At a glance
| Item | Finding |
|---|---|
| Body | Australian Health Practitioner Regulation Agency (Ahpra), with the 15 National Boards it supports |
| Type | A regulator. Ahpra is the administrative agency; the National Boards make registration and notification decisions. Together they run the National Registration and Accreditation Scheme for 16 health professions |
| Enabling law | Health Practitioner Regulation National Law, as in force in each state and territory (text used: Schedule to the Health Practitioner Regulation National Law Act 2009 (Qld), current as at 10 April 2026) |
| Where it handles complaints | All states and territories except NSW (where the Health Care Complaints Commission and the NSW Councils deal with conduct). In Queensland it deals only with matters the Office of the Health Ombudsman refers to it |
| Report under review | Annual Report 2024/25 (tabled November 2025; the 2025/26 report had not been published at 11 October 2026) |
| Record examined | 16 annual reports, 2009/10 to 2024/25; quarterly performance reports to December 2024; Regulatory Performance Committee annual report 2024/25; the National Law; Ahpra's website and 192 media releases (July 2024 to October 2026); National Health Practitioner Ombudsman annual reports 2018/19 to 2024/25; Senate inquiries (2017, 2022); five independent reviews; Health Ministers' response (May 2026); three Supreme Court judgments; ABC and other reporting |
| Money and staff, 2024/25 | Total expenses $362.4m; 1,449 full-time equivalent staff at 30 June 2025 (AR 2024/25 pp 94, 99) |
| Registered practitioners | 959,838 at 30 June 2025 (AR 2024/25 p 52) |
| Proposed overall grade | D |
| Short reason | Registration works. The notification system, which is how the public meets the regulator, does not perform to the standard the law sets. On Ahpra's own figures, 91.5% of notifications closed in 2024/25 ended with no further regulatory action, the number ending in any regulatory action fell by about 28% in a year, open notifications rose 26.7% and matters older than 12 months rose 30.7%. Timeliness has been criticised by a Senate committee (2017), a second Senate committee (2022), an independent review (2025) and Health Ministers (2026). Ahpra has stopped publishing several measures that would show whether this is improving, including its quarterly performance reports after December 2024 |
The grade follows the six criteria settled for Regulator Review on 11 October 2026. Section 11 sets out each criterion, its grade and the reasoning.
1. What the body is for
1.1 What the Law says
The National Law has a statement of objectives and, since the 2022 amendments, a paramount principle.
- The objectives include "to provide for the protection of the public by ensuring that only health practitioners who are suitably trained and qualified to practise in a competent and ethical manner are registered" (s 3(2)(a)), workforce mobility (s 3(2)(b)) and "the rigorous and responsive assessment of overseas-trained health practitioners" (s 3(2)(d)).
- "The main guiding principle of the national registration and accreditation scheme is that the following are paramount- (a) protection of the public; (b) public confidence in the safety of services provided by registered health practitioners and students" (s 3A(1)). The paramount principle was inserted by the Health Practitioner Regulation National Law and Other Legislation Amendment Act 2022 (Qld) s 34.
- The scheme "is to operate in a transparent, accountable, efficient, effective and fair way" (s 3A(2)(a)).
- Every entity with functions under the Law "is to exercise its functions having regard to the objectives and guiding principles" (s 4).
1.2 Who does what
The Law divides the work. Ahpra's functions are largely administrative: to support the Boards, and "to establish an efficient procedure for receiving and dealing with notifications against persons who are or were registered health practitioners" (s 25(i)), and an efficient procedure for registration (s 25(e)). The National Boards "oversee the receipt, assessment and investigation of notifications" and refer matters to tribunals (s 35(1)(g)-(i)).
In public debate "Ahpra" usually means the joint system of Ahpra and the Boards, and Ahpra's own annual report covers both. This report grades the joint system and uses "Ahpra" in that sense, except where the distinction matters.
1.3 How a notification is handled
- A Board "must, within 60 days after receipt of a notification, conduct a preliminary assessment" (s 149(1)). This is a narrow check of jurisdiction and grounds. The Law states no consequence if it is missed.
- A Board may decide to take no further action on listed grounds, including that the notification is "frivolous, vexatious, misconceived or lacking in substance", has been dealt with by another entity, or the practitioner "has taken appropriate steps to remedy the matter" (s 151(1)). The notifier must be told, with the reason (s 151(3)-(4)).
- A Board may take immediate action if it reasonably believes the practitioner "poses a serious risk to persons" and action is necessary to protect public health or safety, or if the action "is otherwise in the public interest" (s 156(1)).
- Section 162 is headed "Investigation to be conducted in timely way". It requires the Board to ensure an investigation is conducted "as quickly as practicable, having regard to the nature of the matter to be investigated". It sets no number of days.
- During an investigation the Board "must, at not less than 3 monthly intervals" tell the practitioner and the notifier of its progress (s 161(3)).
- A Board "must refer" a matter to a tribunal if it reasonably believes the practitioner has behaved in a way that constitutes professional misconduct (s 193(1)), subject to a public-interest exception (s 193A).
No provision of the Law sets an end-to-end time limit for closing a notification.
1.4 Who holds it to account
On the text of the Law:
- The Ministerial Council (Health Ministers) may give binding policy directions to Ahpra and the Boards, but not about "a particular application, notification or proceeding" (s 11(5)-(6)).
- Ahpra must give an annual report to the Ministerial Council within 3 months of the end of the financial year, including "a report about the Agency's performance of its functions" (Sch 3 cl 8(1)-(2)). The Council may extend the deadline by up to 3 months (cl 8(6)). The Law prescribes no performance measures or targets.
- The Commonwealth Ombudsman Act applies with the National Health Practitioner Ombudsman (NHPO) in place of the Commonwealth Ombudsman (s 235). The NHPO handles complaints about Ahpra and the Boards. It cannot take complaints about how NSW bodies or the Queensland Health Ombudsman handled a matter (NHPO Annual Report 2024-25 p 46).
- Only "A person who is the subject of" a listed decision may appeal it to a tribunal (s 199(1)). A notifier has no right of appeal or review. Ahpra's website says: "No other person can appeal a decision, including the person who raised the concern, a patient, employer or any other person" (Appealing a decision, read 11 October 2026).
- Individuals exercising functions are not personally liable for acts done in good faith; liability attaches instead to Ahpra (s 236).
These are features of the Law, not choices made by Ahpra, and they are not held against it in the grading.
1.5 What Ahpra says it is for
"Together, our primary role is to protect the public and set standards and policies that all registered health practitioners must meet" (ahpra.gov.au, Who we are, read 11 October 2026). Its regulatory principles say "Public protection is our paramount objective" and commit it to "take timely and necessary action under the National Law" (Regulatory principles, page dated 27 March 2024).
Its service charter (April 2022) commits it to "act in a timely way" and to keep people informed "about what is going on, what to expect and when". For concerns about practitioners it gives no timeframe (What you can expect from us, read 11 October 2026).
Its website gives two different accounts of waiting times:
- "In most cases, we try to finish the assessment process within 60 days and most notifications are closed within 90 days" (How long does it take, page dated 12 March 2025).
- "We receive over 10,000 notifications per year and, unfortunately, we currently have a waiting period of 3-5 months before these other concerns are allocated to a case officer" (Notifier experience, no date shown).
The pages may describe different groups of notifications. Neither states its base.
1.6 The co-regulatory states
NSW and Queensland are co-regulatory jurisdictions. In NSW, conduct, health and performance complaints are handled by the Health Care Complaints Commission and the NSW Health Professional Councils. In Queensland, the Office of the Health Ombudsman (OHO) receives all complaints, and Ahpra deals only with matters the OHO refers to it (Health Practitioner Regulation National Law Act 2009 (Qld) ss 7A-7C, 32, 34). The OHO referred 1,702 complaints about registered practitioners to Ahpra in 2024-25, down from 2,111 in 2023-24 (OHO Annual Report 2024-25 p 26).
Ahpra's annual report gives national totals and "Ahpra-managed" totals. This report uses Ahpra-managed figures unless it says otherwise. In 2024/25 Ahpra managed 13,327 of 22,658 notifications received nationally (AR 2024/25 pp 62-64).
2. The test
The core test is the gap between what the body is meant to do and what the record shows it does. For this body the test has four parts:
- Notifications: when someone raises a concern about a practitioner, does the system deal with it promptly and act where the public needs protecting?
- Registration: does it register qualified practitioners efficiently?
- Systems: does it find and fix problems that affect many patients?
- Candour: does it publish enough for the public to judge parts 1 to 3?
3. Notifications: volume and backlog
3.1 What comes in and goes out
| Year | Received (Ahpra-managed) | Closed | Open at 30 June | Source |
|---|---|---|---|---|
| 2010/11 | 5,297 | 2,281 | 3,016 | AR 2010/11 pp 57-58, 62, 69-70 |
| 2013/14 | 6,811 | 6,556 | 3,927 | AR 2013/14 pp 129-133, 155 |
| 2016/17 | 6,898 | 6,669 | 4,016 | AR 2016/17 pp 44, 54, 57 |
| 2018/19 | 9,338 | 8,979 | 4,546 | AR 2018/19 pp 64-65, 70-72 |
| 2020/21 | 10,147 | 10,121 | 5,515 | AR 2020/21 pp 64-67, 78, 81 |
| 2021/22 | 10,803 | 10,350 | 5,968 | AR 2021/22 pp 61-63, 67-68 |
| 2022/23 | 9,706 | 10,659 | 5,006 | AR 2022/23 p 62 |
| 2023/24 | 11,200 | 11,156 | 5,049 (4,441 excluding matters at tribunal) | AR 2023/24 pp 60, 69 |
| 2024/25 | 13,327 | 12,086 | 5,627 (excluding matters at tribunal) | AR 2024/25 pp 62, 71 |
Cautions:
- 2010/11 counts include some inquiries and advertising complaints, which were excluded from 2011/12 (AR 2011/12 p 85). The 2010/11 closures are only notifications both lodged and closed that year.
- From 2014/15 the Queensland figures are only matters referred by the OHO. In 2015/16 the state breakdown moved from the office handling a matter to the practitioner's place of practice (AR 2014/15 p 36; AR 2015/16 p 46).
- The 2018/19 rise includes a recording change for complaints retained by health complaints entities: the report says "adjusted increase was 14.3% (not 28.3%)" (AR 2018/19 pp 64-65).
- In 2024/25 Ahpra moved matters awaiting a panel or tribunal out of the open-notifications count and into a separate table counted by practitioner (section 9.2). The 2024/25 figure of 5,627 is therefore not comparable with the 5,049 published for 2023/24. On the comparable basis (excluding tribunal-stage matters), open notifications rose from 4,441 to 5,627 (AR 2024/25 p 62: "26.7% (1,186) more than last year").
3.2 2024/25: demand outran closures
Notifications received rose 19.0% and closures rose 8.3% (AR 2024/25 p 62). Ahpra's Regulatory Performance Committee, which advises the Ahpra Board, said:
- "completions did not keep pace with the increase in incoming notifications. As a result, the number of open notifications as at 30 June 2025 grew by 26.7%, adding 1,186 matters to the total open (5,627)."
- "the number of notifications older than 12 months rose by 30.7% (264 matters)."
(Regulatory Performance Committee, Annual report 2024/25, 15 September 2025.)
The annual report itself says: "The number of notifications open for 12 months or more increased (Table 19), partly due to the overall increase in the number of notifications received" (AR 2024/25 p 71). It attributes many aged matters to "complex and long-running investigations" with "related external legal or investigative processes such as police investigations or coronial inquiries" (p 71).
The quarterly reports for October to December 2024, the last published, show open notifications higher at 31 December 2024 than a year earlier in every state and territory report (Ahpra Quarterly Performance Reports, December 2024, table N1, eight jurisdictions). Summed across the eight reports, open notifications were 4,862, up from 4,115 (calc; Ahpra does not publish a national total in these reports, and the NSW and Queensland reports cover only matters Ahpra manages).
3.3 Aged matters
| 30 June | Open more than 12 months | Of which more than 24 months | Source |
|---|---|---|---|
| 2013 | 509 | 56 | AR 2012/13 pp 160-161 |
| 2017 | 761 | 158 | AR 2017/18 p 53 |
| 2020 | 844 | 233 | AR 2019/20 pp 69, 80 |
| 2021 | 1,164 | 399 | AR 2020/21 pp 78, 81 |
| 2022 | 1,288 | 483 | AR 2021/22 pp 67-68 |
| 2023 | 1,249 | 466 | AR 2022/23 pp 74-75 |
| 2024 | 1,047 (749 excluding tribunal stage; restated as 863) | 576 | AR 2023/24 p 69; AR 2024/25 p 71 |
| 2025 | 1,127 excluding tribunal stage, plus 214 practitioners at tribunal open more than 12 months | 500 excluding tribunal stage | AR 2024/25 p 71 |
All counts are calculated from the published age bands (calc). The tables up to at least 2022/23 are headed by length of time at each stage, so they measure time at the current stage, not time since the notification was received. No report gives the oldest open matter.
In 2016/17 Ahpra published a target: "AHPRA and the National Boards aim to have no more than 15% of investigations open for longer than 12 months. At 30 June 2017, 25.5% of investigations exceeded 12 months, up from 20% the previous year" (AR 2016/17 p 53). No later report states this target or a result against it.
The independent complexity review found that "25% of investigations and 21% of Tribunal referrals are open for more than 24 months" (Dawson review, final report dated July 2025 and released 12 September 2025, Theme 4).
4. Notifications: what happens to them
4.1 Outcomes
Ahpra reports the most serious outcome of each closed notification. Its categories changed in 2023/24 (section 9.2).
| Year | No further action (old basis) | Referred to or retained by another body | Any regulatory action (calc) | Source |
|---|---|---|---|---|
| 2018/19 | 69.5% | 12.9% | 17.5% (stated) | AR 2018/19 pp 70-71 |
| 2019/20 | 69.5% | 16.5% | 14.0% | AR 2019/20 pp 78-79 |
| 2020/21 | 71.1% | 14.7% | 14.2% | AR 2020/21 pp 78-79 |
| 2021/22 | 61.1% | 25.5% | 13.4% (stated) | AR 2021/22 pp 70, 77 |
| 2022/23 | 85.1% "no further regulatory action" (restated on the new basis) | included in 85.1% | 14.9% | AR 2023/24 p 72 |
| 2023/24 | 87.1% "no further regulatory action" | 20.5% (included) | 12.9% | AR 2023/24 p 72 |
| 2024/25 | 91.5% "no further regulatory action" | 29.2% (included) | 8.5% | AR 2024/25 p 72 |
On the new basis, "no further regulatory action" combines "No regulatory action taken" (55.6% in 2024/25), "Practitioner addressed issue" (6.7%) and "Referred to / retained by another organisation" (29.2%) (AR 2024/25 p 72). The report notes: "Actions taken by practitioners, workplaces, and other regulators or entities can contribute to an outcome of 'no further regulatory action'" (p 72).
In numbers, notifications closed with regulatory action (conditions, undertakings, fines, cautions, reprimands, or loss of registration) were 1,586 in 2022/23, 1,437 in 2023/24 and 1,033 in 2024/25 (calc from AR 2023/24 p 72 and AR 2024/25 p 72: 1,467 + 119; 1,211 + 226; 867 + 166). The fall in 2024/25 was about 28% (calc: 1,033 / 1,437 = 0.72), in a year when closures rose 8.3%. "Of the notifications closed this year, just 1.4% resulted in the practitioner losing their registration or being disqualified from applying for registration" (AR 2024/25 p 72).
Three things changed in 2024/25 that may explain part of the fall, and the report does not separate their effects:
- About 50% of notifications received were "categorised as lower risk and managed by an early determination process", up from 34.5% (AR 2024/25 pp 62-64).
- Referrals to or retention by other organisations rose to 29.2% of closures (p 72). The text puts referrals to health complaints organisations at 3,353, "a 63% increase" (p 66).
- Ahpra moved to a new case management system, "which introduced a significant change in the way data are captured and stored" (p 2).
The share closed with no further action has been described as high from the start. "The proportion of cases closed with no further action appears relatively high and AHPRA and the National Boards will continue to closely monitor these data over the coming year to understand the contributing factors" (AR 2010/11 p 64). "The proportion of cases closed with no further action remains relatively high" (AR 2011/12 p 91). The 2010/11 figure was 86% (AR 2010/11 pp 64-65).
Regulator Review's assessment: a high rate of no further action is not in itself a failing. Many notifications are about matters a regulator cannot or should not act on, and some are better handled elsewhere. But the share ending in regulatory action has roughly halved since 2018/19 on Ahpra's own figures, the absolute number fell sharply in the last year, and Ahpra has not published an analysis showing that the fall reflects lower risk rather than lower scrutiny.
4.2 Stage at closure
Until 2022/23 Ahpra published the stage at which notifications closed. Closures at assessment rose from 62.4% in 2017/18 to 78.0% in 2022/23, and closures after investigation fell from 28.7% to 18.4% (calc from AR 2017/18 p 52 and AR 2022/23 p 77). The proportion of notifications referred to investigation fell from 33.0% (2017/18) to 22.6% (2021/22) (AR 2017/18 p 51; AR 2021/22 p 71). Neither measure was published from 2023/24. In 2024/25 Ahpra said: "We no longer divide notifications into these stages and use assessments and investigation methods as information-gathering tools only where needed" (AR 2024/25 p 71, note to Table 19).
4.3 Immediate action
| Year | Immediate action taken (Ahpra) | Source |
|---|---|---|
| 2017/18 | 413 | AR 2017/18 pp 49-50 |
| 2019/20 | 580 | AR 2019/20 p 76 |
| 2021/22 | 685 | AR 2021/22 p 78 |
| 2022/23 | 335 | AR 2022/23 p 73 |
| 2023/24 | 413 | AR 2023/24 p 68 |
| 2024/25 | 554 cases relating to 315 practitioners | AR 2024/25 p 70 |
The 2022/23 fall was attributed to changes in the handling of health matters (AR 2022/23 p 73). The 2024/25 unit differs from earlier years. Median time to take immediate action was last published for 2017/18 (7 days; AR 2017/18 p 49). Victoria's December 2024 quarterly report gave a median of 29 days for that quarter (Quarterly Performance Report, Victoria, December 2024, N9).
The NHPO opened an own-motion investigation into "delay and procedural safeguards for practitioners subject to immediate action" in June 2024. Issues about immediate action in complaints to the NHPO rose from 24 (2020-21) to 84 (2023-24); in 2024-25 it recorded "180 issues across 80 complaints made by 57 people" (NHPO Annual Report 2024-25 pp 30-31). It reported: "The investigation is ongoing" (p 32). No final report had been found at 11 October 2026.
4.4 Tribunals
Ahpra wins almost all tribunal cases it brings: in 2024/25, 94.3% of tribunal decisions resulted in disciplinary action (AR 2024/25 pp 80-82). In 2023/24, "Once a matter was referred, it took on average 683 days for it to be finalised by the tribunal" (AR 2023/24 p 69); the figure for 2022/23 was 660 days (AR 2022/23 p 74). No figure was published for 2024/25. Ahpra attributes tribunal time partly to external parties: "we rely in part on the timeliness of external parties, such as the tribunal itself or the practitioner's representatives" (AR 2024/25 p 71).
The 2024/25 report gives two figures for practitioners referred to tribunals (192 at p 68; 196 at p 80) and two for practitioners with matters open at a tribunal (395 at p 80; 397 in Table 20, p 71).
5. Notifications: timeliness
5.1 What Ahpra publishes
| Year | Average days to complete a notification | Closed within 6 months | Average days to complete an investigation | Source |
|---|---|---|---|---|
| 2016/17 | not published | 64.9% | 392 | AR 2016/17 pp 53-54; AR 2017/18 p 51 |
| 2017/18 | not published | 64.5% | 379 | AR 2017/18 p 51 |
| 2018/19 | 187 (as restated in 2019/20) | 68.2% | not published | AR 2018/19 p 70; AR 2019/20 p 69 |
| 2019/20 | 177 | 71.6% | not published | AR 2019/20 pp 69, 78 |
| 2020/21 | 180 | 72.0% | not published | AR 2020/21 p 78 |
| 2021/22 | not published | "Just over 70%" (the figure shows 68.7%, calc) | not published | AR 2021/22 pp 67-68 |
| 2022/23 | not published | not published | not published | AR 2022/23 p 74 |
| 2023/24 | not published | "Nearly 80%" | not published | AR 2023/24 p 69 |
| 2024/25 | not published; described as "the lowest recorded since the start of the scheme" | 81.1% | not published | AR 2024/25 pp 6, 71 |
The improvement in closures within six months is real on Ahpra's figures, and it is credited below. The Regulatory Performance Committee said the low average was "driven largely by faster completion times for low risk matters" (RPC annual report 2024/25). The Ahpra CEO wrote that "Our focus on timeliness has seen the average time to close a notification reduce by 37% from its peak" (AR 2024/25 p 6). Neither the average nor the peak is stated.
The average is pulled down by the many matters closed quickly at the front of the process. It says little about the serious matters that take longest. Those are where the evidence points the other way:
- The independent complexity review reported: "The evidence available to the review was that between 2018/18 and 2022/23 the average number of days to complete an investigation increased by 52%. The increase between 2021-22 alone was from 367 days to 436 days" (Dawson review, Theme 4; "2018/18" is as printed). These investigation averages do not appear in any annual report from 2018/19 to 2024/25. The review does not say how they were calculated, so they may not be on the same basis as the 379 days Ahpra reported for 2017/18.
- The Victorian quarterly report for October to December 2024 gave an average of 553 days to complete an investigation in 2024/25 to date, and an average age of open investigations of 569 days (Quarterly Performance Report, Victoria, December 2024, N12 and N17).
- Matters older than 12 months rose 30.7% in 2024/25 (section 3.2).
Ahpra's quarterly report defines a notification's timeframe as running from when "Ahpra accepts the matter as a notification until a final decision has been made on the notification or it is referred to a Panel or Tribunal" (Quarterly Performance Report definitions, N12). Time before acceptance, and time at a tribunal, are outside the measure.
5.2 What others found
- Senate Community Affairs References Committee, May 2017: taking "years to conduct an investigation when there is a clear statutory requirement that the action be done as quickly as practicable, is simply unacceptable" (para 5.76). "AHPRA has been advised on multiple occasions that it must make shortening its timeframes for all cases a priority. Based on the evidence the committee received, AHPRA has failed to address these concerns" (para 5.78).
- Ahpra's own 2013/14 report: "We know from this work that we have an issue with the time investigations take and will be continuing to address this as a priority in 2014/15" (AR 2013/14 p 126). Against a target of 80% of investigations completed within six months, it reported a "Result to date" of 59% (p 126).
- Senate Community Affairs References Committee, April 2022, recommendation 11: "The committee recommends that AHPRA and the national boards undertake an analysis of the cause of protracted notifications timeframes and identify ways to further improve timeliness" (as reproduced in NHPO Annual Report 2021-22 pp 25-26).
- Dawson review, released September 2025: "For consumers and practitioners alike Ahpra processes lack timeliness, transparency and natural justice." "The reasons for prolonged investigation timeframes are not apparent or not convincing" (Theme 4).
- Health Ministers, 1 May 2026, accepted the action that the "Ahpra Board to immediately improve timeliness and quality of investigation processes and decision making and the availability of clinical advice across all regulatory functions, with specified actions to achieve this" (Health Ministers Meeting, response to the Independent Review of Complexity, action 4.3).
- Supreme Court of Victoria, Peers v Medical Board of Australia [2024] VSC 630 at [36]-[37]: the investigation "took almost three years"; "For the regulatory regime to operate fairly, the obligation to undertake investigations as quickly as practicable must be complied with." The Court found the Board's decision itself was not affected by error.
6. The people the system is there for
6.1 Notifiers and practitioners
Ahpra's surveys have been published irregularly (section 9.1). The only full set of results is for 2023/24: overall satisfaction 36% among notifiers (30% the year before) and 62% among practitioners (57%); 32% among notifiers whose notification ended with no restriction (AR 2023/24 p 63). Ahpra said: "Though these rates are improving, we recognise they are low" (p 63). No sample sizes were given. No results were published for 2024/25: "We are developing updates to these feedback mechanisms in our new case management system" (AR 2024/25 p 65).
Earlier: "'Fairness' emerged as a strong theme, with more than 70% of notifiers advising that they were unhappy with the outcome" (AR 2017/18 p 44). "One of the key concerns for both notifiers and practitioners is the length of time taken to complete notifications" (AR 2018/19 p 63).
6.2 Complaints about Ahpra
| Year | Complaints to the NHPO about Ahpra and the Boards | Of which about notifications | Source |
|---|---|---|---|
| 2019-20 | 595 | 351 | NHPO AR 2019-20 p 11; AR 2020-21 p 19 |
| 2021-22 | 823 (later restated as 826) | 309 | NHPO AR 2021-22 p 9; AR 2022-23 p 40 |
| 2022-23 | 663 | 430 | NHPO AR 2022-23 p 40 |
| 2023-24 | 691 | 435 | NHPO AR 2023-24 p 10 |
| 2024-25 | 980 | 508 | NHPO AR 2024-25 pp 41-42 |
The 2024-25 total was the highest recorded. The NHPO said the increase "was in part driven by health practitioners experiencing issues when accessing Ahpra's new operating system for the first time", and that "many nurses and midwives needed Ahpra's assistance to use the new system to renew their registration, which Ahpra struggled for some time to provide" (NHPO AR 2024-25 p 5). Issues about process delay in notification complaints rose from 125 to 152 (p 51). In one case: "Our investigation found that Ahpra did not manage the notification about Mary in a timely manner and that its communication with Mary could have been better" (p 43).
Ahpra's own count of administrative complaints was 1,544 in 2024/25, of which 1,053 were from practitioners about registration and renewal after the system change. The complaints raised 2,203 issues, of which 364 concerned timeliness or delay (AR 2024/25 pp 95-98). The base for this count changed in 2020/21 (AR 2020/21 p 110).
Note: the ABC reported in December 2025 that complaints against Ahpra "increased from 430 in 2022/23 to 691 in the latest financial year". On the NHPO's figures, 430 was the 2022-23 count of notification-related complaints only, and 691 was the 2023-24 total; the 2024-25 total was 980 (table above).
6.3 Registration
Registration is the part of the scheme that works best on the published record. Ahpra registered 959,838 practitioners at 30 June 2025, received 111,294 applications and finalised 106,794, and registered 26,703 internationally qualified practitioners (AR 2024/25 pp 52-57). Graduates were registered "six days on average after we received evidence of graduation" (p 56). Median time to decide an application was 2 days in 2020/21 and 2021/22 (AR 2020/21 p 55; AR 2021/22 p 50).
Two qualifications:
- The overall processing-time figures were last published for 2021/22. In 2024/25 Ahpra said "some types of registration applications are taking longer to finalise", without figures (AR 2024/25 p 56).
- The 2023 independent review of overseas practitioner settings found applicants and employers saw the end-to-end journey as "inefficient, complex, costly and slow" (Kruk review, Final report, 2023, foreword p 1). That review covered the whole system (registration, migration, employment), not Ahpra alone.
7. Willingness to use its powers
7.1 Sexual misconduct and boundary violations
This is the area that drew the ABC's December 2025 reporting.
- The ABC reported two Queensland complaints about intimate examinations in which Ahpra took no further regulatory action. In one, the ABC reported Ahpra's view that "in circumstances where [Ms Drake] consented to the procedure and did not withdraw that consent at any time, there is no indication that his conduct was inappropriate or sexual in nature". In the other, according to documents seen by the ABC, Ahpra found it "not possible to form a reasonable belief that [the doctor] engaged in unsatisfactory professional performance". An Ahpra spokesperson said: "A decision to take no further regulatory action means that in a particular case, further regulatory action is not required to manage ongoing risk to patients" (ABC News, 8 December 2025).
- The same article concerned a Brisbane doctor whose matter took five years to reach a tribunal. That delay was on the OHO's side, not Ahpra's; the OHO filed the proceedings (ABC News, 8 December 2025 and 3 March 2026). It is noted here so that it is not attributed to Ahpra.
- Notifications about boundary violations rose to 1,991 in 2024/25, from 1,156 in 2023/24 and 464 in 2019/20 (AR 2024/25 pp 68-70; AR 2023/24 pp 66-67; AR 2019/20 p 77). The category was widened in 2021/22 ("The increase in the number of boundary violation matters can be attributed to the inclusion of new concern types", AR 2021/22 p 79), and from 2022/23 the Queensland figure includes matters managed by the OHO. The series is therefore not like for like.
- Ahpra published outcomes for these notifications from 2019/20 to 2021/22 only. In 2021/22: 6.5% closed after referral to a tribunal, 4.3% ended with loss of registration, 10.6% with conditions and 6.2% with a caution or reprimand (AR 2021/22 pp 79-80). No outcome data for boundary violation notifications have been published since, while the number received has more than doubled (calc: 841 in 2022/23 to 1,991 in 2024/25).
- Mandatory notifications are reports by other practitioners and employers. The share of completed mandatory notifications that led to regulatory action fell from 43.4% (2017/18, as restated) to 38.2%, 35.8%, 31.3% and 29.8% (2021/22). The measure was not published after 2021/22 (AR 2018/19 to AR 2021/22, mandatory notification sections).
Earlier record:
- In 2017 the Paterson review of chaperone conditions found that 27 interim chaperone conditions in place in September 2016 "had been in place for 1.8 years" on average, and concluded: "It is time to abandon chaperone conditions as an interim restriction, given their dubious appropriateness and the evident holes in the safety net they are meant to provide" (Independent review of the use of chaperones to protect patients in Australia, February 2017). Ahpra and the Medical Board adopted the recommendations, and a later review by Professor Paterson found "nearly all 28 recommendations of the 2017 chaperone review report have been fully implemented" (AR 2019/20 p 69). This is credited below.
- In February 2023 Health Ministers ordered a rapid review of Ahpra "to understand the extent to which action has been taken in response to previous reviews including on the management of professional misconduct relating to boundary violations" (Health Ministers Meeting communique, 24 February 2023). The rapid review report was not located.
- From 10 April 2026, findings of professional misconduct involving sexual misconduct must be recorded permanently on the public register (National Law ss 225A-225B, inserted by the 2025 amendments). Ahpra reported that "additional information being added to the register entries of 107 practitioners. Of these, 86 are on the list of cancelled practitioners" (Ahpra media release, 10 April 2026). The ABC reported that 21 of them are still practising (ABC News, 10 April 2026). The change was made by Parliament; Ahpra implemented it.
7.2 Other cases
- The independent review of cosmetic surgery found: "Most concerning was that no mandatory notifications appear to have been made about cosmetic surgery matters received between 1 July 2018 to 31 December 2021" and "a significant variation in approach in managing these matters over the review period" (Independent review of the regulation of medical practitioners who perform cosmetic surgery, August 2022, pp 8-9). Ahpra and the Medical Board accepted its recommendations.
- In February 2026 the ABC reported that complaints about a Victorian gynaecologist had reached Ahpra from patients "going back almost four years" (ABC News, 24 February 2026). In August 2026 the Medical Board referred him to the Victorian Civil and Administrative Tribunal alleging professional misconduct (ABC News, 31 August 2026). The allegations have not been determined. Health Ministers said in May 2026: "The pervading culture of silence cannot continue" (Health Ministers Meeting communique, 1 May 2026).
7.3 Use of powers against the practitioner
The record also contains cases where courts found against the Boards on fairness:
- Wilks v Psychology Board of Australia [2024] VSC 2 at [193]: the Board's decision to pause a 17-month investigation pending civil proceedings "was legally unreasonable and, therefore, affected by jurisdictional error".
- Bay v Australian Health Practitioner Regulation Agency [2024] QSC 315: "AHPRA and the Board conceded that it was open to the Court to find that the decisions were affected by apprehended bias and that they did not afford Dr Bay procedural fairness" (catchwords).
7.4 Offences
Ahpra prosecutes offences under the Law, mostly people who are not registered holding themselves out as practitioners. Prosecutions completed were between 8 and 16 a year from 2017/18 to 2024/25 (AR 2017/18 to AR 2024/25, statutory offences sections). In 2024/25, 15 prosecutions were completed, 14 with a finding of guilt (AR 2024/25 pp 84-86). Of 192 media releases from July 2024 to October 2026, 24 concern prosecutions by title (calc from the Ahpra news listing).
8. Systems: problems affecting many people
On the evidence, Ahpra's systemic work is mixed but real.
- Chaperones: the 2017 review led to an end to chaperone conditions as an interim restriction for sexual misconduct allegations, and the recommendations were implemented (section 7.1).
- Vexatious notifications: Ahpra published a framework in December 2020 and accepted all 17 recommendations of the NHPO's December 2024 review, which also found that "Ahpra did not always record allegations that a notification was vexatious, meaning the number of times the framework should or could have been applied is likely higher than Ahpra reported" (NHPO AR 2024-25 pp 24-26).
- Practitioner wellbeing: research commissioned by Ahpra found that 16 practitioners "currently or recently involved in regulatory processes took their lives between January 2018 and December 2021" (as reported in NHPO AR 2022-23 p 18). Ahpra published this, which is to its credit; it also shows the cost of delay to practitioners.
- Cosmetic surgery and the sexual misconduct register (section 7). The register change and the reprisal protections for notifiers (in force 1 December 2025) were made by Parliament after reviews; several began with reporting by the ABC.
Against that, the main systemic findings about Ahpra have come from outside it, and several recur:
- "The single most important conclusion to be drawn from the Review is that the persistence of inefficient and ineffective accreditation processes … are fundamentally failures of governance" (Accreditation Systems Review, November 2017, executive summary p 1; the passage concerns the accreditation system, of which Ahpra is part).
- "When expected standards of conduct and performance are not met by individual health practitioners, the wide experience is that the National Scheme is not sufficiently effective, timely or fair." The review found the scheme's complaints handling function "is a significant weakness in the National Scheme" and identified "culture and capability issues" (Dawson review, executive summary).
- Health Ministers accepted that the "Ahpra Board to commission an Independent Organisational Capability Review of Ahpra Agency" (response of 1 May 2026, action 3.3).
9. Candour: what Ahpra publishes
Ahpra publishes more data than many regulators: notifications by profession, state, source and outcome, and open notifications by age, every year since 2010/11. That deserves credit. The record also shows a pattern of measures appearing and then disappearing, often in the years they looked worst.
9.1 What stopped being published
| Item | Last published | Source |
|---|---|---|
| Quarterly performance reports (one per state and territory) | October to December 2024. None listed for 2025 or 2026 at 11 October 2026 | Statistics page, ahpra.gov.au, read 11 October 2026 (page "reviewed 27/02/2025") |
| Results against the set of notification KPIs introduced in 2013/14 (for example investigations 80% within six months: 59%) | Full set 2013/14 only. The report said "Having introduced KPIs in 2014, we will be reporting on our performance in 2015". Later reports gave a result against the 60-day assessment target only (97.7% in 2015/16, 98.1% in 2016/17) | AR 2013/14 pp 10, 126; AR 2015/16 p 45; AR 2016/17 p 44 |
| Target of no more than 15% of investigations open more than 12 months, and result | 2016/17 (25.5% against 15%) | AR 2016/17 p 53 |
| Average days to complete an investigation (annual report) | 2017/18 (379 days). Carried in the quarterly reports to December 2024. Later national figures (367 and 436 days) appear only in the Dawson review | AR 2017/18 p 51; Dawson review Theme 4 |
| Median days to take immediate action (annual report) | 2017/18. Carried in the quarterly reports to December 2024 | AR 2017/18 p 49 |
| Average days to complete a notification (annual report) | 2020/21 (180 days); quarterly reports to December 2024. In 2024/25 described as "lowest recorded" without the figure | AR 2020/21 p 78; AR 2024/25 p 71 |
| Average age of open notifications (annual report) | 2020/21 (250 days, up 19.6%); quarterly reports to December 2024 | AR 2020/21 p 78 |
| Average days in assessment | 2020/21 | AR 2020/21 p 78 |
| Closures by elapsed time beyond 6 months (share closed after more than 12 months) | 2021/22 | AR 2021/22 pp 67-68 |
| Share of mandatory notifications leading to regulatory action | 2021/22 (29.8%, falling each year from 2017/18) | AR 2021/22 pp 75-77 |
| Outcomes of boundary violation notifications | 2021/22 | AR 2021/22 pp 79-80 |
| Overall registration processing time | 2021/22 | AR 2021/22 p 50 |
| Stage at closure and proportion referred to investigation | 2022/23 (stage); 2021/22 (referral rate) | AR 2022/23 p 77; AR 2021/22 p 71 |
| Average time at tribunal and time on hold for external processes | 2023/24 | AR 2023/24 p 69 |
| Notifier and practitioner satisfaction | 2023/24 only (36% of notifiers). Partial in 2020/21; none in 2021/22, 2022/23 or 2024/25 | AR 2023/24 p 63; AR 2024/25 p 65 |
Reasons given: for stages, "We no longer divide notifications into these stages" (AR 2024/25 p 71); for surveys, the new case management system (p 65). No reason was found for the other items. On the quarterly reports, the Regulatory Performance Committee reported that it had "Commenced work to improve the performance reporting framework" (RPC annual report 2024/25). The committee's own functions include advice on "Key Performance Indicators on timeliness, cost and quality" and to "review Ahpra's quarterly performance reports" (committee web page, charter dated November 2025).
Several of these measures survived in the quarterly reports after they left the annual report. Since the quarterly reports stopped, none of them has been published anywhere found. No annual report from 2017/18 to 2024/25 publishes a set of notification KPIs with targets and results.
9.2 Changed definitions
- 2012/13: a new outcome, "HCE to retain" (health complaints entity to retain), cut the no-further-action share from 80% to 60%. The report said this "is likely to reflect a change in coding arrangements … rather than significantly altered Board decision-making patterns" (AR 2012/13 p 146).
- 2014/15: Queensland figures limited to OHO referrals, driving falls in the national totals (AR 2014/15 p 36).
- 2023/24: outcome categories reorganised; "no further action" split, and referrals to other bodies grouped into a "no further regulatory action" subtotal. The 2017/18 to 2022/23 "no further action" series (72.0% to 62.7%) is not comparable with the new lines (AR 2022/23 p 78; AR 2023/24 p 72).
- 2024/25: stages replaced by "most relevant activity"; tribunal-stage matters removed from the open count and counted by practitioner: "Cases that are awaiting a panel or tribunal hearing are now counted by practitioner, whereas in previous years they were counted by case (notification)" (AR 2024/25 p 71). The stated reason is the new case management system (p 2).
9.3 Restated figures and inconsistencies
- The 2024/25 report restates the 2023/24 open-notification age table: "The data for 2023/24 in Table 19 has been updated since this report was originally tabled in parliament on 13 November 2025" (AR 2024/25 p 71). No reason is given. The restated 2023/24 row sums to 4,414 against a total of 4,441 (calc), and its "less than 3 months" cell (2,164) is the same as the 2024/25 value. The restatement raises 2023/24 matters open more than 12 months from 749 to 863 (calc).
- Tribunal referrals (192 and 196) and open tribunal matters (395 and 397) are given two ways in the 2024/25 report (section 4.4).
- 2021/22: "Just over 70%" of notifications closed within six months; the report's own figure bands sum to 68.7% (calc; AR 2021/22 pp 67-68).
- Earlier reports carry similar small inconsistencies, for example open matters at 30 June 2011 given as 3,879 in the text and 3,851 in the table (AR 2010/11 pp 69-70), and a count of "legacy" open matters later described as "an over-estimate" (AR 2011/12 p 100).
These are recorded as printed. None changes the findings above. They bear on how much reliance can be placed on headline figures without checking the detail.
9.4 Media releases
Ahpra's release on its 2024/25 annual report said: "The average time to close a notification is now the lowest recorded since the National Scheme began, with 81.1 per cent closed within six months of receipt" (Ahpra media release, 14 November 2025). It did not mention the 26.7% rise in open notifications or the 30.7% rise in notifications older than 12 months, which the annual report and the Regulatory Performance Committee report both record. In September 2025 Ahpra said it had "reduced its average assessment times for complaints to the lowest on record" (media release, 12 September 2025). In May 2025 the CEO acknowledged "that sometimes these matters can take too long to resolve" (media release, 12 May 2025).
10. Money
| Year | Total income | Total expenses | Staff (FTE at 30 June) | Source |
|---|---|---|---|---|
| 2010/11 | $122.7m | $129.1m | about 600 staff | AR 2010/11 pp 23, 118, 120 |
| 2016/17 | $173.2m | $179.2m | 888.2 | AR 2016/17 pp 76, 85-86 |
| 2020/21 | $235.2m | $217.8m | 1,100 | AR 2020/21 pp 107-108, 122 |
| 2024/25 | $358.1m | $362.4m | 1,449 | AR 2024/25 pp 94, 99 |
Expenses roughly doubled between 2016/17 and 2024/25 in nominal terms (calc: 362.4 / 179.2 = 2.0), and staff rose by about 63% (calc: 1,449 / 888.2). Over the same period Ahpra-managed notifications received roughly doubled (6,898 to 13,327) and registered practitioners rose by about 41% (calc: 678,938 to 959,838). Ahpra is funded mainly by practitioners' fees: registration fees were $277.7m of total income of $358.1m in 2024/25 (calc: 77.5%; AR 2024/25 p 107). For 2025/26, "an operating deficit is planned, which will draw upon equity reserves" (p 100).
No annual report gives the full cost of the notifications function. The published "legal and notification costs" ($16.0m in 2024/25) exclude Ahpra staff costs (AR 2022/23 p 118).
11. Assessment and proposed grade
Findings of fact are in sections 1 to 10. This section is Regulator Review's assessment.
Scale used: A excellent; B good; C adequate; D poor; E failing; F not performing the function.
| Criterion | Grade | Reason |
|---|---|---|
| 1. Doing the core job: protecting the public through registration and notifications | D | Registration works and is fast for most applicants. The notification system does not meet the Law's standard of investigations "as quickly as practicable": open and aged matters rose sharply in 2024/25, investigation times rose 52% between 2018/18 (as printed) and 2022/23 on evidence given to the Dawson review, and the number of closures ending in any regulatory action fell by about 28% in a year without an explanation that shows the risk fell too |
| 2. Service to the people it is there for | D | 36% of notifiers satisfied in the only year with full results; a record 980 complaints to the NHPO in 2024-25, partly from the system change; a published 3-5 month wait before many notifications are allocated; no service targets for notifications. In its favour: 81.1% of notifications closed within six months, up from 64.5% in 2017/18 |
| 3. Willingness to use its powers | D | Tribunal cases succeed (94.3%) and immediate action is used, but the regulatory action rate has roughly halved since 2018/19, the mandatory notification action rate fell every year it was published, and outcome data for boundary violation matters stopped as those notifications more than doubled. Reviews found no mandatory notifications in cosmetic surgery over 3.5 years and chaperone conditions left in place for 1.8 years on average. Courts have also found unfairness against practitioners |
| 4. Systemic impact | C | Chaperone reform implemented; vexatious notification and cosmetic surgery recommendations accepted; practitioner suicide research published; register reforms implemented. But the main systemic findings about Ahpra have come from Senate committees, independent reviews and the media, and the same timeliness problem recurs across them |
| 5. Transparency about itself | D | A large annual data set, but quarterly performance reports stopped after December 2024; the full set of KPIs introduced in 2013/14 was reported once; average investigation time, notification time and open-matter age were dropped from the annual report and then went with the quarterly reports; outcome categories and the open-matter count were redefined; 2024/25 claims a "lowest recorded" average without the number and restates 2023/24 data without reason. The 2024/25 media release omitted the rise in open and aged matters |
| 6. Accountability | C | Ahpra accepts external recommendations readily, the NHPO and Health Ministers provide real oversight, and the CEO has acknowledged delay. Against that, the same criticism of timeliness has been accepted and repeated in 2014 (AR 2013/14), 2017, 2022, 2025 and 2026. The absence of any review right for notifiers (s 199) is a feature of the Law and is not held against Ahpra |
Proposed overall grade: D.
Reasoning. Ahpra does two jobs. Registration, which serves practitioners and employers, is efficient on the published record. Notifications, which is how patients and the public meet the regulator, is the job closest to the Law's paramount principle of protecting the public, and it carries the most weight. On that job the record is poor and, on the measures that matter most, getting worse: more open matters, more old matters, longer investigations on the evidence available, and far fewer closures ending in action. Ahpra's headline improvement, faster average closure, is real but is driven by low-risk matters closed quickly, and the measures that would show what happens to serious matters have been dropped or redefined. The grade is D rather than E because registration works, tribunal cases succeed, the system does act in the most serious cases, and Ahpra has implemented several reforms. It is not C because the same failure has been identified by Parliament, independent reviewers and Ministers for at least nine years.
What would change the grade: publication of the quarterly reports again, with a national total; notification KPIs with targets, published and met for two consecutive years; average and median time to complete an investigation and the age of open investigations, reported every year; a fall in notifications older than 12 months; outcome data for boundary violation and mandatory notifications restored; an analysis of why the share of closures ending in regulatory action fell; and notifier satisfaction above one in two. The outcome of the capability review ordered by Health Ministers, and of the NHPO's immediate action investigation, may also bear on the grade.
12. What is not known
- The 2025/26 annual report had not been published at 11 October 2026. Under Sch 3 cl 8 it was due to Health Ministers by 30 September 2026, extendable by up to 3 months; whether it has been submitted is not known.
- National open notifications and timeliness since December 2024, other than the 30 June 2025 figures.
- The current average time to complete an investigation, and the oldest open matter.
- Why the number of closures ending in regulatory action fell by about 28% in 2024/25, and how much of the fall reflects the early determination process, increased referrals and the data system change.
- What happened to boundary violation notifications from 2022/23 to 2024/25.
- The full cost of the notifications function.
- The 2023 rapid review report and the NHPO's immediate action investigation outcome.
- The QCAT decisions in the Queensland matter reported by the ABC (citations not located), and the 2022 Senate report itself (its recommendations are taken from the NHPO's reproduction).
- Whether the OHO, which has a statutory function to monitor Ahpra's performance for Queensland (Health Ombudsman Act 2013 (Qld) s 25(d)), has published any recent assessment of it. None was found in its 2019-20, 2023-24 or 2024-25 annual reports.
13. Sources
- Ahpra and National Boards, Annual Reports 2009/10 to 2024/25, with supplementary material. https://www.ahpra.gov.au/Publications/Annual-reports
- Ahpra, Quarterly Performance Reports, July-September and October-December 2024 (eight jurisdictions each). https://www.ahpra.gov.au/About-Ahpra/What-We-Do/Statistics
- Ahpra Regulatory Performance Committee, Annual report 2024/25, 15 September 2025.
- Ahpra website pages: Who we are; Core functions; Regulatory principles; What you can expect from us (service charter); How long does it take; Notifier experience; Investigation; Appealing a decision; Complaints; NSW and Qld; Regulatory Performance Committee; media releases listing. Read 11 October 2026. https://www.ahpra.gov.au
- Ahpra media releases: 12 May 2025; 12 September 2025; 14 November 2025; 10 April 2026. https://www.ahpra.gov.au/News.aspx
- Health Practitioner Regulation National Law Act 2009 (Qld), including the National Law in its Schedule, current as at 10 April 2026. https://www.legislation.qld.gov.au/view/pdf/inforce/current/act-2009-045
- Health Practitioner Regulation National Law and Other Legislation Amendment Act 2022 (Qld) No 22; Amendment Act 2025 (Qld) No 6. https://www.legislation.qld.gov.au
- Health Ombudsman Act 2013 (Qld), current as at 10 April 2026.
- National Health Practitioner Ombudsman, Annual Reports 2018-19 to 2024-25. https://www.nhpo.gov.au (copies from https://territorystories.nt.gov.au)
- Office of the Health Ombudsman (Qld), Annual Reports 2016-17, 2019-20, 2023-24, 2024-25.
- Senate Community Affairs References Committee, Complaints mechanism administered under the Health Practitioner Regulation National Law, May 2017. https://www.aph.gov.au/~/media/Committees/clac_ctte/complaintsmechanism/report.pdf
- Senate Community Affairs References Committee, Administration of registration and notifications by the Australian Health Practitioner Regulation Agency and related entities, April 2022 (recommendations as reproduced in NHPO AR 2021-22).
- R Paterson, Independent review of the use of chaperones to protect patients in Australia, February 2017.
- M Woods, Australia's Health Workforce: strengthening the education foundation (Accreditation Systems Review, final report), November 2017.
- A Brown, Independent review of the regulation of medical practitioners who perform cosmetic surgery, final report, August 2022.
- R Kruk, Independent review of Australia's regulatory settings relating to overseas health practitioners, final report, 2023.
- S Dawson, Transforming health professions regulation in Australia (Independent Review of Complexity in the National Registration and Accreditation Scheme), final report, July 2025 (released 12 September 2025). https://www.health.gov.au
- Health Ministers Meeting, Response to the Independent Review of Complexity in the National Registration and Accreditation Scheme, May 2026; communiques of 24 February 2023 and 1 May 2026. https://www.health.gov.au
- Peers v Medical Board of Australia [2024] VSC 630; Wilks v Psychology Board of Australia [2024] VSC 2; Bay v Australian Health Practitioner Regulation Agency [2024] QSC 315.
- ABC News: 8 December 2025 (health regulator accused of failing to support patients); 24 February 2026; 3 March 2026; 10 April 2026; 31 August 2026. https://www.abc.net.au/news