Office of the President. It has a small staff and oversees federal technology spending, IT strategy, cyber security and digital transformation to enhance public services and operational efficiency. It has jurisdiction of around 430 departments and agencies and until recently used specialised funds to incentivise desired behaviour from entities against its priorities. Such funds are tailored for ICT modernisation and uplift of services to the public.
12.2 Each department and agency is responsible for its own procurement. Progress against the Federal CIO’s priorities is monitored by the CIO Council which establishes standards against which the success of individual agencies' programs are measured which include optimising Federal Government information resources and investments.
12.3 Other US Government entities also play a role in overseeing procurement:
- The US General Services Administration provides centralised procurement for the US federal government. It has four main roles including “Digital government: A digital government that delivers for the public through trusted, accessible, and user-centred technologies”.
- The US Digital Service was created in 2014 as a technology unit within the OMB. In January 2025 it was renamed as the United States Department Of Government Efficiency (DOGE), although the USDS still exists. Its focus is to promote the use of digital services and improve government websites.
- The Office of Federal Procurement Policy was created by Congress in 1974 and sits within the OMB. Its role is to ensure the efficiency and effectiveness of government procurement.
Key differences
12.4 Given its size, the US Government has an approach which is based on the influence and power of individuals and is completely decentralised. The large departments such as the Departments of Defense, Treasury, Agriculture and Transport can use their size to leverage discounts from sellers, but smaller entities do not get access to these. This can mean there is enormous inequity in costs paid for products and services. Thus the large sellers have limited interest in helping to drive change as they greatly benefit from the current lack of transparency and coordination.
12.5 There is limited meaningful aggregated data on where the US Government is spending its money on ICT products and services. Data collected relies on self-reporting often from personnel without the requisite skills or knowledge. While some progress has been made over recent years, the true knowledge probably sits with the large sellers who have no commercial interest in assisting with transparency.
12.6 The US started the Better Contracting Initiative to meet with sellers and start strategic partnering conversations, however this often ended up being a mechanism for the sellers to gain insight into the US Government’s strategies to use for commercial advantage.
Commonalities with Australia
12.7 Companies like Microsoft are typically engaged through a reseller and the reseller is responsible for landing the Microsoft capability in the agency and supporting implementation. Again, large entities have the capability and capacity to negotiate with resellers, but getting this expertise into smaller agencies is problematic.
12.8 Similar to the Small and Medium Entity procurement pathways introduced by the Australian Government (e.g. the SME exemption within the Commonwealth Procurement Rules), the US has the Small Business Development Program to help small, disadvantaged businesses compete for federal contracts through certification, offering access to sole-source and competitive set-aside contracts, business development assistance, and other benefits.
What better looks like for the US – according to our interlocutor
12.9 The underpinnings to future success for the US Government to move towards a posture where it could better leverage its technology buying power begins with:
- Better data on where money is currently being spent. The Current Federal CIO, Gregory Barbaccia, called for all agencies to inventory licences they have with Microsoft, Adobe, Salesforce, Oracle and ServiceNow by 2 April with a view to save costs and take advantage of economies of scale for software purchases. This inventory will be extended to all software by 30 April.
- Upgrading legacy ICT such that future ICT can provide a stable foundation on which to build shared services that deliver for the public and agencies' missions.
- Clear authority in a single person to mandate change and for this to succeed that person requires control of the money.
12.10 The issues which did drive changed behaviour in the US Government in the last few years were cybersecurity, and in future years the shift to cloud services and artificial intelligence. These were viewed as platforms which can be leveraged to hasten change.
12.11 The US Government itself must maintain sufficient ICT expertise in its workforce in order to have the capability to validate proposals from the private sector for ICT.
12.12 The US Government needs to be prepared to invest money perhaps to the point of temporarily doubling its costs to build digital twins rather than try to cobble together improvements on top of infrastructure - in order to ultimately save money especially through automation.
United Kingdom
Key points
- The Central Digital and Data Office (CDDO) and Government Digital Service (GDS) drive digital performance, both are housed within the UK Cabinet Office.
- The Shared Services Strategy (launched in March 2021) aims to improve efficiency by consolidating 286 departmental systems into five shared service centres, each using a separate Enterprise Resource Planning (ERP) system. Clusters of like-agencies were formed which considered factors such as technology, scale, complexity, service needs, and historic investments.
- The Chief Procurement Officer role was established in April 2012 with the role later being re-named Government Chief Commercial Officer (GCCO) to reflect an expanded scope of responsibilities. Since its inception, the GCCO role has been pivotal in driving commercial and improving procurement practices within the UK Government.
- The Government Commercial Function (GCF), formally established in 2015, incorporates ~6,000 procurement specialists across departments, supported by a Cabinet Office central team. In recent years it has been responsible for implementing the new UK Procurement Act 2023.
- The UK has centralised functions which focus on digital transformation, shared services, and efficiency, similar to Australian governance structures. These functions are not legislated but derive authority from Westminster system governance.
Context
12.13 Responsibility for improving the UK Government’s digital performance rests with the Central Digital and Data Office (CDDO) and the Government Digital Service (GDS), which are both part of the Cabinet Office. The CDDO, created in 2021, leads the digital, data and technology function of government and is responsible for strategy, standards, and capability development. The GDS, created in 2025, has refocused its role on building products and services that help provide a simple, joined-up and personalised experience of government to the public. However, individual departments are responsible for the day-to-day delivery of their own programmes.
12.14 The extant Shared Services Strategy was launched in March 2021 by the Cabinet Office. The Strategy is focused on creating efficiencies by replacing 286 departmental systems with 5 ERP systems clustered through five shared service centres. The clusters were determined by factors such as existing relationships and departmental characteristics such as technology, size, scale, complexity, service requirements and historic and current investments. The Public Accounts Committee (PAC) reported in 2023 that the 2021 Strategy was underfunded blaming the Cabinet Office for failing to make a proper business case whilst also acknowledging that the Strategy was still on course to save £1.8bn over the next 15 years through modernising back-office systems and moving to cloud-based technology and standardising processes and data. The PAC also reported that the clusters had forecast that they would need an additional £480m of investment after 2024-25 to deliver the full Strategy.
12.15 The position of Chief Commercial Officer (CCO), formerly Chief Procurement Officer is responsible for implementing the UK Procurement Act 2023 which came into force in February 2025. The Act aims to:
- Simplify the bidding processes including a new ‘competitive flexible’ procedure.
- Make commercial frameworks more open, so prospective sellers are not shut out for long periods of time.
- Remove bureaucratic barriers for smaller businesses and voluntary, community and social enterprises so they can compete for more contracts - with strengthened provisions for prompt payment.
- Require public bodies to provide consistent, publicly available, feedback for sellers: a requirement on public bodies to provide bid assessments for final tenders.
12.16 The CCO in the Cabinet Office oversees the Government Commercial Function (GCF) which was formed in 2015 and incorporates around 6,000 people working in commercial roles across the UK Government. In this decentralised model, the commercial teams in departments are supported by a central team, including the Crown Commercial Services within the GCF, providing cross-cutting functional coordination support, as well as specialist services and expert advice on complex transactions, key sellers and market stewardship. This helps to ensure that the Government can effectively leverage its significant scale, benefit from greater efficiency and drive improved value for money from its sellers and the wider supply chain. The Crown Commercial Services have framework agreements, dynamic agreements and strategic memorandums of understanding with companies such as HP, IBM, AWS, ServiceNow and Cisco. Companies such as Microsoft often provide services to government through value added resellers. (A full list of these suppliers is available.) Government departments tend to use central frameworks and rather than run tender process for the following reasons: efficiency and speed, accessing discounts, legal compliance, quality assurance, risk management, HMG Policy Alignment. The GCF also provide Playbooks to guide policy and practice for sourcing and procurement and offer skilling and training in these areas for the rest of government.
12.17 In March 2025 the UK Government announced a £3.25bn Transformation Fund to boost government efficiency and invest in digital and emerging technology such as AI. Some reductions on civil service staff have been made already in the expectation that investment in technology can make the provision of services more efficient.
Key differences
12.18 The UK Government has been working towards improving government efficiency through shared services and centralised procurement arrangements for over 15 years. Whilst success has been mixed and slow, some savings have been achieved and the buying power of the UK Government has been leveraged – particularly around so-called back office functions such as finance, HR etc as they continue to move toward 5 shared service centres. The UK is at an inflection point and this year has strengthened governance of procurement in the Cabinet Office and recognised that the next stage of realising more savings will take concurrent financial investment to take advantage of modern ICT.
Commonalities
12.19 The UK has centralised functions with accountability for driving improved digital transformation, shared services and efficiencies within the Cabinet Office. Like Australia, it has had these functions in some form for many years. These functions are not legislated and are given effect to by the power and governance at the centre of a Westminster system.
What better looks like for the UK – according to our interlocutor
12.20 The UK is improving its ability to share and learn from historical failures – the decade long journey of one ERP process was provided as an example, where the technology was adapted to the business process of individual agencies thus creating bespoke systems with limited interoperability. The UK Intelligence Community (UKIC) has become an exemplar for what may be possible in the broader government, and this has taken time and strong and united leadership to achieve whereby now one team in the UKIC enters into contracts on behalf of the whole UKIC.
Canada
Key points
- Achieving shared services remains hard, and a strong and clear central legal mandate is imperative along with clarity on the role of departments and agencies receiving the service.
- Whilst shared services can create significant savings these take far longer to be realised than expected.
- Negotiating power can be realised through sheer scale of requirements.
- Ensuring competition, reliability, self-reliance, and diversity is a challenge with these often operating in tension.
- Improved cybersecurity has been a significant driver towards shared or common services.
- Interoperability has also been a driver towards shared or common services.
- In the current geostrategic context, self-reliance, data sovereignty and cybersecurity are a high priority.
Context
12.21 Following a 2010 Budget Review of government administrative functions, Shared Services Canada (SSC) was created on 4 August 2011 and reports to Parliament through the Minister of Public Services and Procurement Canada. With its formation, SSC initially brought together 5,000 IT positions and resources from 42 departments with a mandate to provide email, data centres and network services. At its stand up, its budget was cut by CAN$500m per year, which in hindsight gave the organisation a challenging start.
12.22 On 1 April 2012, SSC became an independently functioning department in terms of its governance and financial responsibilities.
12.23 SCC centrally delivers email, data centres and networks to the Canadian Government. End user devices and applications are the responsibility of individual departments and agencies.
12.24 The Canadian Security and Intelligence Service and the Communications Security Establishment are the only fully optional clients that are not obligated to use the bulk of SSC’s services (they are however required to use SSC’s purchasing vehicles for certain items). SSC also provides services to border, defence and law enforcement; the sole exemption is for dedicated mobile communications (for example deployed equipment with the Canadian Armed Forces) and SSC also provides technology support to border posts and Royal Canadian Mounted Police detachments. SSC maintains a high threshold for gaining an exception to its enterprise standard, this threshold was lower at the stand up of the SSC and has been addressed since whereby all exceptions are done openly through an enterprise architecture review board.
12.25 SSC is responsible for setting up IT contracts, standing offers and supply arrangements for the Government of Canada. SSC has a role to ensure only trusted equipment and software are used. In practice, this has meant that departments with delegated authority can buy IT goods from SSC’s national master standing offers, such as printers, scanners, toner and other IT peripherals and components, such as keyboards, USB keys and computer mouses. However some goods are excluded in order to leverage volume discounts and ensure the ‘best value to Canadians’. These include: docking stations, monitors, desktops, notebooks, tablets and thin clients.
12.26 The SSC’s Centre of Expertise in Agile and Innovative Procurement was established in 2019 and focuses on removing barriers to entry to complex government RFT processes for organisations not large enough to contend with them. It uses the well documented agile method of incubation, encouraging innovation and solution finding. Its ScaleUP program, launched in 2021, targets micro and small businesses especially those led by minorities essentially by setting aside procurement opportunities that SSC judges can be addressed by those groups.
12.27 SSC also have a program that gives favour to sellers who can demonstrate energy efficient or ‘green’ initiatives.
12.28 Through the consolidation of goods and services contracts, leveraging better pricing and reducing duplication, SSC claims to save $209 million annually in overall IT expenditure.
12.29 SSC is also bringing centralised services support to government organisations, applying industry standards for service delivery and enabling more effective, efficient and cost-effective practices. For example:
- SSC has put in place a comprehensive Service Management Strategy for the delivery and servicing of IT infrastructure running government systems as a complement to its Information Technology Infrastructure Plan.
- Has a Customer Satisfaction Feedback Initiative to identify areas where service delivery needs to be improved.
- Established an on-line IT Service Catalogue for government departments and agencies to obtain information about, and to order, enterprise services such as email, mobile technology and workplace technology devices, thereby enabling those organisations to better deliver programs and services to Canadians.
- Set in place Service Level Expectations for priority IT services such as email, mobile devices and videoconferencing.
- SSC also has in place an electronic system to manage procurement-to-payment processes, including a seller self-service portal that will help to streamline the delivery of enterprise IT services.
Key differences
12.30 SSC is a service delivery agency. It oversees an array of single seller arrangements. Whilst progress has been slow since its stand up in 2011, some significant cost savings are now being realised along with cost avoidance and improved negotiating power given the scale of the Government of Canada‘s buying capacity. In some cases, cost efficiencies have also been achieved because of improved technology.
12.31 SSC continues to need to build credibility and reliability in its reputation among government despite having a clear mandate in legislation. Whilst it supports 3,800 locations around Canada, when only one has a service problem due to an unavoidable incident this impacts the agency’s reputation. The reputational challenge is also a consequence of the agency’s original stand-up where 5,800 staff were transferred to SSC but not moved from their physical locations. This meant that people stayed in their own locations but Shared Services Canada was given all of the money. Other legacy challenges such as an early failure to deliver a one email system for the Government still contribute to today’s reputational challenges.
Commonalities
12.32 Managing competition remains challenging for SSC and they are working to change the current models of procurement to ensure that companies do not become entrenched in monopolies.
12.33 There are several different models used by SSC for central procurement.
12.34 Small items such as laptops and mobile phones are bought under arrangements where an amount is negotiated per item without a commitment for how many items might be bought over time.
12.35 SSC is moving to a ‘Platform As A Service’ model where it provides an application as a service allowing individual departments to avoid the implementation cost and simply pay for consumption. Take up of this service is voluntary but SSC runs the data centre so most departments and agencies do not want the cost of running their own.
12.36 SSC has other initiatives to manage competition. They are moving to a model where SSC negotiate a five-year initial term then annually afterwards. This means that if the Government wishes to move sellers, it has five years to get off a product and the seller has equal warning. SSC are also implementing an approach whereby they do not allow an actual single seller arrangement but instead either have a two-seller arrangement or a two plus one seller arrangement. The latter being where two major sellers are providing services and one small seller provides the same service.
12.37 The challenges of multiple seller arrangements are that SSC has to have teams with the skills to support multiple products. It also means that it has less buying power when negotiating with one seller because it is buying half the service or product.
12.38 Legacy ICT remains a challenge and SSC is looking at ways they may be able to move agencies faster off legacy ICT as allowing them to move slowly has proven to be more expensive. It also means that SSC is carrying unhealthy application layer capabilities that are still managed by individual agencies on its infrastructure which creates risk.
12.39 Interoperability remains a challenge and SSC provided the example of cloud services where they are moving some data back into private clouds so that they have better control of that data from a security and privacy point of view but also as part of recognising that data is critical to the Government of Canada‘s operations. The example provided was HR data. Negotiations with cloud providers is challenging given that those clouds are deliberately not interoperable hence the move to increase private clouds.
What better looks like for Canada – according to our interlocutor
12.40 Looking forward, Canada is thinking carefully about the future move from data sovereignty to digital sovereignty. This is a reflection of challenges in technology supply chains, including as experienced during the COVID-19 pandemic and more recently the rise of geopolitical tensions.
12.41 SSC expects the next generation of savings will be to remove duplication of effort in individual departments and using contract negotiations to remove locked-in monopolies.
12.42 SSC expects to increase the use of pre-commitments when negotiating contracts. It uses these to get good discounts with big sellers. The Treasury has concerns about this approach because the Government is committing to expenditure against future revenue but is starting to appreciate the savings that can be realised by using pre-commitments in negotiations.
12.43 SSC is also reviewing its approach to commodities among its various procurement models including on how to encourage the private sector to bring more innovation to the process.
12.44 SSC also negotiates such that it only pays when it starts to consume services and expects this to continue to be a useful lever in the future.
New Zealand
Key points
- Given their relative size, soft influence and strong coordination by the Chief Digital Officer has realised benefits for NZ.
- The Chief Digital Officer having greater control over ICT spending in the future is being explored.
- Cloud migration has been slower than hoped.
- New Zealand uses a range of models to leverage the buying power of the NZ Government including SSA.
Context
12.45 The Government Chief Digital Officer sits within the NZ Department of Internal Affairs and Chief Digital Officer. Following the 2022 Election, the Digital Investment Office was stood up within the GCDO to increase its influence over public sector digital investments as articulated in the policy document the Digital Investment Mandate. The GCDO reports to the Minister for Digitising Government.
12.46 The GCDO is responsible for setting digital policy and standards; improving investments; establishing and managing services; developing capability and system assurance (assuring digital government outcomes).
12.47 The GCDO’s mandate applies to all Public and non-Public Service departments as well as major Crown agents. Other public sector agencies are also participating in many of the initiatives GCDO is leading.
12.48 The GCDO is designated as a system leader under the Public Service Act 2020 to ‘coordinate best practice in a particular subject matter area’ by the Public Service Commissioner. The details of their mandate in policy is to further centralise the digital government function, and take a whole of public service approach to strategic planning and investment in digital technology.
12.49 One of the main areas of work is for the GCDO and DIO is to streamline common ICT procurement processes. There are two goals for this line of work:
- Simplify agency procurement and security assurance processes for everything from web development to software purchases, telecommunications and identity services.
- Reduce the costs and the time involved in procurement processes for agencies.
12.50 All six of Australia’s SSAs are on this list, except for IBM.
12.51 The GCDO also has in place a programme for what it calls a Common Capability ICT, defined as any technology that can be used by one or more agencies, or across all-of-government, to support business outcomes. Under this model, the lead agency takes responsibility for procurement and contract maintenance, allowing other agencies to focus on service delivery. The idea is to use the scale of government as a single customer. It allows agencies to share ICT investment, pool resources and move to shared standards.
12.52 The Infrastructure as a Service and Telecommunications as a Service Common Capability agreements will expire in 2026 and will be replaced by the Common Capabilities Cloud Programme as part of NZ’s cloud first policy.
Key differences
12.53 The GCDO does not sit in the Finance Portfolio and therefore does not have direct control of financial levers which might drive new behaviours among agencies. Whilst they are a recognised ‘system leader’ under the Public Service Act, this does not give them any particular legislative mandate and they rely on declared strategies, useful services, cabinet authority and the will of Ministers and Government leadership to comply.
12.54 Given their smaller size, the NZ Government has achieved significant progress in the last decade on streamlining and harmonising services to NZ citizens. They have had a cloud first policy in place since 2012 and have 40% of all agencies now on the cloud, in part highlighting the extensive timeframes required to replace or relocate core technology assets. They have also achieved digitisation of almost all agencies’ services to the public.
Commonalities
12.55 New Zealand’s arrangements are very similar to Australia’s. They currently have three layers of how companies can engage with the NZ Government.
12.56 The first layer is the current Common Capability Agreements where the GCDO issue Requests For Proposals (RFPs) to create a standard contract and service level agreements for a range of services. There are currently two of these Agreements, one for telecommunications including mobiles, Wi-Fi access and helpdesk support. The second Agreement is for infrastructure as a service which provides compute power and managed service providers.
12.57 The second layer is panels which are similar to how the Australian Government creates panels for agencies to draw from. In the NZ case, the GCDO has completed the primary procurement processes including due diligence, proof of ownership, terms and conditions and security checks such that agencies can do the secondary procurement process.
12.58 The third layer is creation of a marketplace which is a work in progress for New Zealand, where they hope to achieve smaller panels that are opened more regularly for competition to increase innovation and competitive tension.
12.59 NZ does have a number of single seller arrangements. Microsoft is one which they have in common with Australia having signed a whole of government deal in August 2024. This has standardised pricing and contracts for Microsoft services such as O365 and Azure. Agencies can then have a supplementary agreement for any bespoke requirements. The benefit NZ advised they have achieved is principally that the agency has clarity on rates and those rates stay unchanged for three years. Similar arrangements are in place for cloud providers which currently include: AWS, Google and Datacom. There are SSAs for Software as a Service and Platform as a Service with Oracle, SAP and TechnologyOne, and for Enterprise Resource Planning (ERP) arrangements including with Workday.
What better looks like for NZ – according to our interlocutor
12.60 Looking forward, the New Zealand government is considering how it might improve their arrangements including issues such as:
- The nature of public digital infrastructure.
- How to move from the already digitised services from agencies which are operating in silos to a federated model.
- How to build common government infrastructure such as a payment system, government Apps and common digital ID and credentials.
12.61 The GCDO is considering the benefit of controlling the appropriation of budget to agencies for digital investments, similar to the model the DTA has with the Investment Oversight Framework and the soon to be introduced Digital Investment Plans. This was emphasised in the example that New Zealand has had a cloud first policy since 2012 and that 40% of all agencies are already on the cloud but the goal to moving to 60% has become extended due to the challenges of Capex and Opex rules within the New Zealand government funding arrangements.
Others
World Economic Forum
12.62 In the context of its November 2024 White Paper on Shared Commitments in a Blended reality, the World Economic Forum (WEF) notes that open standards and shared global services and operations have been vital to the underpinnings of a robust and largely open internet. The WEF publishes on these issues at a high principles level and does not address more tactical issues of single seller arrangements of shared services as used by governments.
Organisation for Economic Co-operation and Development (OECD)
12.63 The OECD has from time to time written about shared services. Notably in 2021 it published a paper in the OECD Journal on Budgeting, Volume 2021 Issue 2 in which an Oxford scholar investigated the implementation of the UK Government’s shared services to date. The conclusions were that over the five year period of the study, there were no quick wins, that this was a long-term strategy where difficult trade-offs of the advantages of collective endeavour had to be managed by minimising downsides and managing a sense of a loss of control sometimes impacting the high functioning of often smaller agencies.