Leadership and Accountability — Practice Guide¶
ASQA Practice Guide · Quality Area 4 — Governance · Standards 4.1, 4.2 · 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
Leadership and Accountability
(Standards 4.1, 4.2)
Ver 1.0
S
Published 17 June 2025
Outcome Standards for NVR Registered Training Organisations
Quality Area 4 – Governance
What are the key concepts?
The following key concepts are covered in this practice guide:
Standard 4.1 Standard 4.2
• Suitability of governing persons • Roles and responsibilities
• Information to support governing persons • Accountability
• Organisational culture • Ensuring compliance (including third parties)
Achieving these Standards in practice
The following table lists examples of activities that may demonstrate compliance with the Standards, as
well as risks to mitigate or control. These examples are not a complete list of every activity or risk, nor do
all the activities listed need to be completed to achieve compliance. Rather, they are a guide and should
be considered within the context, size, scale and student cohorts of your RTO’s operations.
Standard 4.1: An NVR registered training organisation operates with integrity and maintains
accountability for the delivery of quality services
Performance indicators Example activities and other considerations for
compliance
An NVR registered training organisation • You can demonstrate the due diligence you
demonstrates: undertake to assure yourself that your RTO
a. the organisation and its governing persons staff are fit and proper in respect of the public
are fit and proper persons, having regard to being able to have confidence in their suitability
the Fit and Proper Person Requirements to be involved in VET delivery.
made under section 186 of the Act, as in • You have up to date records of your RTO’s
force from time to time; governing persons, being all executive
b. its governing persons are suitable persons to officers, high managerial agents and any
oversee the operation of the organisation; persons who exercise a degree of control or
influence over the management or direction of
c. its governing persons act diligently and make your RTO.
informed decisions which facilitate
compliance with this instrument and any • You are timely in submitting a Fit and Proper
other instrument made under section 185 of Person Declaration, in accordance with ASQA’s
the Act, as in force from time to time; and requirements.
• You can show how governing persons are
d. the governing persons lead a culture of
driving the right culture and holding staff and
integrity, fairness and transparency in the
others responsible for high quality training
organisation’s delivery of services.
delivery. The ways this is demonstrated may
vary but governing persons can describe how a
culture of accountability, fairness and
transparency is fostered within the RTO and
their expectations of staff, students and others
(such as third parties) are conveyed and
understood.
• You can articulate how governing persons
communicate and drive the vision, purpose,
commitment and capability of the RTO.
• You have evidence of regular evaluation of your
organisation’s governance structures and
systems – for example by gathering feedback
on how your organisation is perceived in terms
of integrity and quality.
• You undertake external and peer reviews of
your organisation’s governance and control
structures, and initiate action plans to
continuously improve your governance
operations.
• Your governing persons can describe how they
access the information they need to make
informed decisions about the RTO’s compliance
with the Standards, including identifying areas
for improvement.
• You can show how you use data and evidence
to support your RTO’s compliance and integrity,
including:
o student enrolment, progression and
completion data
o student feedback, complaints and appeals
o industry and employer feedback
o outcomes of self-assurance or review
activities.
• You can demonstrate that there is a sufficient
level of financial acumen across the Executive
team.
Known risks to quality outcomes
• Failing to adopt governance structures,
processes and procedures that ensure your
RTO staff are, and remain, fit and proper in
respect of their particular roles in VET delivery.
For example, failing to undertake due diligence
checks as part of your general recruitment or
selection practices, and intermittently
throughout their engagement/ employment.
• Inadequate governance to manage risks and
safeguard against improper or illegal conduct
and prevent the RTO from being vulnerable to
insider exploitation or criminal activities.
• Insufficient processes in place to ensure
governing persons continue to meet the Fit and
Proper Person Requirements.
• Shadow-directorship in an organisation that
leads to a failure to recognise all governing
persons with influence.
• Failing to detect and respond to behaviours or
individuals in the organisation that are
undertaking concerning or suspicious activity.
• Not requiring staff or governing persons to
properly disclose their interests in other
corporations or organisations.
• Not acting on feedback received from students,
industry or the community related to the quality
and integrity of RTO operations.
Standard 4.2: Roles and responsibilities of NVR registered training organisation staff and third
parties are clearly defined and understood
Performance indicators Example activities and other considerations for
compliance
An NVR registered training organisation • You have systems in place to document and
demonstrates: communicate lines of accountability, staff roles
a. It supports staff members to understand and responsibilities (including compliance
the components of this instrument and any obligations), and these are well understood
other instrument made under section 185 within the organisation.
of the Act, as in force from time to time, • You have documented decision making
which are relevant to each staff member’s accountabilities and delegations that are
role as an employee of the organisation; adhered to by all staff.
b. It informs staff members of any changes to • You can demonstrate your processes to
regulatory or legislative requirements that support staff, including those of third parties, to
may affect the organisation’s delivery of understand the Outcome Standards and
services; Compliance Requirements and to keep them up
c. It has a system in place for ensuring any to date on any relevant changes to regulatory
third parties meet the requirements of this requirements that will impact their work.
instrument and any other instrument made • You can show how staff, including those
under section 185 of the Act, as in force employed by third parties, are supported to
from time to time, and are aware of their drive a culture of compliance and continuous
obligations under these instruments; and improvement including providing opportunities
d. the roles and responsibilities of persons for them to proactively raise issues and areas
engaged by the organisation are well for improvement.
understood and documented, ensuring • Your staff can describe how they identify and
accountable decision-making. report compliance risks, particularly where they
may impact student wellbeing or outcomes.
• You can demonstrate your systems for
monitoring and reviewing third party compliance
– for example, you have evidence that your
third parties are aware of, and meet, their
obligations under the Standards, and have
recorded the action you will take if they are not.
Known risks to quality outcomes
• Roles and responsibilities are not clearly
understood by staff and/or reporting lines do
not support the identification, escalation and
resolution of compliance risks.
• Purchased ‘off-the-shelf’ systems for managing
compliance with the Standards are not
contextualised to the organisation’s needs.
• Identified compliance or integrity risks are not
addressed in a timely manner.
• Neglecting to ensure that this Standard is
applied with sufficient rigour to third parties and
their staff, and not maintaining a process for
managing risks against the Standards
associated with third parties.
Self-assurance questions
How do you ensure governing persons are suitable, fit and proper and remain so throughout their
1
engagement with your RTO?
What systems and processes are in place to ensure governing persons are acting diligently
2
and within their delegated authority?
How do you ensure governing persons are familiar with the Standards and aware of their
3
responsibility to monitor the organisation’s performance against them?
How does the organisation communicate and monitor its values and drive a culture of compliance
4
and continuous improvement?
What due diligence do you do during your recruitment and performance management of your RTO
5
staff to ensure that they are fit and proper for their role?
What systems and processes do you have in place to determine, communicate and monitor staff
6
roles, responsibilities and accountabilities within the RTO?
How do you ensure staff remain familiar with the Standards and any changes to regulatory
7
requirements?
How do you support staff to voluntarily report compliance and integrity risks?
8
What systems and processes do you have in place to respond to and address compliance and/or
9
integrity risks that are reported or identified?
What systems, processes and monitoring activities do you have in place to oversee and ensure
10
third party compliance with the Standards?
Source: ASQA Practice Guide — Leadership and 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.