Just an update for those watching this item. The data is showing me many payments being made on a regular basis using some base logic around the volume of bills and length of time between them and the correlation of those to determine some level of frequency... one example is showing a payment pretty much each monthly, but for a small amount so would assume the "paid" supplier is also doing other work, which I cant determine so still determining if it should be raised, suggesting it should not be under a subcontracting account or if its a true issue. So progressing, but any other suggestion on other triggers to identify this would be appreciated.

We will review the government advice on determining when a contractor should be an Employee. https://www.ato.gov.au/business/employee-or-contractor/how-to-work-it-out--employee-or-contractor/. We should be able to look at the entity type, in particular sole traders and billing information. Using this information to determine they are billing in a way that may place them into being an Employee and include Superannuation etc.