The Government, through Water for Victoria has committed to actively monitoring water markets to ensure that they continue to operate effectively.

A key task in this is an annual audit of the water brokers who use the Water Register’s Broker Portal/API (“the portal”).  The audit helps to ensure that brokers meet their obligations to provide transparency of water trades and accurate price disclosure to all parties.

The portal allows brokers to lodge allocation trades on behalf of their customers online at a reduced cost. In most cases the portal processes trades instantly. In 2016-17 this service facilitated 8,810 allocation trades, or 69 percent of all trades.

In 2016-17, there were twenty-three brokers who had entered into an agreement with the Department of Environment, Land, Water and Planning (DELWP) to use the portal. Under the Agreement, brokers must comply with specific requirements when they use the portal.

DELWP engaged RSM to audit all 19 brokers who submitted trades during 2016-17 to make sure they complied with the Agreement.

RSM visited the sites of all 19 brokers being audited in Victoria, New South Wales and South Australia. The audit tested a representative sample of more than 2,086 transactions, evaluated the security of sensitive information and investigated the brokers’ knowledge of their responsibilities to their clients and DELWP.


The audit for the 2016-17 financial year is now complete.

The audit found that overall the control environment surrounding the Water Register interface is adequate, however for a small number of brokers, there are some matters with respect to the current Water Broker Interface controls and awareness that require further action to improve compliance with the Agreement.  In 2016-2017, the audit identified that, for a small number of brokers, there are some reoccurring issues that have not been rectified from previous audits.

The audit summary report is available below and presents the key findings of the audit and outlines DELWP’s risk-based framework for evaluating compliance.


Based on the results from previous audit years, DELWP has worked with RSM to develop a systematic approach to identify compliance issues, the associated risk of different breaches of the Agreement, and subsequent actions.

DELWP will notify each of the brokers who were audited to either close the audit or request further information or actions required to be undertaken based on the individual broker’s results.

Brokers will be given an opportunity to address the issues that have been identified throughout the audit process before any compliance action is undertaken. Subject to the response of each broker, DELWP will consider undertaking further compliance action to ensure brokers improve protocols to ensure ongoing compliance with the Agreement.