Command-level leaders and Army lawyers who allegedly white-washed earlier investigations were not among the 19 individuals earmarked by criminal charges by Justice Paul Brereton's Afghanistan report, but he did recommend Army undertake administrative actions.

Their fate, along with expected structural and cultural reforms, will become clearer with the release of Australia's full response to the alleged war crimes. That announcement could occur as soon as January, after Defence Minister Linda Reynolds confirmed this week that the independent criminal justice response will begin next month once the Office of the Special Investigator begins operating.

The government put the brakes on the defence force plans to crack down swiftly following last month's release of Justice Brereton's report alleging 39 murders by 25 special forces personnel while on operations in Afghanistan between 2006 and 2013.

The government insisted that decisions and announcements be put on hold until the full implementation plan of the Brereton recommendations, including the delicate and lengthy process for criminal prosecutions, be announced simultaneously.

The three-person oversight panel, led by former inspector-general of intelligence and security Dr Vivienne Thom, is already working with ADF chief General Angus Campbell and Army chief Lieutenant General Rick Burr on the administrative and disciplinary components of the implementation plan. Only the plan for criminal prosecutions is yet to make progress.

Senator Reynolds said the oversight panel has hit the ground running working with defence and her as minister.

"I've been working very closely with the Chief of Defence Force over the last few weeks, and he is working through the recommendations, and he is preparing a draft implementation plan," the minister told reporters this week.

"I'm satisfied that when the implementation plan is released, [it will be] transparent, comprehensive, and it will address all of the matters that have been canvassed to date, and many more in that report."

"There's also in the report, a wide range of issues that the Chief Defence Force and the Chief of Army need to address administratively under Defence Force Discipline processes and Act. Those are the sorts of things that the CDF is reflecting on now, and working through how he deals with those, and all of those matters legal disciplinary and administrative will be contained in the implementation plan."

Justice Brereton identified 19 patrol-level individuals for criminal prosecutions in his report. None of the names have been released publicly, and even the Senator Reynold's copy of the complete report had the name redacted to preserve integrity of any decisions she may have to make.

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Additionally, the army sent notices to 13 current serving special forces soldiers asking them to explain why they should not be immediately sacked.

The lack of visible action against the army commanders who were "ignorant" of the actions under their leadership, according to Justice Brereton, has been a cause for concern among current serving ADF personnel and veterans. The Canberra Times understands these issues will be confronted in the implementation plan.

The government has announced senior appointments to fill the Office of the Special Investigator, including moving the secretary of the Attorney-General's Department Chris Moraitis into the top role as Director General.

The role of the Special Investigator will be filled by Justice Mark Weinberg QC, and director of investigations will be filled by Ross Barnett.