Accountability — Practice Guide¶
ASQA Practice Guide · Compliance Standards · Standards CS §15-20 · Published 17 June 2025 · Version 1.0
Verbatim reproduction of the ASQA Practice Guide, extracted from the source PDF with layout preservation (via
pdftotext -layout). The body below preserves the original two-column table structure — performance indicators on the left, example activities and known risks on the right.Source: https://www.asqa.gov.au/for-providers/standards-for-RTOs/practice-guides
Companion docs: -
standards-outcome.md/standards-compliance.md— the underlying legislative text -standards-explanatory.md— the Explanatory Statement commentary -compliance-reference.md— RTOpacks module × standard mapping
Practice Guide
Accountability
Ver 1.0
Published 17 June 2025
Compliance Standards for NVR Registered Training Organisations
Part 2 Compliance Requirements
Division 3 – Accountability
What are the key concepts?
The following key concepts are covered in this practice guide:
Compliance requirements
• Annual declaration on compliance (ADC) • Prepaid fee protection measures
• Notification of material changes • Public liability insurance
• Third party arrangements • Compliance with laws
Achieving these Compliance Requirements in practice
The following tables provide guidance on meeting the Compliance Requirements as well as risks to
mitigate or avoid. These should be considered within the context, size, scale and student cohorts of your
RTO’s operations.
Annual declaration on compliance
Requirement Example activities and other considerations for
compliance
1. An NVR registered training organisation • You can demonstrate how you use the Annual
must submit an annual declaration on Declaration on Compliance (ADC) as an
compliance with its obligations under the Act additional opportunity to reflect upon your
for each annual reporting period in which the RTO’s systems, practices and processes, and
organisation is registered. to inform future improvements to your
2. An NVR registered training organisation’s operations.
annual reporting period is the period of 12 • You disclose to ASQA through your ADC
months that is specified by the National VET responses any self-identified non-compliance
Regulator as the organisation’s annual and what rectification actions you are taking.
reporting period.
• You ensure the preparatory work you do before
3. An annual declaration on compliance completing the ADC covers your RTO’s entire
submitted by an NVR registered training scope of registration, including all services
organisation must be in the approved form as delivered by third parties on your behalf.
published on the National Register by the
• You ensure that only the CEO, as the person
National VET Regulator from time to time.
legally responsible for the RTO’s registration,
submits the declaration to ASQA.
• Where you have third party arrangements, your
CEO completes the ADC having also verified
the compliance of those third parties’ systems,
practices and processes in relation to the
services they deliver on your RTO’s behalf.
• You ensure that you retain evidence to support
any answers provided in the ADC.
Known risks to compliance
• Completing and submitting the ADC without
adequately verifying your RTO’s compliance
with each obligation.
• Not ensuring your CEO has authenticated all
responses in the ADC before submitting them.
• Declaring full compliance on the ADC even
though you have identified non-compliances
internally – i.e. failing to disclose.
• Failing to complete and submit the ADC within
the submission period notified by ASQA.
• Not requesting or reviewing evidence as part of
your ADC submission to confirm services
delivered by your third parties are complying
with the relevant obligations.
Notification of material changes
Requirement Example activities and other considerations for
compliance
1. An NVR registered training organisation must • You can demonstrate how your systems
notify the National VET Regulator of the ensure that you notify ASQA within ten (10)
occurrence of an event that would significantly business days after the occurrence of any
affect the organisation’s ability to comply with event that significantly impacts your RTO’s
any of its obligations under the Act. ability to comply with its legislative obligations.
2. A notice under subsection (1) must be given • You have systems and processes in place to
within 10 business days after the event ensure that:
occurs. ○ any prospective material changes to your
3. An NVR registered training organisation must RTO’s ownership are notified to ASQA as
notify the National VET Regulator of: soon as practicable before the change
a. any prospective changes to the ownership takes effect
of the organisation as soon as practicable ○ any prospective or actual change to
before the change takes effect; or governing persons are notified to ASQA
b. any prospective or actual change in as soon as practicable before the change
relation to a governing person of the takes effect, or, where a change cannot
organisation: be determined until it takes effect, notify
i. if the change cannot be determined ASQA within ten (10) business days of the
until it takes effect – within 10 change taking effect.
business days of the change taking • If requested by ASQA, you ensure that you
effect; or provide information and evidence in relation to
ii. otherwise – as soon as practicable your material change application in a timely
before the change takes effect. manner.
4. A notice under subsection (1) or (3) must be Known risks to compliance
provided to the National VET Regulator in
writing or electronically. • Attempting to conceal material changes from
ASQA, particularly where there may be a risk
5. After giving notice under subsection (1) or (3) to students – for example, financial viability
an NVR registered training organisation must issues.
provide any further information relating to the
notice as soon as practicable, if requested by • Failing to update key personnel changes and
the National VET Regulator. contact details in ASQAs systems.
Third party arrangements
Requirement Example activities and other considerations for
compliance
1. An NVR registered training organisation must • You can demonstrate that all your third party
ensure that where services are delivered by a written agreements include all information
third party on the organisation’s behalf, the stipulated under the Standards.
provision of the services is governed by a • Your written agreements clearly specify the
written agreement that: roles and responsibilities of each party and how
a. is entered into by the organisation and you monitor the performance of the third party
third party as soon as reasonably to ensure the quality of services and
practicable prior to the third party compliance with the Standards.
delivering any of the services set out in
• You can demonstrate the systems and
the agreement;
processes you use to identify emerging risks
b. requires the third party to cooperate with and promptly rectify non-compliance by your
the National VET Regulator where the third party providers.
Regulator conducts any audit of the NVR
• You have evidence that a written agreement
registered training organisation’s
was in place with each of your third parties
operations;
before they commenced delivery of any
c. requires the third party to provide accurate services.
responses to requests for information from
• You can demonstrate how you routinely review
the Regulator relevant to the third party’s
the suitability of your third party arrangements
delivery of the services;
and maintain currency of your written
d. prohibits the third party from: agreements.
i. using the NRT logo; • You ensure your staff understand the definition
ii. using the organisation’s branding; of third parties and when a written agreement is
iii. issuing any AQF certification required.
documentation; and • You ensure that your third parties are aware of
e. contains the following particulars: their ongoing requirement to cooperate with
i. the business or trading names of the ASQA.
parties to the agreement; • You can demonstrate how you make your third
ii. the dates on which the agreement will parties aware of their obligations under the
commence and end; Standards and any other legislative or
regulatory requirements that apply to the
iii. all the parties’ obligations concerning service/s they are delivering on your RTO’s
the delivery of the services; and behalf.
iv. an entitlement for the organisation to
• You can demonstrate the protocols you have in
regularly monitor the quality of the
place to communicate with your third parties
services being delivered by the third
regarding:
party.
o legislative changes that may impact their
2. An NVR registered training organisation must
service
notify the National VET Regulator of any
written agreement made pursuant to o changes in delivery
subsection (1) within: o expectations around providing support for
a. 30 calendar days of the agreement being student wellbeing and managing
entered into or prior to the obligations complaints.
under the agreement taking effect, • You can demonstrate how you authenticate the
whichever occurs first; and credentials and practices of trainers and
b. 30 calendar days of the agreement assessors engaged by your third party
ending. providers.
• You ensure that VET students are made
aware of any third party involvement in their
training and assessment, including that their
AQF certification documentation will be
issued by your RTO (not the third party).
• You have processes in place to notify ASQA
within the required timeframe whenever you
enter into, or end, a third party arrangement.
Known risks to compliance
• Failing to notify ASQA of new and ceasing third
party agreements.
• Failing to undertake due diligence on an
organisation’s commitment, capability and
capacity to deliver quality training and
assessment before engaging it as a third party
– for example, but not limited to:
○ failing to undertake due diligence checks in
relation to the fitness and propriety of
relevant staff of the third party organisation
○ not comprehensively assessing the
capacity of the third party to provide
training support services and wellbeing
support services.
• Assuming that outsourcing services to third
parties will release your RTO of its compliance
obligations.
• Allowing services to be provided by a third party
before the written agreement has been signed
by both parties.
• Failing to invest in dedicated resources to
monitor the quality and compliance of services
provided by your third parties. This is of
particular concern where you have many third
party arrangements.
• Not being transparent with students about the
role and responsibilities of your RTO versus
those of the third party provider.
• Failing to inform students about how they can
provide feedback or make a complaint about a
third party engaged by your RTO.
• Engaging offshore-based third parties that are
unaware of relevant Australian laws and the
VET Quality Framework.
Prepaid fee protection measures
Requirement Example activities and other considerations for
compliance
1. Where an NVR registered training • You can show how your prepaid fee policy
organisation or third party receives prepaid ensures that students are adequately
fees from or on behalf of an individual in protected financially in accordance with this
excess of $1500 in relation to the same VET requirement.
course (the threshold prepaid fee amount), • You maintain adequate controls over how
the organisation must: withdrawals can be made from your protected
a. where the organisation is a government account and by whom – for example:
entity or an Australian university – o multiple signatories for withdrawals
comply with the requirements set out in
subsections (2) and (3); or o ensuring administrative staff are aware
that the protected account is only to be
b. where the organisation is any other NVR used to refund a student, not for other
registered training organisation – operational expenses.
implement one or more of the
arrangements set out in subsection (4). • You ensure prepaid fees received through a
direct enrolment are protected no matter how
the fees are collected, including where they
Requirements for government entities and are collected by a third party loan provider or
Australian universities via online payment instalments.
2. The NVR registered training organisation • Where you choose to hold an unconditional
must have a policy in place for circumstances financial guarantee from a bank operating in
where the organisation is unable to provide Australia, you ensure that:
the services to which the threshold prepaid o the guarantee is structured so that you
fee amount relates (prepaid fee policy). can promptly refund students’ prepaid
3. An NVR registered training organisation’s fees in excess of $1500 in circumstances
prepaid fee policy must specify how an where you are no longer able to deliver
individual who has prepaid will: the training; and
a. be placed into an equivalent course at a o you can demonstrate how the amount of
location suitable to the individual and the guarantee was determined; and
receive all services for which the individual o this level is always greater than the
has prepaid at no additional cost to the amount of fees required to be protected.
individual; or
• Where you choose to implement an alternative
b. be refunded the prepaid fees for services fee protection measure, you ensure that:
yet to be delivered which are in excess of
the threshold prepaid fee amount. o you apply to ASQA for approval in writing,
including details of how the measure will
be implemented; and
Requirements for other NVR registered training o the measure demonstrates an equivalent
organisations level of fee protection as that provided by
4. The NVR registered training organisation an unconditional financial guarantee from
must implement one or more of the following a bank operating in Australia; and
arrangements: o you wait until you receive approval from
a. an unconditional financial guarantee from ASQA before collecting fees in excess of
a bank operating in Australia, provided: $1500, unless you already have another
i. at all times, the guarantee is at least approved fee protection measure in place
equal to the total amount of prepaid fees in the interim.
held by the organisation in excess of the • If you utilise the Tuition Protection Service to
threshold prepaid fee amount; and protect fees paid by international students, you
ii. the costs of establishing and ensure that you have an alternative approved
maintaining the guarantee are met by fee protection measure for domestic VET
the organisation. students.
Note: For example, where an RTO receives prepaid fees • If you utilise the tuition protection
of $2000 from three individuals (totalling $6000), the arrangements under the VET Student Loans
guarantee must be at least equal to $1500 (i.e. $500
multiplied by three). Act 2016 for VET Student Loans (VSL), you
ensure that you have an alternative fee
b. a current membership with a tuition
protection measure for non-VSL students.
assurance scheme operator which, if the
organisation is unable to provide services • You ensure that your refund policy, that
for which the individual has prepaid, must students are provided with at the time of
ensure: enrolment, is reflective of the prepaid fee
i. the individual will be placed into an protection requirements.
equivalent course at a location suitable Known risks to compliance
to the individual and receive all services
for which the individual has prepaid at • Accepting prepaid fees before determining the
no additional cost to the individual; or suitability of a prospective student for the
course they are enrolling in.
ii. if an equivalent course cannot be found
– the individual will be refunded the • Failing to ensure that your fee protection
prepaid fees which are in excess of the method covers all applicable student cohorts
threshold prepaid fee amount. within the scope of your operations.
c. any other fee protection measure • Incorrectly assuming that multiple pre-paid
approved by the National VET Regulator. instalments of less than $1500 each for the
same VET course will avoid the threshold
prepaid fee amount and requirements
associated with it.
• Not monitoring the protected account to
ensure it is always equal to or greater than the
amount of fees required to be protected.
• Failing to ensure that prepaid fees above
$1500 that are collected through external loan
providers, including ‘buy now, pay later’
providers, are appropriately protected.
• Using the protected amounts and accounts to
pay for business operating expenses.
• Failing to have adequate controls over who
within the RTO can make withdrawals from the
protected account.
• Failing to limit online payment gateways to
$1500 where an RTO states it will not collect
more than $1500 in prepaid fees.
Public liability insurance
Requirement Example activities and other considerations
for compliance
An NVR registered training organisation must hold • You have evidence of how you determine
public liability insurance that covers all the appropriate and sufficient public liability
organisation’s operations for the entire period in insurance for your operations.
which the organisation is registered under the • You have systems and processes in place to
Act. ensure that any additions to scope including
activities such as work-integrated learning or
community-based learning, are covered under
your public liability insurance.
• You can demonstrate evidence of your public
liability insurance, such as a certificate of
currency, which:
o identifies that your RTO and its full scope
of operations is covered by the policy; and
o confirms that all VET students’ activities
are covered, or that there are no
restrictions on the activities covered.
Known risks to compliance
• Failing to ensure your public liability covers
your entire scope of operations, including
where training is delivered online.
Compliance with laws
Requirement Example activities and other considerations for
compliance
An NVR registered training organisation must • You can demonstrate how you identify all
comply with all applicable Commonwealth, State Commonwealth, State and Territory laws that
and Territory laws, including, for example, by are applicable to your RTO’s operations (e.g.
ensuring: the Work Health and Safety Act in your
a. personal information is collected, used jurisdiction/s).
and disclosed by the organisation in • You have systems and processes in place to
accordance with all applicable privacy ensure that your staff have knowledge of, and
laws; and comply with, all applicable laws at all times,
b. the organisation complies with all including any changes to legislative and
applicable requirements under the Student regulatory requirements that may affect the
Identifiers Act 2014. services delivered.
• You ensure that the design of training and
Note: There are a range of laws that may be applicable under assessment tasks does not breach the privacy
this section. The examples provided in paragraphs (a) and (b) of any individuals.
are for illustrative purposes.
• Before adding a training product to scope,
you ensure you have checked whether the
training product is required to be approved by
an industry regulator or if there are additional
licensing requirements to be able to deliver
and assess the training product.
• Where your operations involve children (e.g.
students under the age of 18), you ensure
your organisation and relevant staff are fully
compliant with child safety laws.
• You take active steps to protect VET students’
personal and sensitive information and ensure
the secure storage of VET students’
documentation and student identifiers.
Known risks to compliance
• Not identifying and considering all legislative
and regulatory requirements across your entire
scope of operations.
• Failing to train your staff on essential
legislative obligations, such as privacy laws
and work health safety obligations.
• Failing to gain the consent of all individuals
that may be involved in an assessment activity
(e.g. undertaking a personal care assessment
activity with an individual where that individual
has not given consent).
• Assessment activities that put students at risk
of breaching the law (e.g. recorded
assessment activities involving vulnerable
people electronically shared with your RTO).
Self-assurance questions
1 How do you ensure you are completing and submitting the Annual Declaration on Compliance
within the relevant reporting period?
2 How do you use the ADC process to demonstrate to ASQA that you self-disclose non-compliance,
as well as your organisation’s rectification and continuous improvement efforts?
3 How do you monitor your operations to identify whether there are, or likely to be, material changes
that require notification to ASQA?
4 What due diligence do you undertake before engaging a particular third party provider? What
verification do you undertake of their trainers and assessors’ qualifications?
5 How do you monitor your third parties to ensure they comply with all relevant legislative and
regulatory requirements?
6 How do you ensure you have sufficient protected funds to be able to refund students promptly, if
required?
7 How do you ensure your public liability insurance is adequate and covers all VET students in all
delivery settings?
8 How do you identify the Commonwealth, State and Territory laws that apply to your operations?
How do you ensure your staff and third party providers comply with these laws, including privacy
laws and child protection laws?
9 How do you monitor changes to legislative and regulatory requirements that may affect the
services that you deliver?
Source: ASQA Practice Guide — Accountability. Published 17 June 2025, Version 1.0. Authority: Australian Skills Quality Authority. These guides interpret the Standards for RTOs 2025 into practical compliance guidance. The PDF was extracted with pdftotext -layout to preserve the two-column table structure of the original document.