Comparing Regulatory Capability Frameworks: Insights for Regulatory Agencies
This guest editorial for the ANZSOG-auspiced National Regulators Community of Practice (NRCoP) has been written by Jane Hudson, Founder and Director, JBass Learning and Dr Grant Pink, Pracademic Advisor to the NRCoP.
Introduction
In the first article, The Benefits of a Distinct Regulatory Capability Framework: Moving Beyond Organisational Capability Frameworks (ANZSOG, 2025), the authors argued that a dedicated ‘Regulatory Capability Framework’ used alongside an ‘Organisational Capability Framework’ is essential for agencies to effectively manage and develop their regulatory capabilities.
In this article, the authors compare three regulatory capability frameworks (RCFs) to examine how government-level frameworks can inform the design of agency-specific RCFs. The frameworks are briefly outlined below:
Regulatory Services Technical Capability Framework (the New Zealand Framework, 2021)[i] – a national model defining the core skills, knowledge, and behaviours required of regulatory professionals. Provides a structured, level-based approach with clear behavioural indicators. It positions regulation as a distinct profession.
Regulatory Policy, Practice & Performance Framework (the Australian Framework, 2025)[ii] – a high-level, principles-based benchmark for regulatory quality. Rather than defining capability levels or career pathways, it sets out what “good regulation” looks like across the full regulatory lifecycle with a focus on consistency, proportionality, risk-based decision-making, and continuous improvement. While operating with a different level of focus, it provides a useful reference point for agencies developing their own RCFs.
Core Regulatory Skills Framework (the UK Framework, 2026)[iii] – a cross-sector framework that defines essential skills and competencies for regulatory professionals, with structured progression and clear behavioural expectations. It emphasises technical capability and professional judgement including risk-based decision-making, ethical practice, communication, and enforcement, to strengthen consistency and capability across regulators.
Together, these frameworks operate at different levels of focus. Where the New Zealand and UK frameworks emphasise practitioner skills and behaviours, the Australian framework focuses on system-wide expectations of “good” regulatory practice and delivery across the regulatory lifecycle.
For agencies designing or refining RCFs, these frameworks provide a clear, evidence-based, foundation for testing and validating key design choices. Considering them helps ensure that RCFs are grounded in established good regulatory practice rather than developed in isolation.
Themes and capabilities
The frameworks define a range of themes and capabilities, spanning:
ten technical capabilities;
six principles; and
twenty skills (across five themes).
Table 1 – Overview of the three frameworks
Click here to download the table.
Analysis of Framework Strengths and Differences
To illustrate how these frameworks can inform agency-level RCFs, we examine three capabilities that are common across all three. They are:
Regulatory practice
Regulatory systems
Regulatory communication
We also briefly discuss a fourth capability, which the authors consider to be fundamental to all regulatory work: Regulatory decision-making.
While assumed or alluded to in each of the frameworks, regulatory decision-making is not explicitly set out and is therefore effectively missing. We argue that regulatory decision-making should be recognised as a distinct capability, because it is precisely what regulators do and has immediate and tangible impacts on regulated entities.
1. Regulatory Practice
Shared Themes Across the Three Frameworks
All three frameworks position regulatory practice as being grounded in risk-based, proportionate, and evidence-informed decision-making. Each recognises the importance of using regulatory tools in a targeted rather than routine way and emphasise that regulatory actions should be guided by data, information, intelligence, and evidence.
How the Three Frameworks Differ
Key differences lie in how they link evidence, risk, and professional judgement—ranging from day-to-day practice to system-wide integration, to shared professional standards across regulators. These differences are expected, as each framework serves a different purpose. Taken together, however, they offer complementary insights that can support more informed decisions for RCF design.
The New Zealand Framework considers regulatory practice through the daily application of tools and risk-based decision-making.
The Australian Framework takes a more integrated, system-wide approach. It connects policy, implementation, and performance into a single regulatory landscape, where risk is used strategically to guide targeting resources to have the greatest impact.
The UK Framework places strong emphasis on consistent professional practice across regulators. It focuses on shared skills and judgment, with evidence and risk underpinning structured, proportionate decision-making to ensure alignment and coherence across the system.
2. Regulatory systems
Shared Themes Across the Three Frameworks
Collectively, the frameworks recognise that effective regulatory systems require integrated policy, delivery, and oversight, supported by clear governance, roles, and accountability. They also emphasise the use of data and intelligence to improve performance and align intent with implementation, and highlight that regulatory effectiveness depends on aligning people, processes, and tools across and within agencies, and across the wider regulatory system.
How the Three Frameworks Differ
Differences emerge in how each country designs and operates its regulatory systems, particularly in terms of governance arrangements, how consistency is achieved, and what drives system improvement.
The New Zealand Framework focuses on regulatory systems at the frontline, with distributed governance and a strong emphasis on practitioners driving improvement through day-to-day practice.
The Australian Framework takes a more structured, end-to-end view of regulation as an integrated system spanning policy design, implementation, and performance. Governance is formalised, with clear stewardship responsibilities, and improvement is driven by evidence, evaluation, and structured feedback loops.
The UK Framework emphasises consistency across regulators, promoting alignment through shared standards, skills, and approaches to ensure a coherent and joined-up regulatory system across different domains.
3. Regulatory Communication
Shared Themes Across the Three Frameworks
Regulatory communication is a core capability that underpins trust, compliance, and effective regulatory outcomes. It should be clear, concise, complete, correct, and consistent, with a strong focus on explaining requirements, decisions, and expectations in accessible ways for regulated entities, stakeholders, and the wider community. It is a two-way process that supports procedural fairness and strengthens transparency, consistency, and confidence in regulatory decision-making.
How the Three Frameworks Differ
Differences arise from the level at which communication is framed, ranging from individual practice, through agency-level coordination, to profession-wide standards set by regulators.
The New Zealand Framework operates at an individual level – it focuses on how frontline regulators explain decisions, engage directly with people, and manage day-to-day interactions using clear, practical communication skills that support effective on-the-ground delivery.
The Australian Framework is positioned at an agency level –it emphasises how agencies share information across regulatory bodies, engage with stakeholders, and use feedback and data to improve transparency, coordination, and overall regulatory performance.
The UK Framework sits at a profession-wide level – where communication is treated as a core professional capability, with an emphasis on clear, consistent, and well-structured messaging to ensure regulatory decisions are understandable, fair, and applied consistently across different regulators.
4. Regulatory decision making
As noted above, the authors consider regulatory decision-making as a distinct, standalone capability. It underpins the lawful, consistent, and defensible exercise of regulatory powers, drawing on specialist skills and a high degree of professional judgement. Regulatory decision-making is the core function of regulators, anchored in legislation and directly affecting the rights, obligations, and interests of regulated entities.
Implications for Regulatory Agencies
Analysis of the New Zealand, Australian, and UK frameworks, highlights several important implications for regulatory agencies seeking to develop or enhance their own RCFs. The following table highlights three key implications for regulatory agencies.
Table 2– Key implications for regulatory agencies
Click here to download the table.
Conclusion
This article highlights that RCFs are tools to be adapted, not adopted wholesale. A useful starting point for agencies is to consider four simple questions:
Why is the RCF needed?
Who is it for?
What is it intended to achieve?
How will it improve regulatory delivery and outcomes?
These questions support more intentional design and practical application, ensuring RCFs are grounded in contemporary regulatory practice rather than developed in isolation.
The New Zealand, Australian, and UK frameworks each bring distinct strengths. For example, the:
New Zealand Framework provides practical, role-specific guidance
Australian Framework presents a principles-based benchmark that articulates what “good regulation” looks like across the entire regulatory system
UK Framework offers a structured professional development pathway.
All three frameworks can—and should—be adapted and scaled to suit specific regulatory operating environments, with “less is more” serving as a guiding principle for agency-level RCFs.
Effective RCFs are practical and usable, and as concise as they need to be. Design choices matter because they directly shape how regulatory capability is understood, developed, and applied in practice. These choices are not neutral. Those responsible for designing, developing, and maintaining RCFs—including senior leaders, HR and L&D professionals, regulatory managers, executives, and boards—should actively involve regulatory practitioners to ensure RCFs are grounded in operational reality and fit for purpose.
Taken together, these insights point to a broader international shift in how regulation is understood as a profession. Countries such as New Zealand, Australia, and the UK are increasingly recognising regulatory work as a distinct professional field, supported by communities of practice, professional networks, and clear RCFs.
As regulation is increasingly recognised as a profession in its own right, the value and importance of RCFs is no longer optional or easily overlooked.
Article prepared by:
Jane Hudson, Founder and Director, JBass Learning.
Jane has 30+ years’ experience across the public, private, and not-for-profit sectors, specialising in learning and development for regulatory agencies at state and national levels. For over 20 years, she has partnered with government regulators to strengthen capability, culture, and frameworks that drive regulatory excellence.
A recognised expert in regulatory learning and capability, Jane translates complex regulatory concepts into practical, engaging, and impactful learning and development strategies. She has authored articles and academic publications on learning and regulatory capability and taught Instructional Design at the Australian Institute of Training and Development (AITD).
Academically, Jane holds a Master of Adult Education (Global) and a Bachelor of Adult Learning and Development from Monash University and is a certified PRISM Brain Mapping practitioner. She is the founder and director of JBass Learning, a specialist consultancy delivering tailored capability solutions for regulatory agencies.
Dr Grant Pink, Pracademic Advisor ANZSOG NRCoP, Managing Director RECAP Consultants, and Adjunct Professor (Regulation and Enforcement) University of Tasmania.
Grant has more than 30 years regulatory and enforcement experience spanning practitioner, management, executive, academic, and consultancy roles, operating at local, state, national and international levels.
Grant has written more than forty articles for practitioner and academic publications in the areas of regulatory practice, capacity building, networking, and collaboration. In 2021 he authored the book Navigating Regulatory Language: An A to Z Guide, updating it to a second edition in 2025.
Academically, Grant has a MA by research in regulatory and enforcement networks (2010), and a PhD which considered how regulators build, maintain, and sustain regulatory capability and capacity (2017). In 2016 Grant founded RECAP Consultants Pty Ltd (RECAP). RECAP is a specialist regulatory consultancy providing services domestically and internationally.
References
Australian Government Department of Finance. (2025). Regulatory policy, practice & performance framework. https://www.finance.gov.au/sites/default/files/2025-10/Regulatory-Policy-Practice-and-Performance-Framework.pdf.
New Zealand Ministry for Regulation. (2021). Regulatory services technical capability framework: Information and guidelines. https://www.regulation.govt.nz/publications-and-resources/resource-library/regulatory-services-technical-capability-framework/
Pink, G. (2025) Navigating Regulatory Language: An A to Z Guide. RECAP Consultants Pty Ltd: Canberra.
UK Department for Business and Trade. (2026, February 3). Core regulatory skills framework. https://www.gov.uk/government/publications/core-regulatory-skills-framework.
Endnotes
[i] New Zealand Ministry for Regulation. (2021). Regulatory Services Technical Capability Framework: Information and Guidelines. https://www.regulation.govt.nz/publications-and-resources/resource-library/regulatory-services-technical-capability-framework/
[ii] Australian Government Department of Finance (2025), Regulatory Policy, Practice & Performance Framework. https://www.finance.gov.au/sites/default/files/2025-10/Regulatory-Policy-Practice-and-Performance-Framework.pdf.
[iii] UK Government Department for Business and Trade (2026, February 3). Core Regulatory Skills Framework. https://www.gov.uk/government/publications/core-regulatory-skills-framework
