National Licensing for Property Occupations Consultation Regulation Impact Statement

Removal of multiple licences held across jurisdictions

Under current licence requirements, licence holders must apply for a new licence if they wish to work in another state or territory. Initially, this involves both a time cost and the payment of licence fees. Under mutual recognition, a licence issued in one jurisdiction can be equivalent to a number of licences in another jurisdiction, with associated additional licence costs for the applicant. Subsequently, that person would need to renew their licence(s) in the jurisdiction(s) in which they are held, again involving time and fees. This is the case even when mutual recognition of a licence is granted (i.e. when a regulator determines that the applicant has an equivalent licence). These costs would apply regardless of how effectively mutual recognition is operating.

A key benefit of national licensing would be the removal of the requirement for licence holders to hold more than one licence to work in multiple jurisdictions. It would also remove the need to apply for a new licence when they relocated, as long as that licence holder held a valid national licence.

In order to estimate this benefit for licensees, data provided by jurisdictional regulators has been used to estimate the proportion of licence holders in each jurisdiction who also hold a licence in other jurisdictions. Table 4.8 shows this data, which picks up those licence holders who are transitioning from one jurisdiction to another (for instance, who may hold onto a second licence until it expires) as well as those who hold multiple licences over a long term (for instance, if they work or live in a border region).

Table 4.8: Proportion of licence holders in each jurisdiction who also hold a licence in another jurisdiction

Percentage	NSW	Vic	Qld	WA	SA	Tas	ACT	NT
% of existing licence holders	4%	4%	4%	1%	6%	12%	33%	10%

Note: The figures in this table represent the percentage of licensees who operate and are licensed in that jurisdiction, but reside in another jurisdiction.

The reduction in costs associated with holding multiple licences can therefore be estimated by taking the total number of licence holders incurring the cost, and estimating the avoided costs for these licence holders. This has been done using:

the number of licence holders who would be affected by the changes, which is estimated using the proportions of licence holders estimated as being required to hold more than one licence under current arrangements

data on property licence fees in each jurisdiction and an estimate of the time to apply for a licence (which would be avoided costs).

It is important to note the potential for mutual recognition applications to be more onerous (in terms of time and documentation required) than standard applications. To reflect this, the average time to apply for a licence is assumed to be higher under mutual recognition. See 4.2 and 4.3 for more detail on the approach to calculating this impact and the assumptions underlying it.

Using this approach, it is estimated that the total cost of holding multiple licences is about $2.30 million per annum or $14.98 million NPV over 10 years as at 1 July 2012. These costs would not be incurred under a national licensing approach, and therefore they are a key benefit of the national licensing option (as licence holders would no longer incur these costs). The distribution of this benefit across jurisdictions is shown in Table 4.9. Note that the benefits in this table have been attributed to the home state of licensees. For example, the benefit to New South Wales is the benefit to licensees who predominantly live in New South Wales but also hold licences in other jurisdictions. This attribution has been calculated based on migration flows. For further information on the assumptions underlying these estimates, see section 4.3.

Table 4.9: Benefit to licensees of no longer holding multiple licences across jurisdictions

$ million	NSW	Vic	Qld	WA	SA	Tas	ACT	NT	National
Annualised ongoing benefit	0.75	0.39	0.50	0.20	0.15	0.07	0.12	0.11	2.30
10-year NPV as at 1 July 2012	4.86	2.56	3.25	1.33	0.989	0.48	0.76	0.74	14.98

The impact on government

While removing the requirement to hold multiple licences delivers a direct benefit for licence holders, it represents a cost to government (through reduced revenue where there are fewer licences issued). Regulators would also be expected to realise some savings from a reduction in the number of licences issued, as they would no longer need to spend time processing those licences. However, it is noted that jurisdictional regulators will still incur the costs associated with compliance activities for licence holders who continue to work in their jurisdictions, but who are based (and pay their licence fee) in another jurisdiction. Therefore, given that the regulator would no longer be able to recover for activities that would continue to occur under national licensing, this would lead to a net cost for government, as the loss in revenue would be greater than the savings realised.

This cost is estimated to be about $0.93 million per annum (annualised across 10 years) or $6.05 million NPV over 10 years as at 1 July 2012. The distribution of this cost across jurisdictions is shown in Table 4.10.

Table 4.10: Impact on government from the removal of multiple licences across jurisdictions

$ million	NSW	Vic	Qld	WA	SA	Tas	ACT	NT	National
Annualised ongoing cost	0.25	0.10	0.27	0.02	0.10	0.001	0.17	0.02	0.93
10-year NPV as at 1 July 2012	1.60	0.62	1.76	0.15	0.66	0.01	1.13	0.11	6.05