Chapter 7 explores Sourcing as another post-Budget phase of the IOF that supports the successful delivery of digital and ICT investments by providing several procurement mechanisms to achieve value-for-money and make it easier to engage the market for digital and ICT products and services. It will analyse the state’s strengths in using arrangements strategically to achieve policy objectives, use of framework agreements to leverage the buying power of government, provision of data-enabled insights to support better decision-making, and engagement and support to improve procurement behaviours. It will also analyse opportunities for the state to achieve stronger integration with the IOF, collaborate with the Department of Finance on broader consideration for digital and ICT sourcing, and in establishing a dedicated GovTech function to source more innovative solutions.
Digital Government in Australia
Abstract
The Sourcing state of the IOF helps agencies approach the market for their digital investments with the support of specialised procurement arrangements and guidance, brought together on a digital platform. This state has been strong in supporting policy objectives and better procurement outcomes, providing data insights, and improving procurement capability. However, there could be efforts to improve its integration with the IOF, broadening the scope of the state, and exploring the use of GovTech.
Sourcing is another of the post-Budget phases of the IOF that supports the successful delivery of digital and ICT investments by providing several procurement mechanisms that offer better value-for-money and make it easier to engage the market for digital and ICT products and services (DTA, 2025[1]).
Under its mandate, the DTA is responsible for managing whole of government digital procurement to simplify processes for government agencies, reduce costs and generate reuse opportunities. It also is expected to develop, deliver and monitor whole of government strategies, policies and standards for ICT procurement – as part of this broader responsibility for digital and ICT investments – as well as to provide strategic leadership and advice to the Government on this key policy area. . In this way, it works closely with the Department of Finance to ensure that digital procurement align with both policy compliance and strategic digital goals.
However, unlike in many countries (like Shared Services Canada or the National Procurement Service in Korea for example), the DTA does not execute this mandate as a centralised function that does the procurement process on behalf of the responsible agencies – rather it works as an enabling function by establishing and managing several procurement arrangements that are consolidated onto a single digital platform in BuyICT.gov.au described in more detail at Box 7.1 (Australian Government, 2021[2]; DTA, 2023[3]). It should be noted, however, that it is not mandatory for agencies to use all of the DTA’s procurement arrangements (though some are mandatory for certain agencies). Agencies can choose whether to run their procurements using other ways to approach the market, but most agencies do seem to prefer these channels – with an estimated 53% of total government spend on ICT and digital in 2024 transacted under the DTA’s marketplaces.
The procurement arrangements include several dynamic purchasing agreements (Marketplaces) to cover the breadth of digital and ICT products and services, including for hardware, software, cloud, datacentres, telecommunications, professional and consulting services, and ICT labour hire (DTA, 2025[4]). Each of these Marketplaces is established with an overarching agreement that sets out the terms and conditions of contracting under them, with flexibility for the agencies to define additional terms and requirements in each of the contracts that is entered into under the Marketplace. To add suppliers to the Marketplaces, a tender process is undertaken whereby the DTA approaches the market to seek applications and pricing for more specific sub-categories of products and services. Each applicant’s capability and value-for-money are assessed as part of pre-vetting the supplier before they are approved to transact under Marketplaces (DTA, 2021[5]). Regular approaches to market are undertaken to ‘refresh’ the Marketplaces – either to allow new suppliers to join and existing suppliers to update their offerings, or to dissolve the existing agreement and establish a new one with updated terms and conditions, categories, and suppliers (DTA, 2024[6]). As of December 2024, there were 4,259 approved suppliers across the Marketplaces and 268 agencies that were actively using them to facilitate their procurements – spending a total of almost AUD 31 billion (EUR 19 billion) to date (DTA, 2025[7]).
The DTA has also established several framework agreements with key vendors that either have a high level of existing demand within government or provided a strategic opportunity. At the time of writing, this included agreements with Microsoft, IBM, SAP, Oracle, Amazon Web Services, and Rimini Street (DTA, 2025[8]). These agreements aggregate demand across government – with all agencies working together as a single customer – with the aim of achieving better value-for-money and protections with these vendors than might otherwise be possible individually. Similar to the Marketplaces, they establish head agreements under which agencies will usually have individual contracts that address their specific needs (in addition to the overall protections). Given the significant level of spend with these vendors – which is now in the billions – these arrangements are a key mechanism in ensuring a cost-effective use of public resources, but also as a way to shift the market in supporting the key policy objectives.
Finally, there is limited integration of the Souring state with the rest of the IOF, as not all digital investments will make use of the DTA’s procurement arrangements. Despite this, the arrangements do capture a significant volume of spend, which has helped them become useful policy levers to improve procurement outcomes and achieve key policy objectives. The data that is collected on procurements can feed into the Strategic Planning, Prioritisation, and Operations states, but is not yet done routinely. In addition, there are emerging discussions around feeding data back into the Sourcing state to identify key areas or volumes of demand that might require new or updated procurement arrangements.
BuyICT.gov.au is the DTA’s digital procurement platform that consolidates its sourcing arrangements together to create a ‘one-stop-shop’ for digital and ICT procurement. The platform has several features that help to support agencies and suppliers to achieve better procurement outcomes:
Seller catalogue: BuyICT includes a searchable seller catalogue that agencies can use to research the market and determine which of the pre-vetted suppliers to invite to respond to their procurements. The catalogue includes an overview of the supplier’s information, capability, and compliance with Marketplace agreements. The catalogue also includes specific markers to provide visibility for small-to-medium and Indigenous-owned businesses to help agencies reach their procurement targets.
Guided procurement workflows: The DTA has worked to streamline and simplify procurement processes done through the platform to make it quicker and easier to buy and sell digital and ICT products and services. This includes guided procurement workflows that are built into the platform, which allow users to complete the entire procurement process in the platform and include prompts based on certain data inputs to remind agencies of policy requirements and good procurement practices. These workflows are used to improve overall compliance and procurement behaviours, but also as a lever to support better procurement policy outcomes around supporting SMEs and Indigenous-owned businesses.
Guidance, communities and capabilities: BuyICT also includes clear and simple guidance to support agencies and suppliers through the procurement process. This includes an overview of the relevant policies that they need to consider, as well as guidance on how to approach procurement in the right ways. Finally, the Digital Sourcing Network is a community focused on improving the confidence and capability of these users in using the BuyICT platform, selling to government, and navigating the digital and ICT procurement process.
Reports and insights: Each month, the DTA updates the Reports and Insights page of BuyICT with publicly-available data, including on the number of agencies and suppliers using the procurement arrangements, the number of contracts, and the volume of spend. This includes specific reporting on metrics for small-to-medium and Indigenous-owned businesses to help monitor progress against policy objectives.
Source: (DTA, 2025[4])
The strengths of the Sourcing state include its strategic use of arrangements to achieve policy objectives, its use of framework agreements to leverage the buying power of government, data-enabled insights to support better decision-making, and engagement and support to improve procurement behaviours.
Strategic use of arrangements to achieve policy objectives
In addition to facilitating procurements, the arrangements are a useful policy lever in achieving the Government’s objectives around improving the participation of small-to-medium and Indigenous-owned businesses, improving transparency and value-for-money in government procurement, supporting the public administration’s transition towards ‘Net Zero’, and exploring the potential of AI.
The Australian Government has implemented targets to encourage agencies to increase the proportion of contracts that go to small-to-medium and Indigenous-owned businesses (NIAA, 2023[9]; Department of Finance, 2025[10]). To help facilitate this, the seller catalogue on BuyICT (see Box 7.1) include markers to help agencies identify these businesses, as well as prompts in the procurement workflows to remind agencies of these targets. The entry requirements for the Marketplaces have also been minimised to help address any of the barriers that these businesses may encounter in trying to enter the government market. As a result, 51% of the registered suppliers on the Marketplaces are small-to-medium and/or Indigenous-owned businesses, with 53% of the overall spend on contracts also going to these suppliers (DTA, 2025[7]).
The DTA has also recently made a major update to its Digital Marketplace, which is used for digital and ICT professional and consulting services, and ICT labour hire. The new agreement included terms to introduce price transparency for ICT labour hire (rates and margins) and on the collection of candidate information to enable tracking of performance. These clauses are intended to improve value-for-money, encourage competition in the ICT labour market (DTA, 2024[11]).
Further, the Marketplaces’ head agreements can be used to support the public administration’s transition towards ‘Net Zero’ by including requirements on suppliers to use more sustainable practices. For example, to be approved to sell to government under the DTA’s arrangements, data centre providers are required to comply with emission thresholds, use renewable energy from accredited sources, maintain certain environmental ratings, and have a roadmap to meet net zero emissions (DTA, 2023[12]). As a considerable part of the environmental impact of digitalisation, this helps to minimise the government’s carbon footprint, but also to help shift the market towards greener practices.
Finally, the DTA recently used its framework agreement with Microsoft to explore the potential of generative AI. It negotiated a program of work for a 6-month trial of the vendor’s Copilot solution to evaluate its potential for use across the public administration, as well as potential risks around its safe and responsible use (Australian Government, 2024[13]). Having this framework agreement meant that the DTA could use its relationship with the vendor in a strategic way to be responsive to an emerging policy challenge.
Data-enabled insights for better decision-making
The DTA collects and publishes aggregate data on the use of its procurement arrangements. There is also a mandatory requirement in Australia in general for contracts to be reported on the Department of Finance’s AusTender platform, which provides a rich open data source on procurement spend across the public administration, as well as the product categories and suppliers on which it is being spent. Together, these data sources provide valuable insight into where the demand for digital and IT spend is across government (while somewhat limited still by the quality of the data reported). The data in AusTender is publicly available and is being used, as needed, in the Strategic Planning, Prioritisation, and Operations states of the IOF to help the DTA identify where there might be gaps or areas of pressure in the market that should be factored into decision-making – both to inform the sourcing strategies of future investments, but also where there might be areas that the Australian Government might need to invest in growing capability internally or together with other sectors.
Engagement and support to improve procurement behaviours
The DTA has also taken a proactive role in building the capability of both agencies and suppliers engaging in the procurement process, which is made publicly-available on the BuyICT platform. The platform includes information on the relevant digital and ICT policies that need to be considered as part of the sourcing strategy, as well as a sourcing framework – the Digital Sourcing Lifecycle – that guides agencies through a step-by-step approach to doing digital and ICT procurement in the right way (see Box 7.2) (DTA, 2021[14]). This is supported also by the DTA’s Digital Sourcing Network, which is a community of agencies and suppliers that the DTA supports by facilitating events and webinars on how to use BuyICT and the procurement arrangements, understanding procurement policies, and on how to sell to government (DTA, 2025[15]). The DTA also has a service desk that provides support and advice to the users of the BuyICT platform, as well as helping to review the compliance of procurements on the platform.
The Digital Sourcing Lifecycle is a simplified overview of the digital and ICT procurement process that was developed to guide agencies through its three main phases: plan, source, and manage. Each of these phases have steps with specific guidance that agencies can refer to throughout the process.
Plan: The Plan phase is around building the right foundation for a procurement. It advises agencies to refine the problem based on user needs, address digital specific considerations and risks, research the market, define requirements, understand which procurement approach and/or arrangements to use, and to consider more innovative sourcing approaches.
Source: Source is the phase where agencies approach the market. Here, the DTA advises agencies to request market responses, evaluate the responses to find the proposal that best meets the agency’s needs, obtain approval from the agency’s financial delegate, agree contracts and deliverables with the successful supplier, and to notify the unsuccessful suppliers of the outcome (including by providing meaningful feedback on the reasons why in order to improve future responses).
Manage: Finally, Manage is where the procurement becomes a contract that needs to be managed carefully to meet obligations and ensure successful delivery. The DTA advises agencies to consolidate records and maintain evidence of procurement decisions, manage the performance of suppliers and the outcomes of the contract, extend contracts only after considering supplier performance and value-for-money, and to consider the end-of-life of a contract to maintain continuity and avoid unnecessary costs.
Source: (DTA, 2021[14])
As the DTA looks to further develop the IOF, there is an opportunity to strengthen its Sourcing state by improving its integration into the IOF, by exploring broader considerations for digital and ICT sourcing and the IOF, and by using GovTech to provide a way to introduce more innovative procurement practices.
Stronger integration with the IOF
The four initial states of the IOF included Strategic Planning, Prioritisation, Contestability, and Assurance – the DTA’s responsibilities for whole-of-government procurement were therefore not part of the initial iteration of the DTA, meaning that the DTA is still exploring the ways in which the Sourcing state could and should support the delivery of the IOF. While the Sourcing state itself is mature and there is now data flowing to inform the work in the other states, external and internal stakeholders highlighted that there could be benefit in investing efforts to strengthen these linkages and use the horizon-planning that is happening in other states to understand demand and emerging priorities, so that the teams can determine how best to support the Government with the procurement arrangements that the DTA manages. The DTA should therefore improve the integration between these states to achieve this.
Broader considerations for digital and ICT sourcing
While external stakeholders reiterated its value, internal stakeholders raised that the Sourcing state is also currently limited by its focus on dynamic purchasing and framework agreements that are managed by the DTA. As not all digital and ICT procurement by government is required to go through these arrangements, there are likely to be missed opportunities around the advice, value-for-money offerings, and protections that the DTA offers through its negotiated agreements. For example, it is only mandatory for non-Corporate Commonwealth entities (i.e. most departments or agencies at the federal government level) to procure data centres and certain hardware and telecommunications categories through the panel, as well as when contracting with with Microsoft, IBM, SAP, Oracle, Amazon Web Services, and Rimini Street (DTA, 2025[8]). Therefore, government buyers can instead use other procurement pathways for products and services outside of these categories, especially when seeking to work with a service integrator that would deliver these to a government client as a package. However, regardless of the procurement pathway, contracts are still required to be reported by federal government departments and agencies on the AusTender platform managed by the Department of Finance, which is then made publicly-available.
Additionally, there is difficulty in linking procurement processes due to a lack of robust tracking mechanisms, which can limit oversight and benefits realisation, as well as limit understanding of the technology stack that was procured as part of the digital or ICT investment – particularly where the resultant contract was procured via a system integrator and not a particular product vendor. For example, both Chile and Korea have implemented advanced systems that enhance oversight, transparency, and benefits realisation in ICT and digital investment. In Chile, ChileCompra is the national public procurement system, and it includes a digital platform called Mercado Público, and the Observatorio ChileCompra, an oversight body that monitors procurement activities, identifies irregularities, and ensures compliance with procurement. In Korea, KONEPS is a fully integrated e-procurement platform that handles the entire procurement lifecycle and includes automated compliance checks, real-time data analytics, and interoperability with other government systems (e.g., tax, finance, and audit). For ICT projects, KONEPS tracks technical specifications, subcontractors, and delivery milestones.
Therefore, the DTA could collaborate further with the Department of Finance to develop policy levers to address these challenges, as well as additional data fields in the procurements and mandatory reporting of contracts on AusTender to help better track investments through their sourcing phase. This would be in line with the 2015 OECD Recommendation on Public Procurement, which recommends adherents to support the integration of public procurement into overall public finance management, budgeting and services delivery processes (OECD, 2015[16]).
GovTech to source more innovative digital solutions
GovTech is the collaboration between the public sector and start-ups, innovators, government “intrapreneurs”, and academia on innovative digital government solutions. It complements existing public sector capability for agile, user-centric, responsive, and cost-effective processes and services (OECD, 2024[17]). It is a form of challenge-based procurement that help agencies to explore, pilot and scale digital solutions – and by doing so, also invest in the development and growth of the local GovTech ecosystem.
While there are different models available, mature GovTech approaches see a centralised GovTech team or function within a public administration that would act as an independent advisory body to guide agencies on how to approach the market in a more innovative way to seek partners with which to collaborate on or co-design innovative digital solutions to solve key public sector challenges (OECD, 2024[17]). In this way, the centralised GovTech teams would engage with agencies to:
help define a challenge that they face.
provide advice on user research to help understand their needs and expectations.
develop an approach the market to seek ideas.
undertake a shortlisting phase based on pitches and proofs-of-concept.
provide guidance on how to collaborate with one of the shortlisted suppliers to co-design a pilot.
Once complete, there is often then consideration to determine whether the pilot could be scaled for full deployment and replication elsewhere, which can then be showcased by the centralised GovTech team for reuse across the public administration.
Some key GovTech models are outlined in Box 7.3, which includes Lithuania’s approach to running ‘GovTech challenges’ and acting as an accelerator program from the GovTech ecosystem, as well as Norway’s ‘StartOff’ program that allowed for innovative practices whilst maintaining fixed phases, terms, and funding to an offer a balance between agile delivery and more certainty on the cost and outcome.
As highlighted in the findings of the 2023 DGI, Australia currently does not have a GovTech function at the national level, which could be an opportunity for the DTA to foster innovation and grow its role in the strategic sourcing of digital and ICT solutions. To do this, the DTA could follow the OECD GovTech Policy Framework in Box 7.4. Building out a GovTech practice could be helpful in overcoming some of the challenges raised in Prioritisation, Contestability, and Assurance by creating opportunities to:
spend more time helping agencies to assess the feasibility of digital and ICT solutions.
provide an ‘off-ramp’ for urgent or unforeseen proposals that need be progressed in a particular budget cycle but are not yet sufficiently-developed for full-scale funding and deployment.
spend more time with agencies to provide assurance at the pilot stage.
This would be an extension of the role that the DTA currently plays in proving guidance to agencies and to suppliers on how best to undertake procurement processes but would require the DTA to take on more of an advisory role to agencies throughout the end-to-end process of a GovTech collaboration. However, having this function as part of the Sourcing state could also help to expand its focus beyond the procurement arrangements that the DTA manages and to better integrate its efforts more closely into the operations of the IOF in supporting the development and delivery of digital and ICT investments. It would also support the Australian Government’s intent to provide equitable access to procurement opportunities for small-to-medium and Indigenous-owned businesses to foster their participation in the market.
There could also be an opportunity for this GovTech function to work more closely with the Operations state, which has expertise on the Government’s technical domains, policies and standards, the areas of technical risk across the public administration, and the use of innovative technologies, like AI. Representatives from the Operations state could be embedded into the GovTech function that works with agencies to provide more technical advice in line with the Australian Government Architecture, as well as in supporting the Sourcing state to identify opportunities for the GovTech pilots to be replicated or scaled elsewhere across the administration to share innovative practices and improve the cost-effective delivery of digital solutions to address common challenges. Furthermore, in addressing this broad array of risks, the development of a national risk management strategy could also be a step to ensure a co-ordinated and consistent approach (OECD, 2023[18]).
However, external stakeholders did raise that the role of the DTA does not currently include the delivery of projects. Any consideration for how to establish a GovTech function within the public administration should therefore assess either the use of GovTech collaborations within the DTA as part of the IOF or whether the GovTech function would fit better within a delivery agency. Ideally, this would maintain linkages into or consultation with the IOF in order to use the value of these collaborations to support better delivery of digital or ICT investments, whilst still allowing the DTA to remain independent from the delivery of projects.
Therefore, the Australian Government could explore how a GovTech function could be established within the public administration to support agencies in collaborating with other sectors on more innovative digital solutions to address key public sectors in an agile way. Further, to extract the most value of such a practice for the IOF, the Government could consider how GovTech could be used to help assess the feasibility of solutions and agencies’ readiness to deliver them.
GovTech Lab in Lithuania
Lithuania’s GovTech Lab promotes public sector innovation by providing organisations with methods, tools, approaches, and resources to use technology to solve public sector challenges. It coordinates a structured program to define public sector challenges with agencies, call for solutions from the market, collaboratively test and develop proofs-of-concept, and then scale solutions for reuse.
The Lab also runs an acceleration program for start-ups and small-to-medium enterprise to mature their businesses and offerings to make them more viable partners for the government’s GovTech ecosystem.
Source: (GovTech Lab, 2024[19]; GovTech Lab Lithuania, 2024[20])
Norway’s StartOff: a model to balance innovation and risk
In Norway, the StartOff programme was based on a repeatable methodology that would deliver a solution within a defined 6-month process, from defining the challenge through to the delivery of a minimum viable product (MVP) of a solution. A key feature of the programme was its defined procurement processes, which companies are invited to submit idea sketches in response to the client’s ‘need’, with the best 6 sketches progressing to interview and then top 3 of those suppliers progressing to 3-week phase in which to develop a paid solution proposal. Finally, once a preferred supplier was chosen, they were engaged for a further 15 weeks to develop the MVP for a set fee of NOK 450,000. After that, the client could then conduct a standard procurement process to further develop the MVP or to explore other options. The StartOff model represents an effective approach to GovTech, which many countries could replicate to addresses some of the key challenges that they face in finding a balance between agile and innovative procurement and the responsible use of public resources.
Source: (DFO, 2024[21])
The OECD’s GovTech Policy Framework outlines the key building blocks and enablers on which governments can build their capacity for GovTech and maximise the impact of their collaborations:
The building blocks represent the foundations at the micro-level needed for more impactful GovTech collaborations, by introducing more agile practices, mitigating risks, and building meaningful collaboration with the GovTech ecosystem. These building blocks include:
Mature digital government infrastructure: including the technology, infrastructure, tools, and data governance to enable both GovTech collaborations and the digital solutions they develop.
Capacities for collaboration and experimentation: within the public sector, including the digital skills and multidisciplinary teams; agile processes tools, and methodologies; and a culture that encourages experimentation and accepts failure.
Resources and implementation support: considering how to make funding available, further develop procurement approaches, and scale successful pilots across organisations and internationally.
Availability and maturity of GovTech partners: including acceleration programmes to support start-ups growth by facilitating access to capital, the scaling up of solutions, and minimising barriers to access procurement opportunities.
At the macro-level, the enablers instead create an environment that fosters the development of GovTech and facilitates good practices. This is done at the:
Strategic layer: where governments could use GovTech strategies and champions in senior leadership positions to mobilise support and set a clear direction for GovTech.
Institutional layer: where governments could seek collaboration and knowledge-sharing across institutions at the national, regional, or policy levels.
Network layer: where both governments and GovTech actors use networks to strengthen the GovTech practice and garner broader support from communities.
Source: (OECD, 2024[17])
References
[13] Australian Government (2024), Australian Government trial of Microsoft 365 Copilot, https://www.digital.gov.au/initiatives/copilot-trial/summary-evaluation-findings/cts-executive-summary.
[2] Australian Government (2021), C2021G00267 - Order to identify the Minister responsible for the Digital Transformation Agency, and to Specify Functions for the Digital Transformation Agency, https://www.legislation.gov.au/C2021G00267/latest/text.
[10] Department of Finance (2025), Buy Australian Plan, https://www.finance.gov.au/business/buyaustralianplan.
[21] DFO (2024), StartOff, https://anskaffelser.no/innovasjon/startoff.
[4] DTA (2025), BuyICT, http://www.buyict.gov.au.
[15] DTA (2025), Digital Sourcing Network, https://www.buyict.gov.au/sp?id=capability_and_community&kb=KB0010687.
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[7] DTA (2025), Reports and insights, https://www.buyict.gov.au/sp?id=market_insights.
[1] DTA (2025), Sourcing, https://www.dta.gov.au/help-and-advice/digital-and-ict-investments/sourcing.
[6] DTA (2024), The Digital Marketplace Panel 2 is now open for applications, https://www.dta.gov.au/blogs/digital-marketplace-panel-2-now-open-applications.
[11] DTA (2024), The Digital Marketplace: What to expect from the Digital Marketplace Panel 2, https://www.dta.gov.au/blogs/digital-marketplace-what-expect-digital-marketplace-panel-2.
[12] DTA (2023), New Data Centre Panel, https://www.dta.gov.au/blogs/new-data-centre-panel.
[3] DTA (2023), Strategic sourcing made simple, https://www.dta.gov.au/blogs/strategic-sourcing-made-simple.
[14] DTA (2021), Digital Sourcing for Government, https://www.buyict.gov.au/sp?id=sourcingguidance.
[5] DTA (2021), Getting started as a seller, https://ictprocurement.service-now.com/sp?id=seller_getting_started.
[19] GovTech Lab (2024), GovTech Challenge Series, https://govtechlab.lt/govtech-challenge-series/#.
[20] GovTech Lab Lithuania (2024), What is GovTech Lab?, https://govtechlab.lt/about/.
[9] NIAA (2023), Indigenous Procurement Policy (IPP), https://www.niaa.gov.au/our-work/employment-and-economic-development/indigenous-procurement-policy-ipp.
[17] OECD (2024), Enabling Digital Innovation in Government: The OECD GovTech Policy Framework, OECD Digital Government Studies, OECD Publishing, Paris, https://doi.org/10.1787/a51eb9b2-en.
[18] OECD (2023), “Managing risks in the public procurement of goods, services and infrastructure”, OECD Public Governance Policy Papers, No. 33, OECD Publishing, Paris, https://doi.org/10.1787/45667d2f-en.
[16] OECD (2015), Recommendation of the Council on Public Procurement, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0411.