Submission to the National Competition Council Review of Australia’s Mutual Recognition Schemes

Submitted by
Jason Sexton, Principal Security Management Consultant, GuardHERE Consulting – March 2026

This submission outlines the experience of security businesses operating under the current mutual recognition framework and proposes reforms to improve mobility while retaining appropriate safeguards.


KEY RECOMMENDATIONS

1. Simplify Interstate Licence Recognition

Where a worker already holds a valid security licence in one jurisdiction, interstate recognition should involve a streamlined verification process. Recognition should focus on confirming the validity of an existing licence and relevant probity checks rather than repeating parts of the licensing assessments.

2. Establish Clear National Licence Equivalency Guidance

The Commonwealth, states and territories should develop a nationally consistent licence equivalency framework identifying comparable licence categories across jurisdictions. Clear guidance on equivalent licence classes would reduce uncertainty for workers, employers and regulators.

3. Introduce Consistent Processing Timeframes

Mutual recognition applications should be processed within clear national service benchmarks. Defined processing targets would improve certainty for workers seeking interstate employment and businesses attempting to deploy staff across jurisdictions.

4. Reduce Administrative Duplication

Where appropriate and legally reasonable, regulators should recognise probity checks already completed by another jurisdiction, including police checks, identity verification and fingerprinting processes. Reducing duplication would lower administrative burden while maintaining appropriate safeguards.

5. Develop a National Digital Recognition Portal

A single national portal allowing workers to apply for mutual recognition across jurisdictions would simplify access to recognition pathways and improve efficiency for regulators.

6. Explore Long-Term National Licensing Options

While immediate improvements to mutual recognition should be prioritised, governments should consider whether a national security licensing framework could provide a longer-term solution to fragmented licensing systems.


EXECUTIVE SUMMARY

GuardHERE Consulting supports reforms that strengthen labour mobility across Australia by improving the operation of mutual recognition schemes for licensed workers.

The private security industry provides a clear example of how the current mutual recognition framework can create unnecessary barriers for workers and employers. Security licensing in Australia is regulated at the state and territory level, with each jurisdiction operating its own licensing system, licence categories, probity requirements and administrative processes.

While mutual recognition pathways technically allow licence holders to seek recognition in other jurisdictions, the practical process can be complex, slow and costly. Security workers and employers often face duplicated administrative requirements, delays in processing, inconsistent licence equivalency frameworks and additional probity checks that may already have been conducted by another regulator.

These barriers can restrict labour mobility, delay workforce deployment and impose unnecessary compliance burdens on both workers and employers.

The private security industry is particularly affected by licensing fragmentation because it frequently requires workforce mobility across jurisdictions. Security personnel are routinely deployed for national events, infrastructure projects, major public venues and other operations where labour demand may fluctuate significantly.

Ensuring that licensed security workers can move efficiently across jurisdictions is therefore important not only for labour mobility but also for the operational resilience of sectors that rely on security services.

GuardHERE Consulting supports reforms that simplify recognition processes, improve consistency between jurisdictions and reduce administrative duplication while maintaining strong regulatory safeguards.


INDUSTRY PERSPECTIVE

GuardHERE Consulting works with security businesses on licensing compliance, operational planning and workforce deployment. Through this work, the business regularly assists security operators navigating state and territory licensing frameworks.

The observations outlined in this submission reflect practical issues reported by security businesses operating in multiple jurisdictions, particularly in relation to interstate workforce mobility, licensing duplication and administrative delays. These insights are provided to support the review’s objective of identifying practical pathways to remove unnecessary occupational licensing barriers while maintaining appropriate public safety standards.


ABOUT GUARDHERE CONSULTING

GuardHERE Consulting is a Victorian advisory business specialising in security industry licensing, compliance and operational management.

The business works with security companies, providing guidance on regulatory compliance, licensing obligations and workforce management. Through this work, GuardHERE Consulting regularly assists security businesses in navigating state and territory licensing frameworks.

This experience provides direct insight into how current mutual recognition arrangements affect security companies and workers attempting to operate across jurisdictional boundaries.

GuardHERE Consulting does not supply security guards directly. However, the business works closely with companies that do, many of whom experience operational and administrative impacts resulting from fragmented licensing systems.


THE SECURITY INDUSTRY AND LABOUR MOBILITY

The Australian private security industry relies heavily on workforce flexibility. Security personnel are required for a wide range of environments including major events, infrastructure protection, commercial premises, retail environments and government facilities.

Demand for security personnel can fluctuate significantly due to:

  • major events
  • seasonal demand
  • emergency responses
  • infrastructure projects
  • workforce shortages in certain regions

In these circumstances, businesses may need to mobilise personnel from one jurisdiction to another.

Private security is one of the few licensed occupations that routinely supports national mobility through major events, infrastructure projects and critical site operations. Ensuring that licensed security personnel can move efficiently across jurisdictions is therefore important not only for labour mobility but also for the operational resilience of sectors that rely on security services.

Despite the existence of mutual recognition schemes, the current licensing framework can make interstate deployment unnecessarily difficult.


CURRENT CHALLENGES WITH MUTUAL RECOGNITION

Fragmented Licensing Structures

Although many licence categories perform similar functions across jurisdictions, they are not always structured or defined in the same way.

This lack of consistency creates uncertainty when determining whether a licence issued in one jurisdiction is considered equivalent in another.

In practice, this can lead to additional administrative processes or delays when workers seek recognition of their licence interstate.

Administrative Duplication

Security licence holders seeking to work in another jurisdiction may face administrative requirements that duplicate checks already undertaken in their home jurisdiction.

These may include:

  • repeated background checks
  • additional identity verification processes
  • fingerprinting requirements
  • new licence applications rather than streamlined recognition processes

Where these requirements are repeated despite an existing licence, they create additional cost and delay without necessarily improving safety outcomes.

Delays in Processing

In practice, recognition applications can take several weeks to process depending on the jurisdiction and licence category involved.

For security businesses responding to short notice operational needs, these delays can effectively prevent interstate deployment of licensed personnel.


INDUSTRY EXAMPLES

Interstate Event Staffing

Security businesses frequently provide services for large events that attract national audiences. These events may require security personnel from multiple jurisdictions due to workforce demand (e.g. the Olympic Games).

However, companies report that delays in obtaining interstate licence recognition can prevent qualified staff from being deployed in time for short-term contracts.

Where recognition processes take several weeks, businesses may be forced to limit staffing options or decline opportunities despite having licensed personnel available.

Cross-Border Workforce Movement

In regions close to state borders, workers may live in one state but seek employment in another.

Security licence holders relocating for employment opportunities often encounter administrative barriers when attempting to have their licence recognised in the new jurisdiction.

Although mutual recognition pathways exist, the application process can still involve significant documentation requirements, fees and delays.

These barriers may discourage worker mobility even where the underlying occupation and training requirements are broadly similar.


IMPACT ON WORKERS AND EMPLOYERS

The current system can create several unintended consequences. Workers may find it difficult to take employment opportunities in other states despite already holding equivalent licences.

Security businesses may be unable to deploy qualified staff quickly where they are needed. Smaller operators may be particularly affected because they lack the compliance resources required to navigate multiple regulatory frameworks.

In some cases, these barriers may reduce competition and limit workforce availability. These outcomes run counter to the broader objective of creating a more integrated national labour market.


RECOMMENDED REFORMS

  • Simplified Mutual Recognition Process

Recognition processes should be straightforward, transparent and low cost. Where a worker already holds a valid licence in one jurisdiction, recognition in another jurisdiction should focus primarily on verifying the existing licence rather than repeating full licensing processes.

  • National Licence Equivalency Framework

A nationally consistent framework identifying equivalent licence categories across jurisdictions would significantly improve clarity. Such framework would assist regulators, employers and workers in understanding recognition pathways.

  • Faster Processing Timeframes

Recognition applications should be processed within clear and consistent timeframes. Establishing national service benchmarks would improve certainty for workers and employers.

  • Portable Probity Checks

Where appropriate and legally permissible, probity checks such as police checks and fingerprinting should be portable across jurisdictions if they are current and have already been assessed by another regulator. This would reduce duplication while maintaining appropriate integrity safeguards.

  • Digital National Recognition Portal

A single national portal allowing workers to apply for mutual recognition across jurisdictions would simplify access to recognition pathways. This portal could allow regulators to verify licences electronically and streamline administrative processes.


CONSIDERATION OF A NATIONAL SECURITY LICENCE

While improvements to mutual recognition should be prioritised in the short term, governments may also wish to consider whether a national security licence framework could provide longer-term benefits.

A national licensing system could:

  • eliminate duplication between jurisdictions
  • improve workforce mobility
  • simplify regulatory compliance
  • support a more consistent national labour market

If full national licensing is not feasible in the near term, greater harmonisation of state licensing frameworks would still represent a significant improvement.


CONCLUSION

The private security industry provides a practical example of how fragmented licensing systems can create barriers to workforce mobility despite the existence of mutual recognition frameworks.

Workers who are already licensed and vetted in one jurisdiction should be able to work in another jurisdiction through a simple and efficient recognition process.

Reducing unnecessary administrative duplication while maintaining strong regulatory safeguards would support a more flexible and responsive security workforce.

GuardHERE Consulting supports reforms that simplify mutual recognition, improve consistency across jurisdictions and strengthen the effectiveness of Australia’s national labour market.

GuardHERE Consulting would welcome further engagement with the review if additional industry perspectives from the private security sector would assist the evaluation process.

Reference: Review of Australia’s Mutual Recognition Schemes for workers – Australian Treasury.


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