Why Australia's Mining Sector Is Governing Its Biggest Cost Base With Its Weakest Controls
Financial risk has become the mining sector's top concern. The irony is that the greatest exposure often sits not in commodity prices; but in the AP function nobody is watching closely enough.
Australia's mining sector contributes more than 12% of GDP and generates around 70% of the nation's export earnings. CFOs in the sector face their most intense financial scrutiny in years. And yet the AP function; through which billions flow to contractors, equipment suppliers, and site service providers; is frequently governed by controls built for a different era and a different scale of risk.
The Risk That's Hiding in Plain Sight
KPMG's 2025 Australian Mining Risk Forecast, based on self-reported material risks from ASX 300 mining companies, found that financial risk has surged to become the sector's number one concern; overtaking commodity price volatility, climate risk, and geopolitical exposure for the first time.¹ The contributing factors most commonly cited are rising capital costs, inflationary pressure on operational expenditure, and tightening financing conditions.
But the risk conversation in most mining boardrooms is focused almost entirely on the external environment. The internal financial risk; the exposure that accumulates not from market forces but from how the organisation governs its own spending; receives far less attention than the scale of that spending warrants.
The metals and mining sector contributed 14.3% of Australia's GDP in 2024 and directly employs 300,000 people.² Behind that economic footprint lies an enormous contractor and supplier base; hundreds of active vendor relationships per site, processing billions in invoices annually through workflows that were never designed to govern the complexity they now carry.
Mining CFOs are focused on the macro risk. The micro risk; the contractor invoice, the progress claim, the vendor payment; is where money is quietly leaking, and where fraud finds its foothold.
Why Mining AP Is Structurally Exposed
The characteristics that make mining operations commercially complex are the same characteristics that make their AP environments structurally vulnerable. Three compound in particular.
Cost variation is operationally normalised. Scope changes, weather events, and equipment failures generate legitimate cost increases constantly. This creates dangerous cover for inflated billing. When a contractor invoice arrives higher than expected, the default assumption is that something changed on site; not that the invoice is wrong. The ACFE's 2024 Report to the Nations found billing schemes carry the largest median loss of any asset misappropriation category at $160,000 per case.³ In a mining context, individual invoices routinely exceed that figure; and inflated amounts go unquestioned as project exceptions.
Progress claims are legally enforced and hard to dispute. Security of Payment legislation across Australian states creates strict response windows for progress claims; generating genuine legal pressure to pay rather than scrutinise. Inflated percentage completions, billing for uncommenced scope, and double-counting across claim periods are mechanisms AP teams rarely have the contextual information to detect.
Remote operations fragment governance. Procurement decisions are made by site managers and project engineers with the authority to engage contractors but limited visibility into corporate AP policy. The distance between the point of commitment and the finance function is not just geographical; it is structural.
In an environment where cost overruns are expected and payment timelines are legally enforced, inflated billing doesn't trigger alarm. It gets approved as acceptable variance.
The Regulatory Environment Is Closing In
For mining CFOs who view AP governance as an operational matter rather than a strategic one, the regulatory trajectory is worth noting. The National Anti-Corruption Commission's published strategic priorities for 2025–29 explicitly include corruption involving contractors and consultants, and corruption in complex procurement.⁴ This extends to conduct by individuals acting in connection with Commonwealth-funded activities; which includes many mining projects supported by federal critical minerals programs.
The Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 introduced a new corporate offence for failure to prevent an associate from bribing a foreign official, with the AFP's Taskforce Solaris established in October 2025 to investigate such conduct.⁴ In a sector characterised by international contractor relationships and joint venture structures, the accountability chain now reaches further into the organisation than most CFOs have mapped.
The pattern is consistent with what regulators are communicating across the broader economy: procurement integrity in contractor-heavy environments is no longer a matter for internal audit alone. It is a governance responsibility, and increasingly a personal one for the executives who sign off on it.
From PO Matching to Real-Time Payment Governance
The shift required is not a more comprehensive audit schedule. It is embedding controls at the point of payment rather than reviewing them weeks later.
In practice, that means three things. First, validating invoices against the commercial terms of the contract that governs them; not just the PO that initiated them. Rates, scope definitions, milestone conditions, and variation approval requirements all live in contracts, not purchase orders. The gap between the two is where overbilling is invisible. Second, running anomaly detection continuously across the full contractor base; identifying billing patterns that cluster just below approval thresholds, invoices from vendors with no matching PO history, and progress claims submitted at suspiciously consistent intervals regardless of actual site progress. Third, maintaining vendor data as a live asset: ABN verification, bank account validation, and entity name checks that operate at the payment run, not at the onboarding stage twelve months prior.
This is the capability This is the capability RedOwl delivers for complex, high-volume AP environments. By capturing and preserving the full context of every vendor relationship; contracted terms, payment history, verification status, approval decisions; RedOwl gives mining finance teams the organisational memory required to govern contractor spend at scale: knowing not just that a payment was approved, but why, against what terms, and whether those terms were actually met.
For a sector where financial risk is now the number one strategic concern, the question is whether AP governance is keeping pace with that risk. For most mining operations, the honest answer is no. The invoice that nobody checked against the contract is where the gap starts; and where it compounds, quarter after quarter, until someone goes looking.
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- KPMG Australia. (2025). Australian Mining Risk Forecast 2025. Retrieved from https://kpmg.com/au/en/insights/industry/australian-mining-risk-forecast.html
- Gilbert + Tobin. (2025). 2024 Year in Review and 2025 Outlook: Navigating a Complex Metals and Mining Landscape. Retrieved from https://www.gtlaw.com.au/insights/2024-year-in-review-and-2025-outlook-navigating-a-complex-metals-and-mining-landscape
- Association of Certified Fraud Examiners (ACFE). (2024). Occupational Fraud 2024: A Report to the Nations. Retrieved from https://www.acfe.com/report-to-the-nations/2024/
- A&O Shearman. (2025). Australian Regulators Intensify Enforcement of Bribery, Money Laundering and AI-Driven Fraud. Retrieved from https://www.lexology.com/library/detail.aspx?g=a79d3347-99d2-47b4-9431-5f78de69534e
- Minerals Council of Australia. (2025). Economic Policy: Mining's Contribution to the Australian Economy. Retrieved from https://minerals.org.au/policies/economic-policy/
- Mining Technology / GlobalData. (2026). Australian Mining Industry: 2025 Review. Retrieved from https://www.mining-technology.com/features/australian-mining-industry-2025-review/
This article is intended as a thought leadership piece for finance, risk, and governance professionals. Statistics and figures cited are sourced from publicly available third-party research and regulatory publications.

