The 2025 National Statement on Ethical Conduct in Human Research provides clear guidance on minimising unnecessary duplication of ethics review. This is a practical concern for researchers and evaluators that may be working across multiple institutions, such as different government agencies, universities, hospitals, or schools. It also represents a governance challenge for organisations hosting research activities, as this requires these institutions to have clear procedures on deciding whether to accept a review that was not conducted internally.

This resource lays out the rationale for using external reviews, and what needs to be in place to ensure this. It also considers what researchers and evaluators can do to make sure that the potential risks to timelines from further reviews are minimised.

The Core Principle: Minimisation of Duplication

Chapter 5.5 of the National Statement establishes a fundamental responsibility: where more than one institution has governance oversight of human research, each must "adopt a review or authorisation process that minimises any unnecessary duplication of ethics review" (s5.5.1).

This principle applies regardless of research type or  the risk level. It applies to projects that require full HREC review or alternative processes for lower-risk review. The emphasis on "unnecessary" duplication is deliberate. Some research and evaluation contexts genuinely warrant multiple reviews, but these should be the exception, not the default.  

Institutional Responsibilities in Accepting External Review

When an institution receives a research proposal that has already undergone ethics review elsewhere, the National Statement sets clear expectations for decision-making.

Institutions must establish and publicise criteria for accepting external ethics approvals. These decisions should be made case-by-case, taking into account the evidence and standards applied by the external review body. In the case of our HREC, this is the application of the National Statement, consistent with our position statements and resources.

Moreover, where an institution decides to accept an external review, it should not engage in supplementary scientific or technical review of the research "except as agreed to by the reviewing body".

The guidance here is explicit: accepting external review means trusting the substantive ethical assessment conducted by that body. What institutions should do is clarify authorisation processes and negotiate monitoring responsibilities with the reviewing body and with researchers/evaluators. 

When Additional Review May Be Justified

The National Statement (and Iris Ethics) acknowledges that institutions may have legitimate grounds for requiring their own review beyond an external approval. This typically arises where proposed activities create contextual or operational risks that would not be readily apparent to an external reviewer. These may include risks tied to specific institutional circumstances, local communities, or operational contexts.

A clear example appears in research with Aboriginal and Torres Strait Islander peoples and communities. Chapter 4.7 of the National Statement recognises that such research may appropriately require multiple reviews: activities engaging with specific communities might be reviewed by a local body, a state or territory-level HREC, or the AIATSIS HREC, alongside review from another HREC (s4.7.15). This reflects the principle that cultural safety and appropriate community engagement may require expertise and knowledge that sits outside any single review body, and our position statement on this which sets out the cases where we may request review by an alternative HREC is consistent with this approach.

The critical distinction is that additional review in these circumstances serves a substantive ethical purpose and is not simply procedural duplication. 

Researcher and Evaluator Responsibilities: Planning for Multiple Reviews

For researchers and evaluators, understanding the landscape early is essential. During project planning, it is worth establishing whether:

• Participating institutions (e.g. government agencies, health services, universities and schools) are likely to require their own review in addition to external review
• Processes exist for conducting such reviews efficiently in those institutions
• Ethical review for activities at specific institutions can be sought separately from other project components

Where research/evaluation involves elements that may require specialised review, such as engagement with specific Aboriginal and Torres Strait Islander communities, researchers/evaluators should identify this early and determine which review bodies have the appropriate expertise and authority.

This is the researcher/evaluator's responsibility. While external HRECs such as ours can provide general guidance, researchers must actively identify whether multiple reviews are necessary and initiate appropriate processes.  

Coordination and Communication Between Review Bodies

The National Statement encourages practical cooperation. Where multiple reviews are required, communication between HRECs helps ensure that monitoring roles and responsibilities are clearly allocated. This coordination reduces administrative burden and provides clarity for researchers and evaluators about reporting obligations.

For external HRECs operating across institutional boundaries, this means being open to engagement with other review bodies. We work with other HRECs to clarify the scope of the review, discuss monitoring arrangements, and ensure that any additional review addresses genuine gaps rather than repeating assessments already conducted. Researchers and evaluators are welcome to direct HRECs to us for these discussions as and when required.

The Practical Outcome: Efficiency With Integrity

The 2025 National Statement's approach to duplication of review balances two imperatives: maintaining rigorous ethical oversight while avoiding inefficiency that delays beneficial research.

For institutions, this means developing transparent criteria for accepting external reviews and applying them consistently. For researchers and evaluators, it means proactive planning and clear communication about project scope and institutional contexts. For review bodies, it means professional cooperation and clarity about respective roles.

The framework is straightforward: 

• minimise duplication where it serves no ethical purpose; 
• retain multiple reviews where they address genuine contextual needs; and 
• coordinate effectively when multiple reviews are warranted.

This is both an ethical obligation and a practical necessity. Research and evaluation delayed by unnecessary procedural repetition is research and evaluation that does not reach the communities and participants it is designed to benefit. 

AI Disclosure:  Initial drafts of the content for this article were prepared using Large Language Models with input from Iris Ethics staff who guided the scope and design. Subsequent revisions and final versions were developed and approved by Iris Ethics staff.

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