Introduction

Few questions generate as much quiet anxiety in project scoping as this one. How much should we pay participants? Is a $50 voucher enough for an hour-long interview about someone's experience of homelessness? Is $10 too much for a five-minute survey? Should we pay at all?

There are no easy answers here. What there is, however, is a set of considerations that will help you reason your way to a defensible position, and a set of common errors that ethics committees see often enough to be worth naming.

What the National Statement says

The National Statement on Ethical Conduct in Human Research 2025 (the National Statement) is less prescriptive on this topic than many people expect. Paragraph 2.2.10 establishes that it is generally appropriate to reimburse participants for the costs of taking part, including travel, accommodation and parking, and that participants may sometimes also be paid for their time. It then sets the outer boundary: payment that is disproportionate to the time involved, or any other inducement likely to encourage participants to take risks, is ethically unacceptable.

Paragraph 2.2.11 adds that decisions about payment or reimbursement in kind, whether to participants or their community, should take into account the customs and practices of the community in which the project is conducted.

Two further paragraphs matter. Paragraph 3.1.21 asks evaluators, researchers and reviewers to consider the degree to which any payment or incentive could result in pressure on individuals to consent, which connects directly back to the prohibition on coercion and pressure at 2.2.9. And paragraph 2.2.6(j) requires that any payments to participants be communicated as part of the information provided to them.

The National Statement gives you a floor (reimburse costs), a ceiling (do not induce risk-taking), and a process obligation (tell people, and think about context). Everything between the floor and the ceiling is judgement.

Rate cards help, but rate cards anchor

Published rate cards can be a useful starting point. Paper Giant's internal framework for research incentives is a good example, and its underlying logic is sound: assess time investment (including travel, preparation and emotional recovery, not just the session), expertise required, emotional labour, power dynamics, and whether the participant is already being compensated to be there.

The risk with any rate card is anchoring. Once a number is on a page, it becomes the number, and the conversation shifts from "what is a fair recognition of this contribution" to "can we justify departing from the schedule". This creates two problems.

The first is that anchors can travel badly between contexts. A rate designed for a 90-minute focus group with the general public gets applied to a 90-minute interview with a person recounting family violence, because both are 90 minutes. The clock is the easiest variable to measure and the least informative one.

The second is that anchors go stale. Published rate cards are frequently a few years old, and cost of living has moved considerably. A figure set in 2021 and never revisited is now, in real terms, a lower offer than it was. If your organisation maintains a rate card, put a review date on it. If you are using someone else's, check when it was written before you treat it as authoritative.

Voluntary participation is legitimate, up to a point

Not paying participants is a perfectly acceptable design choice. Plenty of evaluation/research proceeds on the basis that people contribute because they care about the topic, want the service improved, or simply have five minutes to spare. The National Statement does not require payment.

What it does require is that the decision to participate is both informed and voluntary. That means people should be told, clearly and up front, that no payment is offered. We recommend treating this as a positive disclosure obligation rather than an omission. If your information materials are silent on payment, some participants will assume payment is coming, and a small number will feel misled when it does not. A single sentence ("There is no payment for taking part in this survey") resolves it.

The strength of the argument for voluntary participation should scale with the burden imposed. A five-minute online survey about local supermarket shopping habits needs almost no justification. A three-hour workshop requiring travel, childcare arrangements and discussion of a difficult service experience needs a strong one.

And the argument for non-payment cannot be "we do not have the budget for it". Budget is a project design constraint, not an ethical justification. If a project cannot afford to recognise the contribution it is asking people to make, the honest options are to reduce the ask, narrow the scope, or reconsider whether the project should proceed in its current form. Reviewers are generally unimpressed by applications that ask a lot of participants and offer nothing in return because of a procurement rule.

Prize draws may be appropriate, sometimes

Prize draws are a reasonable option in a specific set of circumstances: a large respondent pool, a low burden on each participant, and clearly communicated terms. A population survey of 3,000 people about transport preferences with a draw for one of five $200 vouchers is a defensible design. A draw for six participants in a series of in-depth interviews is not, because most participants receive nothing for a substantial contribution.

Where a prize draw is used, the terms need to be genuinely clear: 

• how many prizes; 
• what they are worth; 
• when (and ideally) how the draw occurs; 
• how winners are notified;  
• how contact details for entrants are kept separate from data collected as part of the research/evaluation; and,
• what happens to entrants' contact details afterwards.

There is also a legal dimension that is easy to overlook. Prize draws are regulated as trade promotion lotteries under State and Territory legislation, and requirements vary considerably. New South Wales, South Australia, the Australian Capital Territory and the Northern Territory each operate permit or authority arrangements that are triggered once the total prize value passes a specified threshold. Victoria, Queensland, Western Australia and Tasmania do not require permits, but do impose conditions on how a promotion is run. A national project must comply with the requirements of every jurisdiction in which it recruits. Many evaluation/research prize draws sit below the relevant thresholds, but the conditions of conduct still apply, and evaluators and researchers should check the current position with the relevant regulator.

Context changes everything

Remuneration that is appropriate for one group can be inappropriate, or actively harmful, for another. Two examples make the point.

A supermarket gift card is a sensible, low-friction option for most projects. It is a poor choice for an evaluation of an alcohol and other drug service, where the card can be redeemed for alcohol. A department store card or a prepaid card with retailer restrictions is a better fit (where this is applied consistently across stakeholders).

A prize draw is similarly unremarkable in most market research contexts. However, in an evaluation of a gambling harm reduction program, it introduces a chance-based reward mechanism to a group for whom that mechanism is the presenting problem.

The general principle is that the form of remuneration should not itself introduce risk. This is worth a specific line of thought during design, and it is a question reviewers will ask.

Method matters too. Panel-recruited market research operates under established incentive structures that participants already understand. Community-based evaluation with people experiencing financial hardship may need careful consideration of whether the incentive may be coercive to participation (but then not having an incentive may disadvantage people further). Professional stakeholders participating as part of their paid role (especially government staff members) generally need no payment at all, and offering it can create its own complications due to procurement and gifting rules.

Access costs are not remuneration

This should not need saying, but we want to make this clear.

The cost of making participation possible is a project cost, not a participant benefit. Translators, Auslan interpreters, support workers, accessible venue hire, materials in Easy Read or community languages, assistive technology, and transport that accommodates a mobility aid are all costs of running an inclusive project.

They should never be deducted from, offset against, or counted towards what a participant receives. A Deaf participant in a focus group who requires an Auslan interpreter should receive the same payment as everyone else in the room. A participant who needs an interpreter for a Vietnamese-language interview should receive the same payment as a participant interviewed in English. The interpreter is there so the project can hear from that person. It is not a service rendered to the participant in lieu of payment.

The reasoning is straightforward. Treating access costs as part of remuneration means people with disability and people from non-English speaking communities are systematically paid less than other participants for the same contribution, and the amount by which they are underpaid rises with the extent of their support needs. That is a direct failure of the justice principle in Section 1 of the National Statement, which requires that the burdens and benefits of evaluation/research be distributed fairly and that participant selection and treatment not be discriminatory.

There is a practical dimension as well. Where access costs are treated as fungible with participant payments, budget pressure late in a project tends to be resolved by quietly narrowing recruitment, and the people excluded are exactly the people whose perspectives the project most needed. Cost the supports separately, at the design stage, and make them visible in the budget so they are harder to cut.

Remuneration is not reciprocity

This distinction matters particularly, though not exclusively, for evaluation/research with Aboriginal and Torres Strait Islander peoples and communities.

Remuneration is a transaction. It recognises time, expertise and inconvenience, and it concludes when the payment is made. Reciprocity is a relationship. It encompasses how a project is designed, who holds decision-making authority, how data sovereignty is respected, who owns and stewards the findings, and what the community gets from the work over the long term.

Paying an honorarium does not discharge a reciprocity obligation, and a well-designed reciprocity arrangement does not remove the need to cover a participant's travel costs. Both are design considerations, and they operate on different registers.

Critically, what constitutes appropriate reciprocity cannot be determined by the project team. It requires engagement with the community, and agreement from the community, before the project design is settled. Chapter 4.7 of the National Statement, read alongside the AIATSIS Code of Ethics, sets out expectations here. Applications that describe a payment schedule and call it reciprocity will be asked to do more.

Questions to work through before you submit

• What is the real ask? Not just session length, but travel, preparation, recovery time, and any follow-up.
• What expertise or lived experience is the participant contributing, and would you pay a consultant for equivalent input?
• Are participants already being compensated to take part, for example as part of a paid role?
• If you are not paying, what is your justification, and does it hold up against the burden you are imposing?
• Does your information material state the payment position clearly, including where there is no payment?
• Could the amount offered plausibly induce someone to participate against their better judgement, particularly participants in financial hardship?
• Could the form of the payment (voucher type, prize draw mechanism, cash) create a risk given the topic or the participant group?
• If you are running a prize draw, are the terms clear, and have you checked the requirements in every jurisdiction where you are recruiting?
• Are accessibility supports and interpreting costed separately in the budget, rather than being netted off what participants receive?
• Where the project involves Aboriginal and Torres Strait Islander communities, what reciprocity arrangements have been discussed and agreed, separately from any payment?
• When was your rate card last reviewed?

None of this produces a single correct number. It produces a reasoned position, documented, that you can explain to a participant, a client, a procurement officer, and a reviewer. That is what is being asked for.

If you are unsure whether your proposed remuneration approach is proportionate for your project, contact the Iris Ethics team before you submit. It is a far easier conversation at thedesign stage than as a condition of approval.

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This article draws on the National Statement on Ethical Conduct in Human Research (2025). It is intended as practical guidance and does not constitute legal advice. Requirements for trade promotion lotteries change; check the current position with the relevant State or Territory regulator. If you have questions about your project, get in touch.

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.