My and Randall Pryor’s recent policy brief describing the range and types of support available to Pacific Australia Labour Mobility (PALM) workers noted that country liaison officers (CLOs) are not as effective as they could be. I present below the evidence for this claim based on separate worker and employer survey results. I then examine why this is the case.
Most PALM workers do not view their CLOs as valuable intermediaries. The 2021–23 Pacific Labour Mobility Survey asked PALM workers from Kiribati, Tonga and Vanuatu two separate questions: to whom they would go for advice or help, and to whom they would report a complaint. Among short-term workers, just over one in ten said they would seek advice or help from a CLO. On complaints, short-term workers rarely nominated a CLO (3%), and were far more likely to nominate their team leader (49%) or their employer (33%). Among longer-term workers, fewer than one in 20 said they would report a complaint to a CLO, and the ranking of the other channels was much the same.
Approved employers do not have a positive view of CLOs and how they perform. The Approved Employers of Australia conducted a survey in 2025 of 35 approved employers who employed 12,235 workers, mostly in horticulture. The survey found that only one in five employers agreed that “CLOs help resolve issues involving PALM workers”. Also, only one in five employers agreed that “CLOs provide meaningful support to employers and workers”. For both statements: two in five employers gave a negative response and two in five employers gave a neutral response.
Two major obstacles stand in the way of CLOs seeking to be more effective. First, CLOs face at least three sets of different and often conflicting expectations about what their role involves. Second, although there are now 15 CLOs and two labour attachés, the number of CLOs relative to workers in Australia is low. The overall ratio of CLOs to workers is one to 1,872. Their scarcity, and also where CLOs reside, mean they are often located far from their workers.
The low ratio of CLOs to workers is an obvious problem. But merely increasing the number of CLOs will not increase their effectiveness if their roles are not clear. The more important issue is to identify the sources of the different and often conflicting sets of expectations CLOs face.
I can identify at least three different sets of expectations, belonging to the sending country government who is the CLO’s employer; the approved employer with whom the CLO is seeking to engage; and the Australian government, based on the support it provides to CLOs.
The following information is drawn from two interviews with CLOs, emails received from nine CLOs or labour attachés and feedback from two other stakeholders who have worked closely with CLOs.
First, consider sending-government expectations. The duty statements of the CLOs, where available, show similarities and differences in what is expected of a CLO. Based on information provided on the requirements of three sending governments, the key features of these documents are: (i) CLOs should provide culturally sensitive pastoral care to workers, (ii) CLOs need to liaise with approved employers and a range of Australian government agencies and (iii) CLOs need to report to their government through their high commission or embassy, or their labour ministry.
Second, approved-employer expectations depend on how CLOs negotiate their role with each approved employer. The employers are bound by welfare obligations to their workers as required by the PALM scheme Approved Employer Guidelines, the rulebook that sits alongside the Approved Employer Deed of Agreement and sets out what approved employers must do. Those guidelines say nothing about what the role of the CLO entails. Worker welfare is the responsibility of approved employers and the welfare and wellbeing support people they employ, with CLOs expected to be liaison officers only, engaging with workers through that person (PALM scheme Approved Employer Guidelines, version 2.1, para 9.1.1(l)). The implication is that CLOs are not expected to take on any direct welfare role for workers.
The third set of expectations that CLOs face are those established by the Australian Department of Foreign Affairs and Trade (DFAT). These have been recently spelled out in a document titled “Recommended PALM scheme Country Liaison Officers’ Terms of Reference”. The document is a draft and not published online; the PALM scheme website gives only a brief public description of the CLO role. It has been circulated to labour-sending units and heads of mission of sending-country diplomatic posts in Canberra, as well as to CLOs.
A covering email from the Pacific Labour Mobility Support Program (PLMSP) to the CLOs noted that “the purpose of these ToRs is to improve clarity and consistency of expectations of the role, for CLOs and relevant stakeholders”. DFAT advises that the proposed ToR is a guide only, with each sending country encouraged to change the terms of reference to meet its own requirements.
DFAT has a role in overseeing the support provided to CLOs through the PLMSP. This support includes funding for CLO travel within Australia and, for some CLOs, funding for their positions. An independent evaluation of the Pacific Labour Facility (2023) recommended that “DFAT should continue to resource through diplomatic missions in Australia an expanded gender-equitable network of Country Liaison Officers commensurate with the number and distribution of workers”. DFAT’s management response (26 March 2024) agreed with the “ambition of the recommendation”, noting that the Australian Government Budget 2023–24 included a commitment to resource additional CLOs in line with worker numbers.
At the same time, DFAT also noted that the OECD does not consider the funding of CLOs to be reportable as official development assistance (ODA). The management response stated that “DFAT will continue to work closely with participating governments to grow the number of CLOs, including the number of female CLOs, commensurate with the growth of worker numbers in the PALM scheme”.
DFAT’s terms of reference extend over five pages in language that is bureaucratic in tone and often vague in meaning. Most of the tasks DFAT expects of the CLOs are broad in scope and proactive in intent, such as regular workplace visits and monitoring worker welfare conditions. These tasks are well beyond what the existing number of CLOs can do. CLOs also lack the resources and capacity to make systematic assessments of worker welfare conditions.
The DFAT document also states, under its “key responsibilities” heading, an expectation that CLOs will not only “support PALM employer’s Worker Wellbeing Officers to provide culturally sensitive pastoral care… [and] engage with workers to build trust, monitor welfare conditions, identify welfare concerns early, and facilitate access to appropriate services” but also that they will “provide culturally appropriate welfare support to workers, including advice on how to access relevant support services and interpretation / translation services”. In effect, they are expected to liaise on welfare issues between their countries and relevant government agencies and PALM employers. This appears to muddy or infringe upon on the obligations of the approved employer and the role of welfare and support officers.
CLOs simply cannot be expected to take a longer-term, “preventive” approach to their work because of the strong pressure they are under to react quickly to the latest urgent demand. The key challenge in seeking to lift the effectiveness of CLOs is for them and their stakeholders to work out how they can best perform their jobs. As our policy brief on the welfare support arrangements for PALM workers noted, one way to do this is via annual end-of-year gatherings between CLOs and other key stakeholders, of the kind held in Victoria over the last three years. These meetings would enable CLOs collaboratively to develop realistic functions and achievable tasks that they have the capacity and resources to carry out and report upon.
