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Report 6156

Associated Incidents

Incident 11935 Report
Purportedly Taxpayer-Funded Deloitte Report for Australian Government Contains Alleged AI-Generated Citations and Fabricated Legal Quote

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Deloitte report suspected of containing AI invented quote
afr.com · 2025

New errors have been found in a major report Deloitte prepared for the federal government, raising further suspicions some of the content was generated by artificial intelligence.

On Friday The Australian Financial Review revealed that Deloitte's report for the Department of Employment and Workplace Relations on welfare compliance systems, which cost taxpayers $439,000, contained at least half a dozen references to academic works that do not exist.

The welfare academic who discovered the incorrect references, Chris Rudge, has found the report also contains an apparently invented quote from the decision in a leading robo-debt case, Deanna Amato v Commonwealth.

Deloitte said that in that case "Justice Davis" (a misspelling of Justice Davies) had said at paragraphs 25 and 26: "The burden rests on the decision-maker to be satisfied on the evidence that the debt is owed. A person's statutory entitlements cannot lawfully be reduced based on an assumption unsupported by evidence."

No such quote appears in the consent orders issued by Federal Court Justice Jennifer Davies on November 27, 2019 -- in fact, the orders do not contain a paragraph 25 or 26. Another quote, cited as drawn from paragraph 30, actually comes from paragraph 9.

In three places, Deloitte cited the Amato case as "[2021] FCA 1019". In fact, that citation refers to an unrelated migration case (CKL21 v Minister for Home Affairs).

Rudge told the* Financial Review *that he can find "no source" for the quote, leading him to conclude it had been generated by AI.

"It is one thing to [incorrectly] cite academics or to impute works to scholars that do not exist, it is another to [incorrectly] cite judges and thus to misstate the common law of Australia in an advice to the Commonwealth government," he said.

Rudge also noted that Amato concluded with consent orders, rather than a judgment.

"The fact that the report not only fails to identify this historical legal fact but also treats Amato as a decided case indicates at best carelessness and, at worst, the authors' complete unfamiliarity with the conduct of this pivotal case."

Deloitte declined to answer questions about whether AI was used to write the report and follow-up questions about the errors in citation of Amato. The firm previously stood by the report and promised to correct errors in its references.

After the Financial Review revealed Deloitte had cited two works by Lisa Burton Crawford and one by Carolyn Adams that do not exist, the consultancy supplied a new list of references, including three other chapters by Burton Crawford in edited works.

The co-author of two of those chapters, UNSW law faculty Associate Professor Janina Boughey, said the new references do not necessarily support the propositions in the Deloitte report.

Boughey said the works "don't provide support" for one citation but "might provide support" for two others "though not in any particularised way".

"The statements don't seem to have been drawn from a reading of our work," she said.

"It's fairly obvious that at least some of the references have been generated by AI, as they simply don't exist.

"If I were DEWR, I'd be asking for an explanation, and be reluctant to pay for work that has been generated by AI. I also wouldn't be using Deloitte again in the near future. Public funds have been used to pay for a report which lacks integrity."

Boughey said she would "almost certainly" refer a student paper for integrity concerns if it contained such errors.

Burton Crawford said she agreed with Boughey's conclusions about the new source list. "Insofar as those publications support the claims made in the report, it is only in a very general way. It does not convince me that the initial report simply cited the wrong publications."

A spokesman for DEWR said it "continues to investigate these claims and has sought urgent advice from Deloitte on these matters".

"Questions regarding the drafting of the independent reports should be directed to Deloitte."

On Friday a spokeswoman for Deloitte said: "We stand by our work and the findings in the report. The content of each article referenced is accurate. In finalising footnote referencing for publication, a few titles did not fully match the corresponding sources. This has been communicated to the client and the references are being corrected."

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