Is Your PALM Business Ready for 30 June?

As the end of the financial year approaches, PALM Scheme employers should be reviewing more than payroll and budgets.

A key compliance requirement coming into focus is the obligation for all Approved Employers to have a Fraud Control Plan in place by 30 June 2026.

While many employers have strong operational systems already in place, the requirement highlights an important shift in expectations around governance, risk management and accountability within the PALM Scheme.

The question is not whether your business is at risk of fraud or corruption. The question is whether you have considered where those risks exist and documented how they will be managed.

What is a Fraud Control Plan?

A Fraud Control Plan is a documented framework that outlines how your business identifies, prevents, detects and responds to fraud and corruption risks.

The PALM Scheme Guidelines require Approved Employers to take reasonable steps to prevent fraud against the Commonwealth and maintain a plan that identifies risks, outlines controls and explains how those controls will be monitored and reviewed.

Importantly, the size and complexity of the plan should reflect the size and nature of your business. A small horticultural business will not require the same level of documentation as a large labour hire provider, but every Approved Employer must be able to demonstrate that they have considered their risks and implemented appropriate controls.

Why Does This Matter?

For many employers, compliance obligations can feel like another administrative task.

However, a well-developed Fraud Control Plan is really about protecting your business.

Strong controls can help reduce the likelihood of:

• Incorrect worker deductions

• Payroll discrepancies

• Conflicts of interest

• Unauthorised recruitment activity

• Inaccurate reporting

• Misuse of company resources

• Poor record keeping practices

More importantly, they create consistency across your workforce systems and provide confidence that your business is meeting its obligations under the PALM Scheme.

What Does DEWR Require?

Under the PALM Scheme Guidelines, employers must have a Fraud Control Plan that addresses several key areas.

Risk Summary

Employers should identify and document fraud and corruption risks relevant to their operations.

For agricultural and horticultural businesses, this may include risks associated with worker deductions, payroll processing, recruitment activities, accommodation arrangements or financial approvals.

Treatment Strategies

For each identified risk, employers should outline the controls and mitigation strategies in place to reduce the likelihood of an issue occurring.

Examples may include:

• Approval processes

• Financial controls

• Payroll reconciliation procedures

• Recruitment documentation requirements

• Segregation of duties

  
  

Implementation Approach

A plan should explain how controls are implemented and maintained within the organisation.

This includes ensuring staff understand their responsibilities and follow consistent processes.

Compliance Strategies

Employers should identify how they will ensure ongoing compliance with PALM Scheme obligations, including where host organisations or service providers are involved.

Incident Reporting

A documented process should be in place for identifying, recording and reporting suspected fraud or corruption incidents.

Monitoring and Review

Employers are required to review their Fraud Control Plan annually and whenever there is a significant change to business operations, organisational structure or following a fraud or corruption incident.

Detection and Response Protocols

Businesses should have clear procedures for investigating concerns, taking corrective action and responding appropriately when issues are identified.

Awareness and Training

Employers should ensure personnel understand what fraud and corruption may look like, how concerns can be raised and their responsibilities in maintaining compliance.

Common Risks for PALM Employers

The operational guidance released by DEWR provides practical examples of risks that employers should consider.

Examples include:

• Non-compliant worker deductions

• Undeclared conflicts of interest

• Recruitment decisions influenced by personal relationships

• Inadequate oversight of payroll and worker charges

• Poor documentation of approvals and decisions

While every business is different, these examples provide a useful starting point when reviewing existing systems and processes.

Do Employers Need to Submit Their Plan?

Not routinely.

However, employers must provide their Fraud Control Plan to DEWR if:

• There is a significant change to the structure or activities of the organisation

• A fraud or corruption incident occurs

• DEWR specifically directs the employer to provide it

Where DEWR requires changes to the plan, employers must implement those changes within the required timeframe.

Practical Questions to Ask Before 30 June

Before the deadline, consider the following:

✓ Do we have a documented Fraud Control Plan?

✓ Have we identified fraud and corruption risks relevant to our business?

✓ Are financial approvals clearly documented?

✓ Are recruitment decisions transparent and supported by records?

✓ Are payroll and worker deductions regularly reviewed?

✓ Do staff understand their responsibilities?

✓ Is there a documented process for reporting concerns?

If you are uncertain about any of these questions, it may be time to review your systems.

Compliance is About Building Better Systems

The strongest businesses are rarely those with the most paperwork. They are the businesses with practical systems, clear responsibilities and processes that are consistently followed.

A Fraud Control Plan should not be viewed as a compliance burden. It is an opportunity to strengthen governance; reduce risk and ensure your business is well positioned for continued participation in the PALM Scheme.

Need assistance reviewing your workforce and compliance systems?

Western Advisory Co works with regional employers across agriculture and horticulture to strengthen workforce systems, improve compliance frameworks and support practical risk management outcomes.

If you're reviewing your PALM Scheme obligations or preparing for future growth, we'd be happy to discuss how we can help.