Compliance Reference¶
This is the bridge doc between the Standards for RTOs 2025 and the RTOpacks platform. It maps which module, surface, or product capability addresses which standard or credential requirement.
Purpose:
- Ground product work in the judgement criteria. Every RTOpacks feature is ultimately judged against the Standards. This doc names that mapping explicitly so we don't drift.
- Power Guided Mode. This is the substrate that lets a surface in the product say "this addresses Standard 1.5 and Credential Policy 3A." The Nova Corp pattern: turn guided mode on, see the compliance anchoring.
- Scope discipline. Makes clear what RTOpacks does not cover — SMS/LMS/CRM obligations the spine is not responsible for.
This doc is living. Seeded from the current WS-PRODUCT-01 v0.3 and the six module specs. As modules evolve, update the mapping here in the same commit.
The RTOpacks scope claim¶
RTOpacks is the educational content creation and workforce compliance layer for Australian RTOs, contextually aware of the regulatory text that will be used to judge it.
Not in scope: - Student management systems (enrolment, scheduling, progression tracking) - Learning management systems (content delivery, attempt tracking, LMS gradebook) - Customer relationship management (lead capture, marketing automation) - Financial systems (accounting, payroll, student billing — though integrations exist via SMS Connect)
In scope: - Training product design (Studio) - Workforce credential and currency management (People) - Evidence generation and Standards mapping (Record) - Credential issuance (InstaLearn) - RTO intelligence (Radar / Field Observer) - Cross-module compliance monitoring (Observatory)
Standards RTOpacks cannot satisfy alone but supplies critical infrastructure for: - Some of Part 2 (student support, delivery) — depends on LMS/SMS - Section 9-10 issuance and record retention — depends on integration with SMS - Section 18 prepaid fee protection — depends on finance/banking
Module × Standard map¶
Studio¶
Primary standards addressed.
| Standard | What Studio does |
|---|---|
| 1.1 — training engaging and well-structured | Qual tree canvas with unit-level structure, clustering support, content node types (written, quiz, upload, video call, observation, practical), paced delivery mapping |
| 1.2 — industry engagement | Industry engagement surfaces (where present) — noting that capturing industry advice and feedback into training design happens here |
| 1.3 — assessment system fit-for-purpose | Assessment tool design nodes anchored to performance criteria and knowledge evidence |
| 1.4 — fair and valid assessment | Assessment tool design against principles of assessment + rules of evidence |
| 1.6 — RPL | Unit-level structure supports RPL workflow (process lives elsewhere) |
| 1.7 — credit transfer | Equivalent to 1.6 |
Secondary/indirect. - 1.5 — validation: Studio's content is what gets validated. Validation scheduling lives in Record. - 3.2 — trainer assignment surfaces read from People to show credential status inline.
Compliance Standards touched. - Section 14 — transition of training products: Studio reads TGA for superseded/non-current status and flags impact on designed content.
Guided Mode anchoring. Every Studio surface that renders unit content, assessment tools, or qual structure is anchoring against Standards 1.1–1.4. This is load-bearing — it's the primary reason Studio exists.
People¶
Primary standards addressed.
| Standard | What People does |
|---|---|
| 3.1 — workforce management | Trainer Register as the system of record. Workforce planning visible. CPD log supports PD evidence. |
| 3.2 — trainer/assessor credentials | The four compliance dimensions — Credential Status, Vocational Competency, Industry Currency, T&A Currency — are People's core data model. |
| 3.3 — experts under direction | Expert records and direction relationships (Phase 2) |
Credential Policy. People is the direct home for the entire Credential Policy. Specifically:
| CP Section | Where in People |
|---|---|
| 1A — training and assessment credentials | Credential records on trainer profile, validated against allowed credential list |
| 1B — assessment only | Role-scoped credential validation |
| 1C — actively working towards | "Working towards" status + enrolment/progression tracking + 2-year horizon + direction link |
| 1D — training and assessment under direction | "Under direction" status + direction relationship |
| 1E — providing direction | "Director" capability on eligible trainer records |
| 2A-2C — TAE delivery | Scoped TAE delivery capability |
| 3A-3B — validation credentials | Validator eligibility (used by Record/Observatory for validation scheduling) |
Secondary. - 1.5 — validation: validator eligibility check reads from People. Validation scheduling and outcomes live in Record. - 4.1 / 4.2 — governing persons and role definition (Phase 2). - 4.3 — under-18 safeguarding, where trainer/staff records touch child-safe obligations (Phase 2).
Compliance Matrix. Persons × qualifications with cell-state logic is the audit output surface for Standards 3.1 and 3.2. CSV export provides the evidence artefact.
Record¶
Primary standards addressed.
Record is the evidence spine. It does not own any truth — it expresses the truths held by Studio and People as documentary evidence against the Standards.
| Standard | What Record does |
|---|---|
| 1.5 — validation | Validation scheduling, outcomes, evidence. Reads validator eligibility from People (CP Section 3A/3B). Risk-based sampling surface. 5-year cycle management. |
| 2.7 — feedback/complaints | Policy library for complaints management. Evidence of resolution, systemic use. |
| 2.8 — appeals | Parallel to 2.7 — policy, evidence. |
| 4.1 — integrity | Governance policy suite. Fit and Proper evidence bundle (see CS Sch 1). |
| 4.2 — roles and third-party monitoring | Third-party agreement repository + monitoring records. Staff role documentation. |
| 4.3 — risk | Risk register, conflict-of-interest register, under-18 safeguarding artefacts. |
| 4.4 — continuous improvement | CI register, monitoring artefacts, feedback-to-improvement evidence chains. |
Compliance Standards ownership. Record is the primary home for:
| Section | What Record does |
|---|---|
| 9 / 10 — issuance + records | Certification issuance records (30-year retention), assessment records (2-year retention). Integrates with InstaLearn for issuance trigger. |
| 15 — annual declaration | Annual declaration artefact assembly. |
| 16 — notification of material changes | Notification record trail. |
| 17 — third party agreements | Agreement repository — written agreements, 30-day notification trail, monitoring artefacts. |
| 18 — prepaid fee protection | Policy artefact. Does not solve the finance problem — just holds the policy. |
| 19 — public liability insurance | Insurance certificate repository. |
| Sch 1 §§ 2–7 — Fit and Proper | Fit and Proper evidence bundle per governing person. |
Standards mapping. Every document/artefact in Record is tagged with the standard(s) it addresses. A single policy may address multiple standards — that many-to-many relationship is the schema. This is the Guided Mode data.
InstaLearn¶
Primary standards addressed.
| Standard | What InstaLearn does |
|---|---|
| 9 — issuance of AQF certification | Credential issuance triggered by verified completion, within 30-day window. |
| 11 — qualification/SoA format | Issued credentials meet AQF Qualifications Issuance Policy requirements. |
| 12 — student identifier | USI verification. Non-inclusion on credential. Exemption notification. |
| 13 — NRT Logo | NRT Logo application per Schedule 2 — green PMS 343 / red PMS 192, Fritz Quadrata descriptor, triangle+descriptor only. |
Secondary. Ties back into Record for long-term record retention (Section 10).
Radar / Field Observer¶
Primary standards addressed.
Radar is intelligence, not compliance infrastructure. It does not directly address Outcome Standards. However, it supports:
- 4.3 — risk management: competitive and sector intelligence informs risk landscape.
- 4.4 — continuous improvement: sector observation feeds CI inputs.
- Section 7 — marketing: reference surface for what compliant/non-compliant RTO marketing looks like in the sector.
Radar is outside the spine. Inclusion in RTOpacks is strategic, not regulatory.
Observatory¶
Observatory is the read-across layer. It does not own standards but surfaces the compliance picture across all spine modules:
- "What is red right now?" — 3.2 credential gaps, 1.5 validation overdue, 2.8 appeals open, etc.
- "What expires in 30 days?" — credential/currency/agreement/validation cycle boundaries.
- "What actions are outstanding?" — drive-to-green across the whole system.
- "What does the self-assurance system show?" — the rolling picture.
The unified review and scheduling system flagged in WS-PRODUCT-01 as a gap is Observatory's Phase 1 design problem. Every compliance obligation has a cadence — Observatory is the single surface that says "what is due when."
Gaps — where the spine does not fully own¶
Per WS-PRODUCT-01 v0.3, three obligations are not fully resolved:
| Gap | Standards involved | Likely home |
|---|---|---|
| Validation process management | 1.5, CP 3A/3B | Record Phase 2 surface, reading validator eligibility from People |
| Third-party monitoring process | 4.2, Section 17 | Record surface with People integration |
| Unified review/scheduling | Cross-cutting cadence | Observatory Phase 1 |
Each needs a dedicated design decision before the relevant module's Phase 2.
Standards out of scope for RTOpacks¶
Some standards require infrastructure RTOpacks does not and will not provide:
| Standard | Why out of scope | What satisfies it |
|---|---|---|
| 1.8 — facilities/resources/equipment | Physical infrastructure. Can hold the policy artefact in Record. | RTO's physical setup; evidence artefacts in Record. |
| 2.1, 2.2 — pre-enrolment information | SMS/CRM territory. | Student management system / LMS pre-enrol flows. |
| 2.3, 2.4 — training support, safe environments | Delivery-time obligations. | LMS, in-person delivery operations. |
| 2.5, 2.6 — diversity, wellbeing | Programme-level operations. | Organisational practices; policies tracked in Record. |
| Section 18 — prepaid fees | Finance/banking product. | Bank guarantee, tuition assurance scheme, finance operations. |
| Section 19 — public liability insurance | Insurance product. | Insurer. |
| Section 20 — compliance with laws | General legal compliance. | Legal counsel, policy in Record. |
Record can hold policy artefacts relating to these standards. RTOpacks does not solve them, but documents that the RTO has.
Self-assurance question mapping¶
ASQA's self-assurance model asks seven questions. RTOpacks covers them as follows (per WS-PRODUCT-01):
| Self-assurance question | Primary module(s) | Primary standards |
|---|---|---|
| Are we training and assessing to the training product? | Studio, People | 1.1–1.4, 3.2 |
| Are our trainers and assessors qualified and current? | People | 3.1–3.3, Credential Policy |
| Is our assessment producing consistent outcomes? | Studio, Record | 1.3–1.5 |
| Do we support students to succeed? | Record (policies); out-of-spine for delivery | 2.1–2.6 |
| Do we learn from feedback and complaints? | Record | 2.7, 2.8, 4.4 |
| Are we operating with integrity? | Record, People | 4.1, 4.2, FPP |
| Do we manage risk and continuously improve? | Observatory, Record | 4.3, 4.4 |
Guided Mode contract¶
When a user turns on Guided Mode on any RTOpacks surface, the surface must answer:
- Which standards does this surface address? — the primary + secondary list.
- Why is this field / control / data point here? — its regulatory purpose.
- What happens if this is empty, stale, or wrong? — the compliance consequence.
- Where is the evidence this generates stored? — the Record linkage.
This doc is the data layer for that answer. Every surface that exposes Guided Mode tooltips is reading against a mapping defined here.
Maintenance rule¶
This doc lives at docs/ops/compliance-reference.md (or equivalent). It is updated in the same commit as any module spec change that alters the mapping. When a module spec bumps a version, the relevant row in this doc is reviewed.
If Guided Mode is surfacing a standard reference in the product, that reference must be sourced from this doc. No inline-hardcoded standards references in module code.
Seeded April 2026 from WS-PRODUCT-01 v0.3 and the current module spec set. Living document — revise as modules ship and as the Standards are interpreted in practice through ASQA guidance and audit outcomes.