Using Industry Earnings Data to Benchmark a Plaintiff's Income

When a forensic accountant assesses the economic loss suffered by an injured person, the starting point is usually straightforward: what did the plaintiff earn before their injury, and what are they earning now?

In many cases, the answer is available in tax returns and payslips. But real matters are rarely that simple. A plaintiff might have been early in their career with limited earnings history. Records may be incomplete. A claim may involve projecting what someone would have earned had they not been injured, rather than simply measuring what they did earn. Or the plaintiff may have been self-employed, making direct income comparisons difficult.

In these situations, industry-level average weekly earnings data becomes one of the most useful tools available to a forensic accountant.

What Industry Earnings Data Is

The Australian Bureau of Statistics publishes average weekly earnings broken down by industry sector, updated twice yearly in May and November.

The May 2025 data covers 19 industry categories across Australia, showing average weekly earnings for males, females, and all persons, as well as the split between ordinary time earnings and total earnings including overtime.

This sector-level data provides a benchmark for what workers in a given industry typically earn, which can be used to contextualise a plaintiff's pre-injury income or to project what they would have earned over their working life.

The Range of Earnings Across Industries

The variation in average weekly earnings across industry sectors is substantial.

As at May 2025, total weekly earnings for all persons varied considerably. Mining was the highest-paying sector at $3,174.40 per week for all persons. Financial and insurance services followed at $2,041.90 per week. Professional, scientific and technical services came in at $2,003.90 per week.

At the other end of the scale, retail trade averaged $939.20 per week for all persons, and accommodation and food services averaged $715.50 per week.

Health care and social assistance, one of the largest employment sectors in Australia, averaged $1,427.80 per week. Construction averaged $1,872.00 per week. Education and training averaged $1,508.60 per week.

The national all-industries average for all persons was $1,542.30 per week.

These figures highlight how significantly the applicable industry benchmark can affect a damages assessment, particularly when projecting career earnings over a long future period.

When Industry Data Is Used

There are several situations where industry earnings benchmarks are particularly useful in an economic loss assessment.

The first is where a plaintiff was early in their career at the time of injury and has limited personal earnings history. Using the average earnings for their industry and occupation level provides a reasonable basis for projecting what they would have earned as their career progressed.

The second is where a plaintiff's tax records are incomplete or unavailable and their income needs to be reconstructed. Industry data provides a cross-check against other available evidence.

The third is where a plaintiff claims that their earnings would have grown significantly beyond their pre-injury level. Industry data can be used to assess whether the projected growth is consistent with what workers in the same sector typically earn at more senior levels.

The fourth is where the plaintiff was transitioning between industries at the time of injury. The earnings profile of the destination industry becomes relevant to assessing what they would have earned in the role they were moving toward.

Gender and Employment Type Matter

The ABS industry data is broken down by gender and by full-time versus all employees. These distinctions are relevant in practice.

Female workers earn less than male workers on average across most industry sectors, reflecting both occupational concentration and the impact of part-time employment. For any given plaintiff, it is important to use the benchmark that is most comparable to their specific employment circumstances rather than a combined average that may not reflect their situation.

Similarly, the difference between full-time adults and all employees is significant in industries with high rates of casual or part-time work. Using the all-employees figure for a plaintiff who was working full-time will understate the appropriate benchmark.

Presenting Industry Benchmarks in a Report

When industry data is used in a forensic report, the basis for selecting the particular sector and employment category should be clearly explained. This includes identifying the specific ABS series used, the period the data relates to, and how the benchmark has been applied to the plaintiff's specific circumstances.

At DB Forensic, we apply industry earnings benchmarks where they are appropriate, clearly identifying the basis for each comparison and explaining how the industry data supports the broader economic loss assessment.

Working on a Matter Where Earnings Need to Be Benchmarked

If you are preparing an economic loss assessment where the plaintiff's income history is limited or requires independent verification, DB Forensic can help identify the most appropriate industry benchmarks and apply them correctly.

Speak to DB Forensic About Your Economic Loss Assessment