Insights · Article
Beyond self-assessment: the Regulator Maturity Model and ANAO lessons
Assessing maturity is the beginning of the conversation, not the end.
The Department of Finance’s Regulator Maturity Model is a welcome addition to the toolkit for Commonwealth regulators. It describes regulator capability against the Regulatory Policy, Practice and Performance Framework and the best practice principles in RMG 128 Regulator Performance. It sets out 12 capability domains across six principles, and four maturity levels: Emerging, Developing, Embedded and Leading. A self-assessment tool lets regulators see where they sit.
This matters. A common model gives regulators, departments, ministers and audit committees a shared language for talking about capability. It also helps regulators see their strengths and gaps across areas such as risk-based regulation, engagement, transparency and governance, use of data and continuous improvement.
But a maturity rating, on its own, doesn’t change anything.
Assessing maturity is the beginning of the conversation, not the end
Self-assessment tells you where you think you are. It doesn’t tell you why, and it can be optimistic. The ANAO’s insights on auditing regulatory activities point to consistent lessons: where regulators fall short, it’s rarely because they lack a framework or policy on paper. It’s because of gaps between intent and practice. Risk frameworks aren’t consistently applied. Performance measures don’t show whether regulation is achieving its outcomes. Data isn’t used to target effort. Agreed improvements aren’t followed through.
These are the kinds of issues a self-assessment can miss, because they sit in how work is actually done day to day, not in what documents say.
From rating to action
That’s why I think of maturity assessment as the first of three steps:
- Assess maturity: understand where the regulator sits, using evidence rather than perception alone, and test the self-assessment with the people doing the work and those affected by it.
- Diagnose causes: ask why. Is a gap about systems, capability, governance, culture or resourcing? Fixing a symptom without understanding its cause means the same issue comes back.
- Plan action: prioritise a realistic set of improvements, assign ownership and track them through to outcomes, so the next assessment shows genuine progress.
Done well, this turns a compliance exercise into a practical improvement plan, and gives leaders and audit committees confidence that the regulator is getting better at what matters.
The maturity model gives regulators a strong starting point. The opportunity now is to use it as a catalyst for honest diagnosis and real improvement, not as a score to report and file.
Stop fixing symptoms. Start fixing systems.
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