Should we make a submission?

Not-for-profit organisations often have opportunities to make submissions in response to inquiries and reviews, and many spend considerable effort in preparing and lodging responses to these.

The question of whether to make a submission may best be addressed by reference to a few principles, framed as simple questions.

We can learn from the Tasmanian Government in this regard, as their Department of Premier and Cabinet has crafted a set of principles to help line agencies and central agencies decide whether or not to invest resources in a submission.  The following is an adaptation of those principles which may assist your not-for-profit organisation when faced with the question of whether a submission is warranted.

Will preparing a submission:

  • contribute to our policy objectives? (Is it a high priority issue for us?)
  • be of strategic benefit to our stakeholders/community? (Could the submission position us well for future discussions/negotiations?)
  • add value for us given the effort required? (Do the benefits of making a submission outweigh the resources necessary to prepare and lodge the submission?)
  • mitigate significant risk? (Also, what is the risk of not making a submission?)

Usually your decision will be based on answering more than one of these questions, however, in some instances, a single principle will suffice to justify your response.

A submission may not be the most appropriate response in the circumstances, so you might also consider what other measures are justified.  Also, a submission is likely to only ever offer one element of a campaign plan designed to achieve your policy objective.

The process to be adopted when preparing a submission will depend on your resources (people, time and money), but that’s the subject of another article for another time.

Remember the current offer of free and confidential phone advice on your advocacy campaign plans, which is available until 8 December.  If you would like to take advantage of this offer, just send me your preferred phone number and a pdf copy of your campaign plan documentation addressed to and I will ring you within a week for up to 20 minutes of phone advice.

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Garry Pearson

Garry is the Director of PolGovPro Pty Ltd (, which aims to improve the quality and effectiveness of policy and governance processes used by NFP professionals.

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