Ethical Supplier Threshold: Retired, What Replaced It
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QueenslandEthical Supply Chains

Ethical Supplier Threshold: retired, and what applies now

Queensland's Ethical Supplier Threshold no longer applies to new procurement. If you still see it in old templates, here is what it was, and what replaced the wider ethical supplier regime from 1 January 2026.

The Obligation
Retired
Ended 31 December 2025
EvidenceSupplier Code of Conduct records now
DeadlineNo longer due
OwnerFormerly the Queensland Government. Successor arrangements are run by the Queensland Government Procurement Assurance Branch
Retired. It ended on 31 December 2025 and has no direct equivalent in the Queensland Procurement Policy 2026, which took effect on 1 January 2026.

What is the Ethical Supplier Threshold?

The Ethical Supplier Threshold was a Queensland Government requirement that suppliers declare they had not breached workplace laws, such as underpaying staff or sham contracting. It ended on 31 December 2025. The Queensland Procurement Policy 2026 does not use the Threshold. Suppliers now warrant that they adhere to the Supplier Code of Conduct 2026, which includes complying with workplace laws, and a Procurement Assurance Model applies.

1 August 2019
Date the Threshold started applying
31 December 2025
Date the Threshold ceased
1 January 2026
Queensland Procurement Policy 2026 commenced
1 January 2027
Procurement Assurance Model incentive scheme starts
Who It Applies To

New Queensland Procurement

The Threshold no longer applies. Invitation and contract documents no longer need its declarations and conditions.

Who It Covered

From 1 August 2019 it applied to suppliers engaged by budget sector agencies, statutory bodies, government owned corporations and special purpose vehicles.

Contracts Signed Before 2026

The 2019 guideline required contracts to include an obligation to comply with the Threshold during the term. We could not confirm how those existing clauses are treated now, so read your own contract and ask the agency.

What the Ethical Supplier Threshold asked for.

Workplace Law
Retired
Suppliers were not to have contravened set civil remedy provisions of the Fair Work Act or Queensland's Industrial Relations Act, or committed offences against them.
Wages And Super
Retired
No wages below the modern award and no failure to make superannuation contributions.
Sham Contracting
Retired
No treating employees as independent contractors, or requiring them to get an ABN to do so.
Unpaid Work And Labour Hire
Retired
No unpaid trials or internships where the person should be an employee, and no unlicensed labour hire.
Tender Declaration
Retired
A mandatory criterion, covering the previous five years but not retrospective before 1 August 2019.
Evidence To Keep
  • Copy Of Your Existing Contract Terms
  • Any Threshold Declarations Previously Given
  • Workplace And Payroll Records For Past Contracts
  • Current Supplier Code Of Conduct Commitments
  • Trade Partner Compliance Records
Where Teams Get Caught

Copying Old Tender Templates

Declarations on this Threshold are no longer needed in new Queensland invitation and contract documents. Teams that reuse older response schedules can end up answering, or asking trade partners (subcontractors) to answer, for a test that has ended.

Assuming Ethics Checks Have Stopped

The policy has changed, not gone away. Queensland says it deals only with ethical suppliers, and a request for records under the Supplier Code of Conduct that is not met can bring consequences under the Procurement Assurance Model.

Confusing It With Other Governments' Rules

The term Ethical Supplier Threshold is a Queensland one. Commonwealth and other state rules on ethical suppliers are separate instruments with their own terms, so do not read this one into them.

In Catchment

Keeping the record for the Ethical Supplier Threshold.

No Ready-Made Template

GovAssure

Catchment has no built-in framework for this Threshold, and because it has ended it would not make sense to add one. If an older contract still carries the clause, set it up as your own framework in the Policies & Frameworks library.

Old Declarations On Record

GovAssure

Declarations given under the Threshold, and the contract clauses that carried them, can sit in the Document Register with revisions, so you can find what you said and when if a past contract is ever queried.

Trade Partner Evidence Going Forward

GovAssure

A package-level annual Document or Form requirement in your own framework can collect workplace compliance statements from each work package. You choose what it asks, so it can follow the Supplier Code of Conduct terms in your contract.

Answering A Records Request

GovAssure

A Register plus filed documents gives you one place to pull records from if the Procurement Assurance Branch asks. Catchment does not assess your compliance or check anything with a regulator.

Set Up As Your Own Framework
Ethical Supplier Threshold

Catchment has no ready-made template for this one. You build it in the Policies & Frameworks library, then adopt it on each project.

Ethical Supplier Threshold questions.

Is the Ethical Supplier Threshold still in force?

No. It ceased to be in effect on 31 December 2025. Threshold declarations are no longer used in new documents, but tenderers must still warrant that they adhere to the Supplier Code of Conduct 2026, which covers workplace laws.

What replaced the Ethical Supplier Threshold?

Nothing replaced it directly. The separate Ethical Supplier Mandate moved to the Procurement Assurance Model on 1 January 2026, and the Queensland Government Supplier Code of Conduct 2026 sets the expected behaviour. Together they now do the ethical supplier work.

What did the Ethical Supplier Threshold require?

Suppliers had to state they had not breached set Fair Work Act or Industrial Relations Act provisions, failed to pay superannuation, used sham contracting, used unpaid work trials or interns wrongly, used unlicensed labour hire, or paid below the modern award. A yes made the offer non-conforming.

What is the difference between the Ethical Supplier Threshold and Ethical Supplier Mandate?

Both were Queensland measures. The Threshold was a tender and contract test about workplace law conduct. The Mandate relied on mandatory contract clauses with penalties for serious breaches. The Mandate moved to the Procurement Assurance Model, while the Threshold was removed.

Is the Ethical Supplier Threshold part of the Commonwealth Procurement Rules?

No. It came from the Queensland Procurement Policy. We found no Commonwealth or Victorian instrument with this name, so check those governments' own rules separately.

What is the Procurement Assurance Model?

It is Part 3 of the Queensland Procurement Policy 2026. It combines an incentive scheme, capability building and accountability, and aims to make sure suppliers meet the Supplier Code of Conduct. The incentive scheme starts on 1 January 2027 and the rest applied from 1 January 2026.

Connected Obligations
Fair Jobs CodeVIC (Ethical Supply Chains)ACT Secure Local Jobs CodeACT (Ethical Supply Chains)Modern Slavery ActNational (Ethical Supply Chains)Queensland Building and Construction Training PolicyQLD (Skills & Training)
Sources
  1. Guidelines: Ethical Supplier Threshold (v1.0, July 2019) (Office of the Chief Advisor - Procurement, Queensland Department of Housing and Public Works)
  2. Queensland Procurement Policy 2026 (Version 1.1, 11 November 2025) (State of Queensland (Department of Housing and Public Works))
  3. Preparing for the refreshed Queensland Procurement Policy 2026 (Ashurst Perkins Coie)
  4. Queensland Procurement Policy 2026: What you need to know (MinterEllison)
  5. Procurement Assurance Model Framework resource (Queensland Government (For Government))
  6. Procurement Assurance Model (formerly Ethical supplier requirements) (Queensland Government (Business Queensland))
  7. Supplier Code of Conduct 2026 (Queensland Government)

Reviewed 5 November 2026. General information to help you plan reporting, not legal advice. Policies change, so check the current version with the policy owner before you rely on it.

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