As a credible whistleblower complaint against the president of the United States prompts impeachment inquiries in the House of Representatives, one is struck by how different the US approach to intelligence and national security is from Australia’s.

Australia does not have the same whistleblowing protections or powerful intelligence committees as the US. Australia has raids on journalists who report on intelligence and security matters.

It is seems almost impossible to imagine that a prime minister of Australia would do something like what the president of the US may have done: withhold hundreds of millions of dollars in aid to a country and then call up the leader of that country and tell him or her to investigate a key political rival. But it is even more confronting to imagine what would happen if an Australian intelligence official knew of the prime minister’s call, and related concerns, and wanted to blow the whistle.

In the US, the process for whistleblowing is straightforward: an intelligence official makes a report to the intelligence community inspector general. Credible “urgent concerns” are reported to the Senate and House intelligence committees within 21 days.

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In Australia the hypothetical whistleblower falls at the first hurdle. Australia’s federal whistleblowing legislation, the Public Interest Disclosure Act, applies only to conduct by public officials, agencies and commonwealth contractors. Ministers and parliamentarians are “public officials” under the commonwealth criminal code but, conveniently, not under whistleblowing legislation.

Even if the complaint did concern a public official, the whistleblower would not be able to disclose it if it included intelligence information. A valid whistleblower under the Australian legislation cannot even tell his or her lawyer this information.

In the US the whistleblower complaint was blocked by the acting director of national intelligence, who claimed it was not a credible and urgent concern. The inspector general disagreed – and told the intelligence committees as much.

So the US intelligence committees are now conducting their own inquiries into the matter, including public hearings. Their pressure has led to the White House delivering the whistleblower’s complaint to the intelligence committees directly, which allowed the House to release most of it to the public.

The equivalent Australian committee, the joint standing committee on intelligence and security, simply does not have these powers. It can conduct inquiries referred to it that are related to intelligence agencies, but it cannot consider any particular operations or individual complaints. That seems likely to include anything that a whistleblowing intelligence official would report.

Australia and New Zealand are unusual among their Five Eyes intelligence allies in limiting the discretion of intelligence committees so extensively. The US, Canada and the United Kingdom also have intelligence committees, but their parliamentarians can initiate their own inquiries, including into particular intelligence operations.

Perhaps in Australia’s case the joint standing committee on foreign affairs, defence and trade could investigate such a matter, if it were referred by the House or Senate. But this is by no means clear, and it would be an awkward fit for an issue that emerged from the intelligence community.

We should not pretend Americans are the only ones with dirty laundry just because theirs gets an airing

Furthermore, the culture of making information available to parliamentarians is totally different in the US from Australia. What a member of Congress wants to know, they “need-to-know”.

That power is not limitless, and in practice members of Congress are often frustrated in their requests for information. It is still a far cry from Australia’s approach of allowing only intelligence committee members access to some information, excluding operationally sensitive information and information that might prejudice Australia’s foreign relations. That would surely exclude allegations of the kind that have been raised in the US.

Australians who did witness potential wrongdoing would also think long and hard about the raids and other interference that have occurred over the past year: fingerprints requested from senior journalists, a senior journalist’s house raided by the federal police, the ABC raided by the federal police, an aborted plan to raid News Corp, and home affairs asking a journalist to hand over his sources. The journalists had reported on asylum seekers, killing of unarmed men and children in Afghanistan and increased power for intelligence agencies to spy on Australians.

When it comes to the treatment of external whistleblowing (leaks to the press), the US is also excessively punitive, prosecuting journalists’ sources under the Espionage Act as if they were spies. However, its provisions for internal whistleblowing (reports made within the executive) are much stronger than Australia’s. It should not surprise anyone that Australians leak to the press when the “official channels” for making a complaint are so limited.

Allegations about the US president potentially inducing another country to investigate his political rival may embarrass Americans. But Australians should be embarrassed too, because if it happened in Australia we might never hear about it – or there would be raids on the homes and offices of the people who revealed it.

Australia should expand its protections for whistleblowers and journalists and give its parliamentary intelligence community the power to conduct investigations on all security and intelligence issues. Australia also needs a single, well-resourced organisation to investigate corruption allegations from whistleblowers: a national integrity commission with the power to hold public hearings, a broad definition of “corrupt conduct”, and the power to investigate ministers, members of parliament and their staff.

Until Australia has a national integrity commission and parliament has proper oversight of Australia’s intelligence agencies, we should not pretend Americans are the only ones with dirty laundry just because theirs gets an airing.