The commission claimed those under investigation were highly experienced public servants with "impeccable professional reputations" who became blinded to the risks and concerns surrounding the now-widely scheme.

"In their dogged pursuit to deliver on a government priority, some respondents lost their way," the report read.

"These public servants lost their objectivity and, in all likelihood, drowned out the deafening and growing criticisms."

Four people still working in the public service have been slapped with sanctions ranging from fines, demotions, reprimands and salary reductions.

It is unclear how the rest - who have retired or resigned - would be treated because there is no framework to punish a former employee, but if they sought re-employment in the public sector over the next five years, they would have to declare their breaches.

Community and Public Sector Union national secretary Melissa Donnelly called for further action.

"It is incredibly disappointing that there are no meaningful consequences for those at the top," she said.

The commission's report found public servants claimed they had behaved ethically because they acted in line with rules.

However, they should have considered whether the robodebt program - which was concocted to recover so-called "debts" to Centrelink - was a "sound and fair" public policy.

For example, the illegal scheme automatically calculated debt by averaging an individual's income, but this often failed to accurately reflect their earnings and many were ordered to pay more than they owed.

The commission found "little evidence" of any concern or assessment about whether this approach was the right thing to do, even when dealing with vulnerable people who may not have the records necessary to disprove their debt notices.

Workplace culture created by leading public servants, including Ms Campbell, failed to foster critical discussion over the robodebt scheme and criticism was often perceived as delaying progress towards implementing government policy.

This was because the intimidating senior leadership created a culture where employees felt they could not raise issues.

Some higher-ups would deflect accountability when they had delegated large and unsustainable amounts of work to junior staff.

Ms Campbell, in particular, failed to seek legal advice or respond to public criticism and whistleblower complaints and did not ensure her minister was fully informed of these issues.

She caused income averaging to resume even when she should have known the raised debts could be inaccurate.

Ms Leon did not properly brief the solicitor-general and relevant minister about the lawfulness of the debt collection scheme. 

No single person was accountable for the scheme, the report said, but multiple individual failures led to progressive systemic problems.

The pair's actions cover 25 code of conduct breaches while the 10 unnamed individuals were responsible for 72 occasions.

In a statement, Ms Leon said she was disappointed with the commission's decision, adding that she stood by "the actions I took to get definitive legal advice and bring the robodebt program to an end".

Australian Public Service commissioner Gordon de Brouwer apologised for the damage caused by robodebt.

"We can't change what happened, but we can learn from it and work together to make sure those mistakes won't happen again," he said.

Dr de Brouwer said the decision not to name others was to ensure proportionality and allow those involved to "restore themselves" and have some closure.

Between 2016 and 2019, the former coalition government's scheme recovered more than $750 million from almost 400,000 people.

Many welfare recipients were falsely accused of owing the government money and robodebt was linked to several suicides.

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