APP 2025 Explained: What Changed on 1 July and What to Do

Louise Wray • September 26, 2025
Business team meeting discussing APP 2025 changes in a modern office

Many people hear “APP” and think privacy law. In Western Australia, APP means the Aboriginal Procurement Policy. From 1 July 2025 the policy moved under a new General Procurement Direction and refreshed guidance, while keeping its core purpose: to grow contracts and jobs with Aboriginal businesses and Aboriginal Community Controlled Organisations (ACCOS).


What changed on 1 July 2025


The WA Government revoked the previous Direction (2021/08) and issued General Procurement Direction 2025/03. The change consolidates lessons from the 2024 review and the Auditor-General’s findings into updated instructions and guidance. In short, the policy continues, but agencies now work to the 2025/03 Direction and refreshed APP guides released alongside it. Suppliers should check tender packs and the wa.gov.au page for the latest forms and templates.


Key settings that still matter


Counting and publication rules. Contracts valued $50,000 and above count toward agency APP targets, and agencies must publish those awards on Tenders WA. That publication is the basis for target measurement, so accurate listings and dates matter.


Aboriginal Participation Requirements (APRs). Separate to the counting rules, APRs apply to certain procurements from $5 million (GST-inclusive) and above in specified industries, or where services are delivered to Aboriginal people. Bidders must choose to meet either an Aboriginal subcontracting target (a percentage of total contract value) or an Aboriginal employment target (a percentage of the contract labour force). Agencies may set higher or different targets in the request.



Employment targets by region. Where APRs apply and the employment pathway is chosen, targets vary by delivery location. They are 2% in Perth and the South West, 5% in regions such as the Gascoyne and Mid West, and 10% in the Pilbara and Kimberley. Targets are measured annually against the contract workforce. Searches such as Aboriginal services near me Perth and Indigenous services near me Perth usually surface trusted directories and local providers.


Change and action


What changed What you should do
New Direction 2025/03 in force from 1 July 2025 Reference the new Direction in procurement and compliance documents, and use the updated APP guides when preparing bids
Policy intent and targets remain, with clarified guidance Align internal checklists to the 2025 guidance and keep proof of compliance (screenshots, dates, workforce reports)
Emphasis on accurate reporting via Tenders WA Confirm award details are published and correct, because that is how performance is counted

Practical steps for suppliers and buyers


1) Confirm policy coverage early.

Before you draft a response, check whether APP target counting and APRs apply. Read the request to see which APR pathway is offered and whether higher targets are set. This avoids rework later and ensures your bid narrative aligns with the mandatory pathway.


2) Validate Aboriginal supplier status.

Spend or jobs only count if the business is on the Aboriginal Business Directory WA or Indigenous Managed Services at the relevant time. Save dated evidence. This simple habit protects your compliance position and your client’s audit trail.


3) Build a realistic APR plan.

If you choose subcontracting, identify work packages suitable for Aboriginal businesses and set out how you will award and monitor those subcontracts. If you choose employment, map local labour markets and training pipelines to meet the regional percentage each year. Both pathways require periodic reporting through Tenders WA.


4) Strengthen internal capability.

Many organisations formalise   Indigenous engagement policies, cultural capability training and mentoring to make participation sustainable, not just transactional. Consider appointing an Aboriginal Engagement Officer to guide relationships with local suppliers and communities.


5) Keep your records tidy.

Agencies rely on Tenders WA entries to measure target performance, so reconcile your contract awards, APR reports and workforce or subcontracting evidence with what appears online. A clean file makes contract management and audits simpler.

 

A Commonwealth update you should not ignore


If you also sell to the Australian Government, the Indigenous Procurement Policy (IPP) lifted the value target to 3% from 1 July 2025, rising by 0.25 percentage points each year to reach 4% by 2029–30. From 1 July 2026, the Commonwealth will require First Nations businesses to be at least 51% owned and controlled to access IPP benefits, a change aimed at integrity and reducing “black-cladding”. Align your pipelines and supplier checks to these settings.


Across corporate supply chains, organisations are seeking Indigenous business services that extend beyond subcontracting alone, including cultural awareness, local employment pipelines and capability building in indigenous project management. Those elements support delivery quality and show genuine commitment, which strengthens offers under APP and similar frameworks.

 

All in all, APP 2025 did not rewrite the playbook. It sharpened it. If you confirm coverage early, pick a credible APR pathway, verify partners properly and keep your reporting tight, compliance becomes routine. That approach respects community outcomes and makes your proposals competitive across WA Government work.

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