Participation requirements can be met through employment, supplier use or a combination; they are not guaranteed expenditure with FORCES. Engaging FORCES does not by itself satisfy a prime contractor’s obligations. A genuinely delivering Indigenous supplier or eligible joint venture can contribute to contract-specific supplier participation objectives only where the contract and measurement method recognise that contribution. MMR does not apply to every Defence contract.
Strengthened IPP eligibility criteria commenced on 1 July 2026: 51% or more First Nations ownership and control, or ORIC registration. Transition arrangements apply in 2026–27. Private-sector purchasing is not automatically subject to the Commonwealth IPP. Every route depends on eligibility, the buyer’s assessment and value for money; no route guarantees a contract award.
A proposed specialist operating company must independently confirm its own ownership and control, applicable certification, SME status and incorporated joint venture requirements. Saltwater’s current credentials are not inherited, and a negotiated 51% / 49% ownership structure alone does not establish procurement eligibility.