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Australia’s Privacy Act Reform

Australia’s Privacy Act Reform Round 2 Is Coming — Get Your SAP Access Controls Audit-Ready Now

Round One Wasn’t the Whole Story

When the Privacy and Other Legislation Amendment Act passed, the Australian Government agreed to only 38 of the 116 recommended changes from its own Privacy Act Review, and agreed “in principle” to another 68 that were never implemented. Government commentary has been consistent that this second wave of reform is expected during 2026 — and that it will likely be more prescriptive and more onerous than what businesses have already adapted to.

For organizations that treated the first round as the finish line, that’s an uncomfortable surprise sitting on the near-term horizon.

What’s Already in Motion

  • The OAIC has been tasked with developing a Children’s Online Privacy Code, due by December 10, 2026
  • A new statutory tort and doxxing offence provisions have already reshaped what counts as reportable harm
  • “Reasonable steps” to protect personal information now explicitly include technical and organisational measures — not just policy documents
  • The OAIC holds expanded powers to issue infringement and compliance notices directly

The SAP Angle Most Compliance Teams Miss

Privacy Act obligations live and die on one operational question: can you prove personal information is only accessible to people who need it, and that access is actively monitored? For Australian enterprises running SAP, that’s rarely a policy gap — it’s a visibility gap. Access reviews happen annually, custom tables holding personal data go unmapped, and segregation of duties conflicts sit unnoticed for years.

“Technical and organisational measures” as a regulatory phrase points directly at systems like SAP, where the actual data lives and the actual access decisions get made.

Building a Defensible Position Before Round 2 Lands

  • Move from annual to continuous access reviews across SAP modules holding personal data
  • Document Segregation of Duties controls with evidence, not assumptions
  • Build a sensitive-data map covering standard and custom SAP tables
  • Generate audit-ready reports proactively, so a compliance notice doesn’t trigger a scramble

Be Ready Before the Rules Tighten Again

SimpAudit gives Australian enterprises real-time SAP access visibility and audit-ready reporting — built to keep pace with a Privacy Act framework that’s still evolving. Book a free demo to see your current exposure.

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Australia's Privacy Act Reform

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