Australian Industry Group has made a submission to the Queensland Government's Strategic Review of the Queensland Human Rights Commission and related reviews of Queensland's human rights and anti-discrimination framework, including the Strategic Review of the Queensland Human Rights Commission Discussion Paper.

Australian Industry Group considers that Queensland's human rights and anti-discrimination framework should provide clear legal standards, fair and efficient processes and proportionate obligations that are practical to implement.

We do not support a further expansion of protected attributes and the existing discrimination tests, and burden of proof should be retained. The combination of attributes amendments should not commence unless a deficiency is demonstrated that cannot adequately be addressed through existing provisions and the complaints process.

Australian Industry Group also opposes the commencement of the proposed Queensland positive duty and the conferring of related regulatory and enforcement functions and a power to investigate potential systemic contraventions of the ADA on the Queensland Human Rights Commission, whether immediately or through staged implementation. Existing Commonwealth and Queensland obligations differ in their purposes, scope and enforcement mechanisms. Those differences require consideration of the cumulative compliance task rather than an assumption that an additional duty would merely restate existing requirements.