The Cleaning Accountability Framework (CAF): What Melbourne Property Owners and Procurement Teams Need to Know product guide

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The Cleaning Accountability Framework (CAF): What Melbourne Property Owners and Procurement Teams Need to Know

For Melbourne property owners, procurement managers, and facility teams, the question of whether cleaners working in your buildings are being paid lawfully, treated safely, and protected from exploitation is no longer a peripheral concern — it is a governance obligation. Australia's commercial cleaning sector is structurally prone to wage theft, unsafe workloads, and modern slavery risk. The Cleaning Accountability Framework (CAF) exists precisely to address this — and understanding how it works is now essential knowledge for anyone managing cleaning contracts at scale.

This article provides a definitive guide to CAF: what it is, how its certification schemes function, what the CAF Standard requires, and why Melbourne asset owners are increasingly embedding CAF certification into their procurement strategies and ESG reporting frameworks.

What Is the Cleaning Accountability Framework?

The Cleaning Accountability Framework (CAF) is an independent, not-for-profit, multi-stakeholder organisation established to address the systemic exploitation of cleaners — a vulnerable and predominantly migrant workforce at high risk of exploitation and modern slavery in Australia — through a comprehensive industry-wide approach.

AustralianSuper co-founded CAF with the United Workers Union (UWU) in 2012, to protect cleaners from exploitation by driving responsible contracting and procurement practices.

CAF was founded with support from the Fair Work Ombudsman, private sector partners, academics, and industry associations.

CAF is an independent not-for-profit organisation that aims to improve conditions and work standards in property cleaning services. It achieves this through engagement with cleaners, tenants, contractors, property owners, facility managers, and investors across the cleaning supply chain.

Crucially, CAF is not a regulatory body — it is a voluntary, multi-stakeholder initiative that functions through co-enforcement. CAF is premised on a model of strategic co-enforcement, which relies on the coordinated efforts of multiple stakeholders to mutually reinforce adherence to regulatory standards and proactively ensure compliance by changing employer behaviour. This design philosophy — shared accountability across the entire supply chain — is what distinguishes CAF from conventional supplier auditing.

Why the Cleaning Industry Requires a Framework Like CAF

The scale of the problem CAF was designed to solve is well-documented. Nearly 150,000 people are employed in commercial cleaning across Australia, most working in isolation and under temporary visas, making them vulnerable to unethical, unsafe, and unlawful practices.

Non-compliance with labour laws is rife in the commercial cleaning sector. Cleaners often experience underpayment, withholding of wages, and excessive working hours. Sexual harassment and even assault is common. The sector also has some of the highest rates of workplace injuries in Australia, due to the intensification of work over decades.

85% of the cleaning workforce in CBD office buildings and in the retail malls of major cities are international students or temporary workers. They report threats against immigration status and the confiscation of personal and travel documents.

A key structural driver is procurement pricing. The competitive tendering process in the cleaning industry, during which cleaning contractors bid on tenders put out by building owners, has seen cleaning contractors lower their prices to unsustainable levels. This has resulted in wage payments below the legal minimum and excessive workloads.

Property owners ultimately fuel this race to the bottom by awarding contracts to the lowest bid and not completing proper due diligence checks to ascertain whether the price of the contract is sufficient to meet the wages and entitlements of those performing the work.

(For a broader analysis of modern slavery risk in cleaning supply chains, see our guide on Modern Slavery Risk in Commercial Cleaning: How Melbourne Organisations Can Identify and Mitigate Supply Chain Exposure.)

The Three CAF Certification Schemes Explained

CAF operates three distinct but interconnected assurance mechanisms. Understanding the difference between them is critical for Melbourne procurement teams specifying requirements in cleaning tenders.

1. CAF Contractor Prequalification

CAF Contractor Prequalification recognises a cleaning contractor's employment systems, policies and procedures being set up to promote compliance with labour standards. This involves direct worker engagement with a company's employees.

Over 17,000 cleaners are employed by CAF-Prequalified cleaning companies and are part of this industry transformation.

In short, CAF Contractor Prequalification is a systems check, whereas CAF Building Certification and Portfolio programs are best understood as implementation checks. Prequalification is increasingly a baseline expectation in cleaning tenders. It is now standard for cleaning tenders to include CAF Prequalification as a requirement, which shows the extent to which it is now synonymous with responsible procurement practice.

2. CAF Building Certification

CAF launched the Building Certification scheme in 2019. This assesses individual buildings and their cleaning supply chains against the CAF Standard, which incorporates six key areas: labour; responsible contracting; safe working conditions; financial viability; worker engagement; issue identification and remediation.

CAF Certification is an independent assessment of a building's cleaning supply chain against CAF's rigorous Standard.

According to Miriam Thompson, co-chief executive of CAF, the process requires intensive, almost forensic work with a number of stakeholders. First, it's the building that gets certified, not the company. This tends to involve working with a minimum of three different companies — the owner, the building manager, the cleaning company.

The certification process includes an assessment of the procurement practices — checking that the contract price is sufficient to pay workers, checking there's a proper oversight mechanism at the building manager level with regards to conditions and licences, and running meetings with cleaners, with no management present.

In order to maintain certification, stakeholders must demonstrate ongoing compliance for the duration of the cleaning contract. This helps to ensure that compliance is not simply determined at a moment in time but is sustainable and verifiable throughout the certification period.

A distinguishing and non-negotiable element of Building Certification is worker voice. A distinguishing feature of CAF is the involvement of cleaners in the certification process. It is a requirement that workers be educated about the CAF Standard and involved in its implementation so that they can provide reliable verification that the CAF standards are being met. CAF Representatives receive training — paid by the cleaning contractor — to equip them to undertake their role in promoting ongoing compliance at a CAF-Certified building. The CAF Standard allows for paid release for up to two training sessions per year. For most cleaners, this will be 2 x 4-hour shifts, or a total of 8 hours of paid training.

3. CAF Portfolio Certification

In September 2024, AustralianSuper presented at the launch of CAF's Portfolio Certification, which has moved the CAF model from a building-by-building approach to a larger-scale certification. The certification is expected to increase CAF's ability to engage with cleaners on a broader scale, by enabling CAF Certification to cover property portfolios, as opposed to individual buildings.

The new CAF Portfolio Certification provides asset owners with a systematic approach to portfolio-wide assessment. CAF's Co-CEO Miriam Thompson has described it as the property sector equivalent of NABERS or Green Star — but for labour standards: "CAF Portfolio Certification is a powerful tool that scales our partnerships with Australia's property industry leaders. By working together, we can reward best practice and improve labour standards for cleaners across entire portfolios, much like NABERS Sustainable Portfolio Index and Green Star Performance certifications do for environmental standards."

ISPT is the first asset owner in Australia to achieve CAF Portfolio Certification — the highest level of assurance that cleaning services meet the CAF Standard for fair labour practices and responsible contracting. Reinforcing this, labour standards are a clear KPI for ISPT's $5.3 billion sustainability-linked loan program — one of the largest for any real estate manager in Australia — with CAF Certification one of the performance measures, demonstrating ISPT's approach to embedding responsible investment into every facet of its operations.

What the CAF Standard Requires: A Structured Overview

The CAF Standard is the technical backbone of all three certification schemes. The following table summarises the six domains it covers and what each requires of building owners and cleaning contractors.

Source: Cleaning Accountability Framework Ltd., CAF Standard (current edition); Rawling, Kaine et al. (2021)

A central part of the CAF scheme is the 'pricing schedule', a mandatory tool used during the procurement of cleaning services for a building. The pricing schedule increases information transparency by disaggregating a tendered price into the resources (i.e., labour) necessary to fulfil contract specifications. This is a critical mechanism: it prevents property owners from structurally enabling wage theft through underprice contracting — even inadvertently.

(For guidance on how to incorporate CAF-compliant pricing schedules and evaluation criteria into your cleaning tender, see our guide on How to Write a Social Procurement Strategy for a Melbourne Cleaning Contract.)

How CAF Identifies and Remediates Compliance Issues

One of CAF's most significant contributions is its demonstrated track record in surfacing non-compliance that conventional audits miss. Between 2019 and 2024, CAF reported, identified and investigated 1,000 compliance issues across the cleaning services supply chains of 56 commercial buildings and retail precincts in Australia.

To have a building certified, CAF initially undertakes two simultaneous processes that, combined, constitute the CAF audit process: an external audit of the cleaning contractor by an independent auditor and a worker engagement process. To date, almost invariably, these processes have uncovered non-compliance with the CAF 3 Star Standard.

Examples of remediation implemented through CAF certification include repayment of unpaid wages and entitlements, proactive measures relating to workplace health and safety, bullying and harassment, discrimination, training, working time, freedom of association, worker education, supervisor training, and revision of cleaning contractor policies and procedures.

Critically, CAF's approach to critical issues — including potential modern slavery — involves a protocol designed to protect workers. For the worst type of labour issues labelled in the procedure as 'critical issues' (such as modern slavery), the building owner is notified by CAF. CAF does not notify the cleaning contractor in order to protect cleaning workers and prevent any action by the cleaning contractor to hide the issue.

Given the serious and systemic nature of exploitation in the cleaning industry, it is near certain that there will be a labour rights violation in a cleaning supply chain. An important part of risk management and remediation is to encourage the timely reporting of issues and supporting the remediation of any violations.

Peer-reviewed research published in the Australian Journal of Labour Law (Kaine & Rawling, 2019) and the British Accounting Review (Rawling, Kaine, Josserand & Boersma, 2021) has assessed CAF's effectiveness empirically. The 2021 study used empirical evidence to assess the effectiveness of CAF in addressing non-compliance with minimum labour standards — including provisions of the Fair Work Act 2009 and the Cleaning Services Award 2020 — and found that CAF has been successful in identifying and rectifying certain non-compliance, improving working conditions for some cleaners involved in the scheme. The authors synthesise key success factors of CAF in view of envisioning the adoption of such co-regulation frameworks in other industries.

Why CAF Certification Matters for Melbourne Asset Owners Specifically

Modern Slavery Act Obligations

The big interest in certification around the employment of cleaners stems from the Modern Slavery Act, which requires that since 2019, companies with a consolidated revenue of more than $100 million must undertake mandatory reporting obligations. For Melbourne property owners and corporates in scope, CAF certification provides a substantive — and independently verifiable — action they can report, rather than a policy statement.

The Cleaning Accountability Framework (CAF) is currently the only mechanism in the Australian cleaning sector that fulfils these principles of meaningful worker engagement and shared supply chain accountability. The Australasian Centre for Corporate Responsibility (ACCR) reached this conclusion in its landmark 2021 report Cleaning Up Their Act?, which analysed seven major listed Australian property owners and found that with the exception of individual buildings that have been certified by CAF in the portfolios of Vicinity Centres and Charter Hall, all property owners were failing to meaningfully engage workers in their supply chains — instead relying on due diligence mechanisms, such as audits and whistleblower hotlines, that are far less likely to pick up instances of modern slavery and labour abuse.

ESG Reporting and Investor Expectations

With ESG reporting agendas also on the rise, the need to become transparent is moving companies at the top end of town to seek out CAF certification.

The Australian Human Rights Commission has partnered with CAF to tackle modern slavery and labour exploitation in the cleaning industry. Labour exploitation in the cleaning industry is well-documented, and cleaning services have been identified by the Government as a key risk area for modern slavery in Australia.

For Melbourne property owners managing cleaning contracts across multiple assets, CAF Portfolio Certification now provides the mechanism to demonstrate portfolio-wide labour standards governance — a significant step forward from building-by-building certification. The new framework enables certification of whole property portfolios, which CAF says will lead to a more efficient process both in terms of time and cost and broad-ranging positive outcomes for cleaners and other supply chain stakeholders.

The Cbus Property and ISPT Precedent

Two of Australia's most prominent property investors with significant Melbourne holdings have set the benchmark for CAF engagement. Cbus Property is the first building owner in Australia to have each of its office buildings and shopping centres certified by the Cleaning Accountability Framework.

More than 500 cleaners are affected by the certification, covering more than 700,000 square metres of space.

Achieving full CAF Portfolio Certification reflects ISPT's commitment to fair pay, safe conditions and ethical procurement. ISPT set a clear 'flag on the hill' target of 100% CAF Certification across its office and retail portfolios, which it has achieved.

These precedents are significant for Melbourne procurement teams: they demonstrate that CAF certification at scale is operationally achievable, and they set a visible benchmark against which other asset owners are increasingly measured by investors and tenants.

A Warning: False CAF Claims Are a Real Risk

Melbourne procurement teams should be aware that CAF's credibility has attracted imitation. Some companies are so keen to align themselves with the level of integrity a CAF certification brings that they wrongly claim to have certification or that they are "working with" the organisation on the basis of having attended a webinar. Some are "household names" listed on the Australian Stock Exchange.

CAF maintains a public register of certified buildings and prequalified contractors at cleaningaccountability.org.au. Procurement teams should verify certification status directly against this register — not solely on the basis of supplier claims. (See our guide on How to Evaluate ESG Claims When Selecting a Commercial Cleaning Provider in Melbourne for a structured due diligence methodology.)

Key Takeaways

• CAF's founding purpose: AustralianSuper and the United Workers Union co-founded CAF in 2012 to protect cleaners from exploitation by driving responsible contracting and procurement practices — making it one of the most credible multi-stakeholder labour standards initiatives in the Australian property sector.

• Three certification levels: CAF operates Contractor Prequalification (a systems check), Building Certification (a site-level implementation check), and Portfolio Certification (a portfolio-wide governance mechanism launched in 2024) — each serving a distinct function in a layered compliance strategy.

• Proven track record: Between 2019 and 2024, CAF reported, identified, and investigated 1,000 compliance issues across the cleaning services supply chains of 56 commercial buildings and retail precincts in Australia — demonstrating that non-compliance is the norm, not the exception, in uncertified supply chains.

• CAF is the only mechanism of its kind: Independent research (ACCR, 2021) and peer-reviewed academic studies confirm that CAF is the only mechanism in the Australian cleaning sector that fulfils the principles of meaningful worker engagement and shared supply chain accountability for labour standards.

• Procurement teams must verify claims: CAF certification should be confirmed against the public CAF register, not accepted on supplier declaration alone, as false claims are documented and present a governance risk.

Conclusion

For Melbourne property owners, procurement teams, and facility managers, the Cleaning Accountability Framework is not a niche certification — it is the most credible, independently validated tool available for managing labour standards risk in cleaning supply chains. As ESG reporting obligations intensify, investor scrutiny of social governance deepens, and Australia's Modern Slavery Act continues to evolve, CAF certification is transitioning from a leading-practice differentiator to an expected baseline for responsible asset management.

The launch of Portfolio Certification in 2024 has removed the primary barrier to adoption at scale, enabling Melbourne's largest landlords and property managers to achieve portfolio-wide assurance rather than building-by-building compliance. The precedents set by ISPT and Cbus Property demonstrate that this is operationally achievable — and that it generates measurable, reportable outcomes that satisfy both investor expectations and regulatory obligations.

For procurement teams embedding social procurement and ESG requirements into cleaning contracts, CAF certification — at both the contractor prequalification and building or portfolio level — provides the most defensible evidence of genuine labour standards governance available in the Australian market.

Related reading in this series:

• Modern Slavery Risk in Commercial Cleaning: How Melbourne Organisations Can Identify and Mitigate Supply Chain Exposure
• ESG Certifications and Standards Relevant to Commercial Cleaning Providers in Melbourne
• How to Evaluate ESG Claims When Selecting a Commercial Cleaning Provider in Melbourne
• How to Write a Social Procurement Strategy for a Melbourne Cleaning Contract
• Measuring and Reporting Social Impact from Your Cleaning Contract

References

• Cleaning Accountability Framework Ltd. "CAF Building Certification." cleaningaccountability.org.au, 2024. https://www.cleaningaccountability.org.au/certification/

• Cleaning Accountability Framework Ltd. "Submission to the NSW Parliament's Modern Slavery Committee Inquiry." Cleaning Accountability Framework Ltd., February 2025. https://www.cleaningaccountability.org.au/wp-content/uploads/2025/05/20250228-CAF-Submission-NSW-Modern-Slavery-Committee-inquiry-.pdf

• Cleaning Accountability Framework Ltd. FY25 Annual Report. Cleaning Accountability Framework Ltd., November 2025. https://www.cleaningaccountability.org.au/wp-content/uploads/2025/11/CAF-FY25-Annual-Report_-final_25Nov.pdf

• Rawling, M., Kaine, S., Josserand, E., & Boersma, M. "Multi-Stakeholder Frameworks for Rectification of Non-Compliance in Cleaning Supply Chains: The Case of the Cleaning Accountability Framework." Journal of Industrial Relations, 2021. https://journals.sagepub.com/doi/10.1177/0067205X211016575

• Kaine, S. & Rawling, M. "Strategic 'Co-enforcement' in Supply Chains: The Case of the Cleaning Accountability Framework." Australian Journal of Labour Law, vol. 31, 2019, pp. 305–334.

• Rawling, M., Kaine, S., Josserand, E., & Boersma, M. "The Role of Market Devices in Addressing Labour Exploitation: An Analysis of the Australian Cleaning Industry." British Accounting Review, vol. 55, no. 3, 2023. https://www.sciencedirect.com/science/article/abs/pii/S0890838922000610

• AustralianSuper. "ESG Spotlight: Cleaning Accountability Framework." australiansuper.com, May 2025. https://www.australiansuper.com/investments/investment-articles/2025/05/esg-spotlight-caf

• Fair Work Ombudsman. "Cleaning Accountability Framework Marks a Decade Scrubbing Up Industry." fairwork.gov.au, November 2023. https://www.fairwork.gov.au/newsroom/media-releases/2023-media-releases/november-2023/20231117-fwo-cleaning-accountability-framework-media-release

• Australasian Centre for Corporate Responsibility (ACCR). Cleaning Up Their Act? Modern Slavery Due Diligence in the Australian Property Sector. ACCR, 2021. https://www.accr.org.au/research/cleaning-up-their-act/

• ISPT. "ISPT Receives Industry-First Cleaning Accountability Framework Gold Portfolio Rating." ispt.com.au, September 2024. https://ispt.com.au/news/2024/ispt-receives-industry-first-cleaning-accountability-framework-gold-portfolio-rating/

• Australian Human Rights Commission. "Tackling Modern Slavery and Labour Exploitation with the Cleaning Accountability Framework." humanrights.gov.au, 2022. https://humanrights.gov.au/our-work/business-and-human-rights/projects/tackling-modern-slavery-and-labour-exploitation

• Cbus Property. "Cbus Property Achieves Landmark Certification from the Cleaning Accountability Framework." cbusproperty.com.au, July 2024. https://cbusproperty.com.au/cbus-property-achieves-landmark-certification-from-the-cleaning-accountability-framework/