The NSW Office of the Public Service Commissioner (OPSC) released the NSW Government Sector Integrity Framework (the Framework) in March 2026, alongside a self-assessment tool, action planning guide, and template. For public sector agencies, it is the most structured integrity diagnostic the sector has seen, and the timing is not incidental. The obligations on NSW government sector agencies, under the Public Interest Disclosures Act 2022, the work of the ICAC, and the expectations of an increasingly scrutinous public, have never been more demanding.
What is the Framework?
The Framework is built on the foundation of the Government Sector Employment Act 2013 and the Ethical Framework for the government sector, which enshrines four core values: integrity, trust, accountability, and service. It gives agencies a structured methodology for assessing the maturity of their integrity culture across five pillars:
- Policies and procedures;
- Leadership;
- People and culture;
- Preventing wrongdoing; and
- Oversight and accountability.
Accompanying the Framework are a self-assessment tool, an action planning guide, and an action planning template. Together, these allow agencies to rate themselves across each pillar on a four-level maturity scale: Vulnerable, In Development, Generally Compliant, and Excellent Practice. The assessment outputs include a radar chart, performance ratings, and a report card, giving agencies a visual and numerical representation of their current position.
What makes this Framework different?
The Framework is explicit that integrity is not a compliance exercise. The OPSC’s design intent is for agencies to treat the self-assessment as a genuine diagnostic, one that asks not whether policies exist, but whether they are embedded, understood, and actually shaping behaviour.
That framing aligns with a broader shift in how courts and regulators are assessing institutional conduct, one that treats the gap between documented policies and actual practice as the central question, not an afterthought. The ICAC’s Assessing Corruption Control Maturity guide, the obligations introduced by the PID Act 2022, and recent litigation involving senior executives all point in the same direction.
For agencies that have historically treated integrity as a documentation exercise, the Framework asks something harder.
Key Considerations for Agencies
The self-assessment is internal, but the findings carry weight
The Framework makes clear that results do not need to be published. That design choice creates space for honest reflection. But agencies should understand that a self-assessment which identifies known gaps creates an obligation to act. An agency that identifies weaknesses in its Preventing Wrongdoing pillar, for example, and fails to take remedial steps, is in a more difficult position if those weaknesses are later exposed through an investigation, a PID, or an ICAC referral.
Boards and audit and risk committees who receive action plan outputs should treat them as governance documents. Filing them without resourcing them is its own kind of risk.
The ‘Preventing Wrongdoing’ pillar sits at the intersection of significant legal risk
This pillar covers prevention, detection, response to integrity breaches, complaints handling, workplace investigations, PID management, and ICAC engagement. These are also the areas where the gap between policy and practice tends to be widest, and where it tends to surface at the worst possible time.
The PID Act 2022 significantly reformed the disclosure regime in NSW. The categories of disclosable conduct are broader. Protections for disclosers are stronger. Agencies with structural vulnerabilities in this space face real legal and reputational exposure, and a self-assessment is a useful moment to find out whether they have them.
Leadership is a legal, not just cultural, consideration
The Framework’s dedicated Leadership pillar reflects the OPSC’s view that ethical tone is set from the top. But leadership obligations are not merely aspirational. Under the GSE Act and applicable codes of conduct, senior officials carry active responsibilities in relation to workplace culture, the management of integrity risks, and the behaviour of those they supervise.
Where investigations or regulatory inquiries arise, the conduct of senior leaders, and the extent to which they modelled and enforced integrity standards, will be directly relevant. A poor result on this pillar is a governance issue, not an HR one.
Beware your blind spots
The action planning guide explicitly cautions against overuse of ‘not applicable’ responses. These answers are excluded from the score and do not generate action items, meaning genuine gaps could be masked. The guide notes that marking several measures as N/A can make overall results look stronger than they really are.
Agencies should approach N/A designations with care, document their reasoning, and consider whether a measure truly does not apply or whether it reflects an area of underdeveloped practice.
The Framework should not be completed in isolation
The OPSC encourages agencies to complement the self-assessment with the ICAC’s corruption control maturity guide, internal audit findings, and culture data. For agencies with known integrity risks, external support in designing and interpreting the assessment is worth considering. The most reliable results come from genuine discussion across different parts of the agency, not a desktop exercise completed by one team and signed off by another. Skilled facilitation that draws out the gaps between policy and practice, and unspoken assumptions, will drive the assessment process from good to great.
What Comes Next
The OPSC has designed the Framework as an ongoing process. Agencies are encouraged to repeat the self-assessment periodically and to share what they’ve learned, areas of strength and challenges overcome, with the broader sector.
For agencies completing it for the first time: nominate a senior leader to own the process, take the N/A caution seriously, and treat the action plan as a live document with named owners and real deadlines. Seek endorsement from the agency head or board, and build in accountability mechanisms that will survive a change of personnel.
The agencies that get the most from the Framework will be the ones that approach it as a genuine question about how they operate, not a process to be managed before the next audit cycle.
For further information, reach out to Kate Peterson and Nathan Leivesley. They practice in employment law and workplace investigations at McCullough Robertson, advising NSW public sector agencies on integrity frameworks, public interest disclosure obligations, and complex workplace matters.