A number of jurisdictions in Australia are currently reforming their Indigenous cultural heritage laws. One of the most controversial aspects of these reforms is the scheme of administrative merits review of decisions. This is particularly so as in many of the current regimes, administrative review opportunities are only given to proponents (often mining interests), and not to Indigenous peoples. This paper is based on parts of a submission made to the New South Wales Government reform process on cultural heritage law. The paper considers diverse Indigenous cultural heritage merits review provisions nationally, with a comparative focus. In this context, this paper suggests that such domestic comparative administrative law scholarship is not common place across specific substantive areas, but reveals useful patterns and approaches for both a national and international audience.