Freedom of Information Systems in Australia and China Compared: What Can Malaysia Learn?

This thesis explores why access to government information matters and compares how Australia and China regulate such access. Although both jurisdictions provide legal rights to obtain government-held information, they operate in very different political and institutional contexts. Australia exemplifies a liberal democratic model with legislative safeguards and independent review, but its operation is hindered by executive resistance, exemptions, and prolonged delays in administrative review. China illustrates the limits of access rights within an authoritarian framework dominated by secrecy and administrative control. Drawing on these comparisons, the thesis proposes key reforms features for a Malaysia’s FOI system that balances openness with legitimate confidentiality.