AMCA lodges submission to Productivity Commission’s National Competition Policy Analysis 2025 Interim Report

5 September 2025

AMCA's submission draws on the practical experience of the specialist HVAC mechanical services contractors we represent nationwide.

AMCA has lodged a submission in response to the Productivity Commission’s National Competition Policy Analysis 2025 Interim Report.

Our submission draws on the practical experience of the specialist HVAC mechanical services contractors we represent nationwide.

In our view, the Commission’s work on standards—particularly the focus on harmonisation and the recognition of the need for cheaper or free access to mandated standards—is well on track to deliver significant improvements for industry.

At the same time, we remain concerned that simply bolstering Automatic Mutual Recognition (AMR) will not deliver the long-term productivity benefits required. As outlined in our submission, national licensing must remain the central goal of reform, or at a minimum, aligning jurisdictional licensing to a common framework to suit AMR adoption.

We look forward to continuing to support the Commission’s important work.

Download AMCA's submission

Background

  • The Treasurer has asked the Productivity Commission (PC) to provide advice on reforms under the revitalised National Competition Policy (NCP).
  • Focus areas:
    1. Occupational licensing – particularly for high-risk professions such as electrical trades. 
    2. Adoption and harmonisation of international and overseas standards. 
    3. Other reforms that may promote competition.
  • Interim report has been published with feedback on interim report open until 5 September 2025. 

🔗 Read the interim report here

Key findings of the interim report

Economic impacts:

  • Reforms could lift GDP by up to 0.24%. 
  • Aligning standards with international/overseas equivalents: $1.9–3.8 billion per year (0.1–0.2% GDP). 
  • National labour mobility for high-risk licensed occupations: up to $846 million per year (0.04% GDP). 
  • Within this, the electrical trades could benefit by $51–62 million annually.

Standards:

  • Of 7,519 Australian Standards, 893 are mandated in legislation. 
  • 76% of these mandated standards are bespoke Australian-only, concentrated in manufacturing, construction, and technical services. 
  • 40% of referenced standards are outdated (superseded/obsolete). 
  • Only 26% of mandated standards are applied consistently across states and territories. 
  • Recommendations:
    • Harmonise standards nationally and with international/overseas benchmarks.
    • Review outdated standards in legislation.
    • Provide free or low-cost access to mandated standards (estimated cost: ~$7m annually to government).

Occupational licensing:

  • About 1 in 5 occupations in Australia require licensing (16% of the workforce). 
  • Current systems (mutual recognition and Automatic Mutual Recognition, AMR) improve mobility, but key gaps remain:
    • Queensland does not participate in AMR.
    • Many high-risk professions (e.g. electricians, plumbers) are excluded.
  • Recommendations:
    • Conduct an independent review of AMR (as agreed under National Cabinet).
    • Encourage jurisdictions to remove remaining exemptions.
    • Explore national licensing models where AMR is insufficient, especially for high-risk occupations.

Other reform areas (future NCP agenda):

  • Public procurement reform (potential savings: up to $4.7b).
  • Data sharing reforms ($1.6b benefit).
  • Road user charging reform (particularly important with the shift to electric vehicles).

Implications for AMCA Members

  • Standards: More consistent and streamlined use of standards across jurisdictions would reduce compliance burden, while free access to mandated standards would address a long-standing industry concern. 
  • Licensing: Moves toward greater portability of licenses nationally could reduce red tape for mechanical and electrical trades, enabling firms to deploy labour more flexibly across state borders. 
  • Competition reforms: Broader reforms (e.g. procurement and data sharing) could indirectly benefit construction and mechanical services through reduced costs and improved market efficiency. 

Next steps

  • Final report due to Treasurer by 31 October 2025.  

Here to help

📩 Email your feedback to the AMCA Policy team for inclusion in AMCA’s submission.