The Australian Resources and Energy Employer Association (AREEA) welcomes the opportunity to provide this reply submission in response to the Closing Loopholes: An Independent Statutory Review Draft Report (Draft Report) released on 15 May 2026.

AREEA remains of the view, consistently advanced in our March 2026 submission, that this review has been conducted too early to draw reliable conclusions about the real-world impacts of the most consequential reforms.

This reply submission responds directly to the Draft Report’s findings and recommendations on the three areas of most significant concern to our members: the regulated labour hire arrangement (RLHA) framework; workplace delegates’ rights; and the intractable bargaining declaration (IBD) regime.