The new APP 1.7 automated-decision transparency requirement commences 10 December 2026 — what it asks of businesses using AI to make significant decisions, and how to prepare.
dgm is an independent osFoundry integration partner — not affiliated with osFoundry’s maker (OS LLC), and dgm has no completed client integrations yet.
A genuinely new obligation is coming for AI in Australia: from 10 December 2026, privacy policies must disclose automated decisions that significantly affect people. Here is what the new APP 1.7 asks — and why to prepare now.
| Item | Detail |
|---|---|
| What | New APP 1.7 — disclose ADM in your privacy policy |
| When | Commences 10 December 2026 (scheduled, not yet in force) |
| Trigger | Automated decisions that significantly affect an individual’s rights/interests |
| Enforcer | OAIC (existing infringement/compliance-notice powers apply) |
What APP 1.7 requires
A new APP 1.7, added by the 2024 privacy reforms, will require an APP entity that uses computer programs to make (or substantially and directly assist making) decisions that could reasonably be expected to significantly affect the rights or interests of an individual to disclose this in its privacy policy, using personal information. It is a transparency obligation, not a ban on automated decisions.
When it commences
It is a delayed commencement: 10 December 2026 (about 24 months after the 2024 Act’s assent). As of mid-2026 it is scheduled but not yet in force — so you have time to prepare, but the date is fixed. Once it commences, the OAIC’s infringement and compliance-notice powers (live since December 2024) apply to a non-compliant privacy policy.
How to prepare
Inventory where AI makes or materially assists significant decisions (credit, hiring, eligibility, pricing), and plan privacy-policy disclosures and supporting governance. Building explainability and audit logging now makes the December 2026 disclosure straightforward. osFoundry’s managed cloud pins data to the US, EU or Japan — it does not currently offer an Australian managed region. For data that must stay in Australia, the honest path is self-hosting osFoundry (BYO Cloud) inside an Australian cloud region such as AWS (Sydney or Melbourne), Microsoft Azure (Australia East, Australia Southeast or Australia Central in Canberra) or Google Cloud (Sydney or Melbourne), or running models locally on-device.
Where dgm fits
dgm is an independent integration partner that helps Australian businesses adopt osFoundry — scoping a first use case, handling the build, and connecting AI to the systems you already run. dgm is independent of osFoundry’s maker (OS LLC) and has no completed client integrations yet, so everything described here is a service offered, not a past result. If you want to scope a practical first project, dgm can help you map it out.