When the government changes, who knows what else needs to change?

Machinery of Government changes are designed to reshape responsibilities and improve the delivery of public services. But transferring a function is only the beginning. The harder challenge is ensuring that the policies, decisions and operational processes supporting it remain aligned.

The Australian Government Department of Finance recently announced an update to its Machinery of Government (MoG) Changes Guide, including additional guidance on Ministerial Statements of Expectations and Regulator Statements of Intent where responsibility for regulatory functions changes.

It is a relatively specific update, but it highlights a much broader challenge facing the government.

When responsibilities move between departments, accountability must move with them. Yet accountability is not established simply by updating an organisational chart, issuing a new delegation or transferring a set of documents.

It depends on whether the receiving organisation understands how those responsibilities connect to everything else it does.

And that is where Machinery of Government changes become considerably more complex.

The administrative transfer is only part of the change

Machinery of Government changes can involve the creation or abolition of departments, the movement of functions between agencies, or changes to ministerial responsibilities.

These changes are familiar territory for public-sector leaders.

The Commonwealth’s MoG Changes Guide provides a structured framework covering governance, people, financial management, information assets, technology and continuity of government business.

Where no alternative completion date is specified by the government, the guide sets an expectation that MoG changes will be completed within 13 weeks of commencement.

That creates a necessary focus on immediate priorities: transferring resources, clarifying accountability, establishing delegations, ensuring employees are supported and maintaining essential services.

But the completion of these activities does not necessarily mean the receiving organisation has achieved operational integration.

A function may have transferred successfully while the policies that govern it remain inconsistent with those of the receiving department.

A delegation may have been updated while related approval procedures still reference a previous structure.

Operational instructions may remain technically accessible but no longer accurately reflect the organisation’s responsibilities.

These are not simply documentation issues.

They affect how people make decisions, how managers exercise oversight and how an organisation demonstrates that its activities are consistent with its obligations.

The distinction is between transferring responsibility and establishing the conditions for that responsibility to be exercised consistently.

The evidence suggests this is a persistent challenge

The difficulties associated with Machinery of Government changes are well documented.

In its 2023 report, Implementing machinery of government changes, the Queensland Audit Office examined the implementation of significant government restructures.

The scale of the change was substantial. Following Queensland’s 2020 restructuring, 17 core departments were affected, with 23 functions moving, more than 6,200 employees transferring and approximately $8.3 billion in assets involved.

The audit also highlighted the longer-term consequences of these transitions.

Among its findings, the Audit Office identified that existing policies and procedures were sometimes adopted without being updated for consistency across departments or adequately communicated to employees.

It observed that policy reviews were frequently delayed by competing priorities, creating risks of inconsistent practices and poor decision-making.

The report also identified problems with records management and the retention of institutional knowledge.

These findings point to a challenge that extends beyond the initial administrative transfer.

Government departments may have a clear understanding of which functions have moved, while having a less complete picture of all the operational relationships affected by that movement.

And the consequences can remain long after the formal transition activities have been completed.

The hidden complexity is in the connections

Consider a government regulatory function moving from one department to another.

At the highest level, the change may appear straightforward: a new department assumes responsibility for administering the function.

But beneath that transfer sits an extensive network of organisational requirements.

Legislation establishes the legal framework. Policies interpret obligations and set expectations. Delegations identify who can exercise particular authorities. Procedures describe how activities should be performed. Work instructions help staff apply those procedures in specific situations.

Controls, reporting arrangements and assurance processes provide further oversight.

None of these elements operate independently.

A change to regulatory responsibility may require updates to authorisations, delegations, decision-making procedures, records arrangements, staff guidance and oversight mechanisms.

A revised policy may affect multiple procedures across different business units.

Two departments may use different terminology to describe the same activity, or apply different rules to activities that become part of the same operating model.

And information describing those relationships may be distributed across document repositories, intranets, business systems and local team knowledge.

The challenge is not necessarily that the information is missing.

It is that the relationships between the information are difficult to see.

An organisation can possess every relevant policy and still struggle to identify which ones conflict, which depend on one another and which require attention when circumstances change.

That is a different problem from document availability.

It is a problem of organisational understanding.

Why traditional approaches struggle to keep pace

Public-sector organisations have developed established methods for managing complex transitions.

Project plans, risk registers, governance committees, legal reviews, policy inventories and transition working groups all play important roles.

These mechanisms are essential.

But the work of identifying operational dependencies often remains heavily manual.

Teams must find the relevant information, determine whether it is current, understand how it relates to other material, identify discrepancies and agree on the changes required.

The process depends on expertise and institutional knowledge, sometimes concentrated in a relatively small number of people.

That becomes particularly difficult when the organisation itself is changing.

People move. Teams are restructured. Responsibilities shift. Existing documents may be incomplete or out of date.

The Queensland Audit Office identified the loss of experienced personnel and institutional knowledge as challenges in implementing previous changes.

The result is a difficult combination: increasing organisational complexity at precisely the moment when the knowledge needed to navigate that complexity may be most fragmented.

Better document search can help people locate information.

But locating a document is not the same as establishing whether its contents remain consistent with another policy, a changed delegation or a new organisational responsibility.

Likewise, consolidating information into a common repository does not, by itself, resolve contradictions or establish the relationships between requirements.

Improving access to information is important. Understanding its dependencies is the next challenge.

From managing the transition to understanding its impact

This suggests an opportunity to strengthen the way government approaches organisational change.

Rather than treating policies, procedures, delegations and operational guidance as separate collections of documents, organisations can begin to consider them as interconnected elements of an operating framework.

That changes the questions leaders can ask.

Instead of asking only whether policies have been transferred, they can ask which policies may be inconsistent with the receiving department’s existing requirements.

Instead of checking whether delegations have been updated, they can examine which procedures and operational instructions depend on those delegations.

Instead of relying solely on individual teams to identify downstream implications, they can seek a broader view of where a change may have consequences across functions and business units.

The objective is not to automate governance decisions or remove expert judgement.

Legal interpretation, regulatory authority, policy ownership and accountable decision-making must remain with appropriately authorised people.

The opportunity is to give those people better visibility into the information and relationships they are responsible for managing.

Technology that can help identify potential inconsistencies, map dependencies and surface areas requiring review could make a meaningful contribution.

It could help organisations focus scarce expert attention where it is most needed.

And it could help leaders gain greater confidence that important implications have not been overlooked.

There is a distinction here between identifying a possible conflict and determining how that conflict should be resolved. The former can be supported by technology; the latter remains an organisational decision.

Operational alignment should not be a one-off exercise

Although Machinery of Government changes make these challenges particularly visible, they are not unique to restructures.

Organisations are continually affected by changes to legislation, regulation, policy, operating models, technology and internal responsibilities.

Each change can have consequences beyond the document, department or process in which it originates.

A governance framework that appears aligned today can gradually become inconsistent as new requirements are introduced and older instructions remain in circulation.

This raises a broader question for government leaders.

What would it mean to maintain an ongoing understanding of how organisational requirements connect, rather than reconstructing those relationships every time a major change occurs?

The value would extend beyond transition management.

It could strengthen policy governance, operational consistency, change-impact assessment and the organisation’s ability to respond when responsibilities evolve.

It would also shift the emphasis from periodic reconciliation towards more continuous awareness of potential alignment gaps.

For complex departments managing substantial volumes of policy and operational information, that is an important direction to consider.

A different measure of successful change

The Department of Finance’s updated guidance is a useful reminder of the importance of clear regulatory accountability when government responsibilities change.

And the broader MoG framework provides necessary structure for what are often demanding transitions.

But the experience documented by public-sector audit offices points to a further question that deserves attention.

How should the government assess whether the organisation is genuinely operating in alignment after responsibilities have been transferred?

Completing the transfer of people, budgets, records and functions is essential.

So is maintaining continuity of services throughout the change.

Yet lasting success also depends on whether the organisation’s policies, procedures, delegations and operational guidance support consistent decisions under the new arrangements.

That requires more than knowing where information is stored.

It requires understanding how organisational information connects, where inconsistencies may exist and what else needs to change when one part of the organisation changes.

Because changing the structure of government is one thing. Ensuring the organisation can operate coherently within that structure is another.

And it is that second challenge that deserves greater attention.

References

• Australian Government Department of Finance, PGPA Newsletter 119, 2 October 2026.
• Australian Government Department of Finance and Australian Public Service Commission, Machinery of Government Changes Guide.
• Department of Finance, Machinery of Government Changes Guide — Executive Overview.
• Queensland Audit Office, Implementing machinery of government changes, Report 17: 2022–23, June 2023.