Under the proposed integrity commission model put forward by the government, staff in law enforcement bodies - such as the Australian Federal Police, Border Force, and others covered by the current Australian Commission for Law Enforcement Integrity - would be covered by one branch, with the same powers as those currently in place.

But politicians and other public servants would be covered by another branch, which would be unable to take tip-offs from the public, hold public hearings or make public findings, and would only be able to investigate conduct suspected of being criminal corrupt conduct.

The AFPA represents members of the Australian Federal Police, and while the draft exposure bill for the Commonwealth Integrity Commission represents little change to oversight of their members, the association is concerned it would create a double standard given the two-tiered system.

"Our members are no better or no worse than any other public official," said the association's president, Alex Caruana.

"So if the politicians are saying that this is going to be a fairer system, and this is going to help everybody - everybody - then let's make it fairer, let's make it a truly fair system."

Under the proposed system, Mr Caruana pointed out that if a member of the Australian Federal Police and an MP were found to be committing corrupt conduct that wasn't necessarily illegal conduct, the police force member would likely lose their job, while the politician would go uninvestigated and unsanctioned.

"We think that there needs to be that level of parity - not suggesting that the AFP people or any of the politicians are dodgy, but if there is if there is an instance where there is that sort of thing going on, then surely the punishment should be the same," he said.

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The association warned that the proposed system would fail to close gaps that exist currently, pointing out that even though the Australian Federal Police could not find evidence of criminality in the case of the falsified City of Sydney annual report provided to The Daily Telegraph by Energy Minister Angus Taylor's office, "the public has a right to know how the false documents were created and circulated".

"Using (and allegedly creating) doctored official documents for political gain may not have amounted to a crime in this instance, but it raises questions about the integrity of the minister and his staff," the submission said.

The association is wary of how the role of the Australian Federal Police has been politicised, and is concerned about the implications if the public were to view an integrity commission as a toothless tiger.

In criticising the government's preferred integrity commission model, the association joins a series of voices calling for an overhaul of the proposal, which has been subject to a series of delays, and slammed for the dual systems it would put in place.

On Monday a group of retired judges warned the draft bill had been worded in a way that could leave ministers exempt from the commission's remit.

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