Government Advertising and Communications

Agency communications

We found examples of government communications managed by DPC and DGS that were inconsistent with the apolitical requirements of the Act:

• the Premier's media centre website contains party-political content (see Case study 1)
• the community attitude research survey commissioned by DPC asks respondents to rate government performance (see Case study 2).

The Premier's media centre website is hosted on the Victorian Government's Single Digital Presence (SDP) platform. DPC established the government-funded SDP in 2018 and set up the Premier's media centre website on the SDP platform, for the Premier's office.

DGS became responsible for the SDP in 2023. DPC and DGS advised that they are not involved in the operation of the website and that the Premier’s office manages the content.

Using public resources

The Victorian Government's digital guides provide guidance to the public service about when to publish ministerial content and outline relevant regulations and codes of conduct. It requires that agencies should not:

• have any involvement in the operation of a minister's personal website or social media platform
• prepare material or content specifically for a minister's personal website or social media platform.

The use of public resources, including staff time or publicly funded content, for political purposes is inconsistent with the apolitical requirements of the Act regardless of whether the final content includes explicit political sentiment.

Suburban Rail Loop Authority

Agencies should not use public resources to create tailored content for ministers' personal social media accounts.

SRLA provided documents that explicitly guided staff to develop content solely for ministers' social media channels.

It also provides monthly social media content to its Minister and local MPs to promote the Suburban Rail Loop. In the project's social media strategy, the SRLA team develops tailored content for the Minister’s channels each week and maintains a monthly content compilation from Suburban Rail Loop sites for government use – including tailored posts for local MPs to support coordinated project messaging.

Agencies can appropriately support ministers by directing them to content already published on official agency channels. But creating, tailoring or adapting content solely for politicians' personal websites or social media accounts is not an appropriate use of public resources and is inconsistent with the apolitical requirements of the Act and digital guides.

SRLA advised us that they have removed the word 'tailored' from their strategy. However, the SRLA's continued use of public resources to prepare content specifically for ministers' personal social media accounts is inconsistent with the Act and does not meet public expectations of an apolitical public service.

Department of Transport and Planning

DTP provided documents that explicitly guide staff to develop content solely for ministers' social media channels. DTP advised that the guidance we assessed is now no longer being used.

Based on the information provided by DTP, we remain concerned that DTP has not clearly articulated a position that staff should refrain from creating, drafting or preparing content for publication on ministers' personal social media accounts. Such activity is prohibited under the Victorian Government's digital guides.

We identified its current guidance could be clarified to set clear boundaries for staff.

Advertising channels

Since our 2022 audit, the way the government communicates has changed.

Figure 2 shows that government spending on television advertising has declined since 2023. The government now spends more on digital channels and social media.

Guidance

Despite the government increasing its use of digital channels and social media, existing guidance remains largely principles-based and does not provide agencies with specific direction on managing compliance with legislative and policy requirements when using these channels.

The government has policies and guides about managing public websites and social media accounts. But these policies and guides do not outline:

• how agencies should engage social media influencers
• what disclosure requirements should apply when influencers communicate public messages on behalf of a public sector agency
• the Act and other legal requirements that agencies should follow
• agencies' responsibility for ensuring content created by third parties meets requirements
• the expectation that agencies retain sufficient control and oversight over how their digital content is used, shared, republished or distributed by third parties.

Social media influencers

Agencies publish content on their own social media channels. They also increasingly work with social media influencers to help share messages.

Agencies may use influencers to reach new audiences or communicate with specific groups of people.

Agencies should ensure influencers clearly disclose government involvement so that audiences understand where the communication is coming from.

Controlling output

Agencies remain responsible for ensuring communications shared by influencers meet relevant requirements. But the level of control agencies have over the content they create varies depending on the type of engagement.

Figure 3 outlines the different ways agencies engage social media influencers.

Figure 3: Examples of how agencies work with influencers and what they produce

Source: VAGO.

Paid or sponsored posts

Social media content shared by influencers engaged by the government is a form of government advertising. Agencies may pay influencers directly or provide in-kind benefits, such as brand exposure, goods or exclusive access to projects.

We selected samples of social media posts created by social media influencers based on a paid arrangement with agencies. We assessed whether:

• agencies had arrangements in place to help ensure the posts complied with the Act
• government sponsorship or paid promotional arrangements were clearly disclosed to audiences.

We did not find any social media posts that were not compliant with the Act. But agencies did not consistently require disclosure of government involvement.

Influencer disclosure

We found agencies require influencers to disclose government involvement in social media content in different ways. For example:

• identifying both the influencer and the agency as authors (Figure 4)
• using a 'paid partnership' label (Figure 5, although as at 6 October 2026 the ‘paid partnership’ label has since been removed from this post)
• including the hashtag '#ad' in the content (Figure 5)
• tagging the agency's account in the post using '@' (Figure 4 and 6).

Requirement of disclosure varies

The examples below illustrate less and more mature approaches to requiring disclosure of government involvement in influencer content.

Figure 4: Example of a paid post without clear disclosure of government involvement

Note: The influencer's post is referenced for context only. This example assesses how agencies managed and controlled publicly funded communications, not the conduct of the individual who created the content. This post did not use '#ad' nor label 'paid partnership'. DTP's account appeared on the post as 'co-author' and tagged in content.
Source: Instagram, posted by 'izziewhitecreative'. Accessed in February 2026. This image was edited to improve resolution but the original content is unchanged. This social media content was commissioned by DTP.

Figure 5: Example of a post where government involvement is clearly disclosed using 'paid partnership' and '#ad' labels

Note: The influencer's post is referenced for context only. This example assesses how agencies managed and controlled publicly funded communications, not the conduct of the individual who created the content.
Source: Instagram, posted by 'queenacknowledgements'. Accessed in June 2026. This image was edited to improve resolution but the original content is unchanged. This social media content was commissioned by the Department of Education (DE).

Figure 6: Example of a paid post that did not disclose it was a government advertisement

Note: The influencer's post is referenced for context only. This example assesses how agencies managed and controlled publicly funded communications, not the conduct of the individual who created the content.
Source: Instagram, posted by 'tiffanys.album'. Accessed on 5 May 2026. This image was edited to improve resolution but the original content is unchanged. This social media content was commissioned by VIDA.

Political reuse risk

Agencies often seek to maximise the reach and effectiveness of social media content by encouraging resharing, including by MPs and ministers through their personal social media channels.

We identified several instances where agency-produced content was repurposed without attribution to the original source (see case studies 3, 4 and 5). Agency social media content was repurposed in ways that illustrate risks of political reuse.

We found examples where agencies' existing controls did not prevent the repurposing of content created using public resources, including:

• content not consistently branded with clear government branding or attribution
• agencies not applying measures that require attribution when content is shared or reused.

Agency-produced digital and social media content is a public resource. While agencies cannot fully control how content is used once published, stronger governance arrangements would help to:

• promote clear attribution to agencies
• support stakeholders to share existing agency-branded materials, such as stakeholder communication packs or links to agency-published content
• prevent content from being repurposed for actual or perceived political purposes.

We found examples of better practice from agencies sharing digital content with stakeholders, including publicly available social media communication packs with approved, non-tailored messaging, and ministers resharing agencies' social media posts without modifying the original content (Figure 7).

Figure 7: Example of agency content being shared with clear attribution to original post

Note: The shared post retained the Department of Health’s original message, branding and link to information.
Source: Facebook, posted by Harriet Shing MP. Accessed on 24 July 2026.

What these examples show

These examples show that when agency-produced content is shared without clear government branding or strict attribution requirements, it can easily be repurposed for political purposes. This may weaken public confidence that government communications are impartial and produced solely in the public interest.

Other types of influencer engagement

Apart from direct payment, agencies also engage influencers or commercial brands by providing in-kind benefits. For example, providing exclusive access to a project or content, or brand exposure.

Agencies may engage influencers through partnerships, sponsorships or invitations to exclusive events. These arrangements may result in influencers sharing content about government initiatives on their social media channels.

Government policy and industry practice

The Victorian Government Sponsorship Policy, which also covers partnership agreements, requires that 'agencies providing sponsorship must ensure that the sponsored organisation provides public acknowledgement of government support'.

Ad Standards, Australia’s advertising regulator, states that 'influencers must disclose any arrangement with a brand to help followers distinguish between advertising content and user generated content… it’s not just where money changes hands – free products or services indicate a relationship that should be disclosed too.'

Ad Standards recommends that influencers disclose any arrangement in a way that is visible and easy to understand, for example by adding hashtags to content (such as #ad, #PaidPromotion, #sponsored) or using platform disclosure capabilities.

Across the cases we assessed, agencies did not have a consistent approach for requiring influencers, content creators or partnered brands to disclose these sponsorship or in-kind benefits. Governance arrangements for sponsored content disclosure have not kept pace with industry best practice.

Further details can be found in case studies 6 and 7.

Permitted purposes

The Act permits television advertising only for a limited set of purposes. Some permitted purposes for general government communications are not listed for television advertising, as Figure 15 shows.

Noncompliant advertising

We selected 9 case studies across 7 agencies for detailed analysis. Two campaigns included television advertising that did not meet the Act or DPC’s requirements.

Government communication and advertising can often serve multiple purposes. For our audit, where a communication appeared to serve multiple purposes, we considered its dominant purpose when assessing whether it met the Act’s television advertising requirement.

Television advertising

In 2017, Parliament amended the Act to include additional restrictions on television advertising.

The amendments introduce permitted advertising purposes. They distinguish campaigns that promote ‘public safety, personal security or behavioural change’ from those that inform the public about government policies and projects, or encourage the use of government services. This indicates that Parliament intended these purposes to be treated differently.

Unclear definition led to broad application

We identified different applications of the 'public safety, personal security or behavioural change' purpose across agencies. For example:

• VIDA applied the behavioural change purpose to its Metro Tunnel and West Gate Tunnel opening campaigns because by promoting new infrastructure, it encouraged Victorians to shift the way they travel
• DPC applied the behavioural change purpose to its cost-of-living campaign because it encouraged Victorians to use the government's 'Savings Finder' tool
• Victoria Police applied the same purpose to its recruitment campaign, on the basis that recruiting police officers contributes to community safety outcomes.

In our view, the above behavioural change campaigns more closely align with informing the public about a government project or encouraging the use of a government service. Similarly, recruitment is a distinct purpose and should not be broadly characterised as promoting safety.

These examples illustrate how, in the absence of a clear definition, the behavioural change purpose can be interpreted broadly in ways that may extend beyond Parliament's intended purpose. This risks weakening the Act's tighter controls on television advertising and makes compliance difficult to assess.

Campaign compliance

Of the 9 campaigns we assessed, 7 clearly complied with the Act and DPC’s requirements. This is an improvement since our last audit, particularly as most agencies:

• met the Victorian Government communication requirements on multicultural media and regional media spend
• evaluated their campaigns within 3 months of campaign conclusion.

Risk-based approach

The AAG is chaired by DPC and comprises senior communications executives from departments and representatives from the Premier's office. The AAG plays a key role in reviewing and endorsing agency campaign proposals and assessing campaign strategies and materials for compliance before approval.

In our 2022 audit, we recommended that DPC and agencies adopt a risk-based approach to assessing compliance with the Act.

DPC has since included a new step where the AAG should identify 'high-risk' or 'sensitive' campaigns and require agencies to seek independent legal advice.

DPC defines 'high-risk' or 'sensitive' campaigns as 'any campaigns that could be, or be perceived to be, non-compliant with legislative requirements'.

We found that the new approval step is not working as intended because the:

• definition of 'high-risk' or 'sensitive' was unclear, without objective measures
• definition was documented for the AAG but not shared with agencies, limiting agencies’ visibility of the criteria that may trigger additional scrutiny
• AAG is not required to document its assessment or rationale when deciding that a campaign is not high risk, reducing transparency of decisions
• AAG did not identify any campaigns as high risk or sensitive during the past 2 years.

This is despite the fact that:

• in our 2022 audit, we identified that campaigns about transport infrastructure projects carry higher risk of not complying with the Act, and there were several similar campaigns during the past 2 years
• by-elections during this period, and the pending state election, increase the risk of campaigns being perceived as indirectly or directly influencing voting behaviour.

Conflict-of-interest process could be improved

AAG members may at times review campaigns that were proposed by their own department. To manage conflicts of interest, DPC requires representatives from the sponsoring agency to withdraw from the endorsement process.

We identified a gap in this process. DPC's cost-of-living campaign promoted the Savings Finder service, which was developed and operated by DGS. While DPC's representative withdrew from the process, the campaign was endorsed by a DGS representative. The conflict-of-interest process did not address the perceived conflict arising when an agency is involved in endorsing a campaign that promotes its own product or service.

Without appropriate conflict-of-interest controls, perceived bias in campaign endorsement decisions may undermine confidence in the effectiveness and integrity of the role of the AAG.

DPC's reporting

DPC reports annually on the Victorian Government’s advertising spending and whether it meets policy targets.

When we started our audit in December 2025, the latest published Government Advertising Report was for 2022–23. During the audit, DPC published the 2023–24 report (in March 2026) and the 2024–25 report (in August 2026). DPC had not established a defined timeframe for publishing these reports, which limited transparency and timely access to information.

Budget Paper output

From 2021 to 2026, one of DPC's departmental objectives was to 'maintain compliance with government advertising and communication guidelines to support effective financial management, probity, and accountability of government advertising’.

DPC's measure for this objective was 'relevant communication activity compliant with government advertising and communication guidelines'. This measure was reported as 100 per cent compliant since 2021–22, for 4 consecutive years. DPC advised that they calculated 100 per cent based on 'campaign advertising' endorsed but not on other government communication.

This limits the usefulness of the output measure because it focuses on approved campaign advertising rather than the broader scope of government communications covered by the Act.

Meeting reporting requirements

DTF's FRD 22 requires agencies to report on campaign advertising spend (with a media buy over $100,000).

DGS has not published its campaign spend in its annual reports for the past 3 years.

DFFH and DH did not follow the latest reporting format required. They included figures for 'actual spend' but did not include approved spend for each campaign.

Record keeping

Most agencies followed the FRD 22 requirement, but not all of them have a traceable record of their campaign spend to support the accuracy and completeness of their reported figures.

We tested agencies' annual report figures for 2023–24 and 2024–25.

Three agencies (DEECA, DTP and VIDA) provided the underlying records that informed their reporting, but not in a form that allowed recalculation. This means we were unable to verify whether the figures reported in the annual report were accurate.

Advertising definitions

Agencies report annually on campaign spending, depending on the amount spent and whether the activity is classified as 'campaign' advertising. But existing government definitions of 'campaign' versus 'non-campaign' advertising no longer reflect how agencies classify and use advertising in practice.

Source: DPC's requirements.

Existing government guidance defines functional advertising as text-based, short-duration, and requiring less creative input than campaign advertising.

However, we observed examples of advertising classified as 'functional' or non-campaign that shared characteristics commonly associated with campaign advertising (Figure 20).

Figure 20: Examples of ‘functional’ advertising that shares characteristics with campaign advertising

Source: VAGO.

These examples suggest that current agency practices have expanded beyond the traditional characteristics of functional advertising reflected in government guidance. This means existing definitions may not consistently capture the range of activities that agencies classify as functional advertising. This reduces the comparability and transparency of reported advertising activity and spending.