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One of the clearest emerging compliance risks for RTOs is assessment integrity — particularly in an AI-enabled environment. Increasing regulatory focus is moving toward: • AI-related assessment misconduct • authenticity of student evidence • observation-based assessment practices • and whether competency can genuinely be verified. Does your RTO assessment evidence demonstrate: ✔the learner completed the work themselves? ✔ the evidence is authentic and current ✔ observa

ASQA has released today a Statement of Regulatory Expectations on: Fit and Proper Person Requirements and Notification of material changes Reinforcing RTOs must engage with ASQA in an open, honest and transparent manner. A good reminder on the specific obligations and 10 day rule

Increasingly, regulators appear to be assessing whether compliance is embedded into everyday operations — not just prepared for audits. There’s a big difference between: “audit-ready” and “operationally compliant.” The organisations navigating change best are the ones where compliance is part of everyday practice You may have all the documents - but do you have the actions? Interested in assessing your organisation? E: compliance@assessconsulting.com.au #RTO #CRICOS#GT

If you’re a CEO, Compliance Lead, or Board Member across an RTO, CRICOS provider, or GTO — these are questions worth asking today. When was your last real Board due diligence review? Not a meeting. Not minutes. A genuine, evidence‑based assessment of governance oversight. In the last 3–6 months: • Has your Board formally reviewed its own effectiveness? • When was your last Board meeting — and what high‑risk areas were actually scrutinised? • Were actions monitored, closed out

This is where regulatory action escalates to: conditions, suspension and cancellations. Common red flags that trigger attention immediately: • Students enrolled but not consistently engaged in training • High completion rates with little evidence of competency • Heavy reliance on agents with limited oversight • Sudden growth that doesn’t match your systems, staff, or infrastructure • Rapid ownership, directors or control changes that raise questions • Links to previously

Do you have apprentice or trainee placements that struggle… especially at the start? It’s not the apprentice. It’s not the employer. It’s the lack of structure and support around the arrangement. That’s where the GTO (Group Training Organisation) model outperforms. ✔ Clear expectations from day one ✔ Coordinated support ✔ Someone overseeing the full picture GTOs — through their dedicated Field Officers — are responsible for: • Employment • Ongoing support • Coordination

How would it fit with an RTO ? A Group Training Organisation (GTO) employs apprentices and trainees directly, then places them with host employers for their workplace training and experience. GTO = employer and support organisation RTO = training provider Host employer = workplace where practical skills are developed For many businesses, the GTO model can be a lower-risk and more supported way to take on an apprentice or trainee because the GTO often manages things like: •

If ASQA reviewed your student files tomorrow —would they be easy to defend? Gaps in student files can impact compliance across multiple Standards (2, 3, 5, 7, 8, 10, 11) of the National Code 2018. From recent reviews of CRICOS providers, common patterns include: • evidence spread across too many places, emails, handwritten notes, SMS • limited documentation of pre-enrolment information and suitability decisions • inconsistent application of entry requirements • reliance o

For international students, compliance starts before they accept the offer. Marketing and Information Practices can expose providers as high risk if incorrect. They are a core part of your compliance framework. What a student sees, reads, hears and relies on before they enrol matters. This is a requirement of Standard 1 of the National Code 2018. Issues I continue to see in reviews: • course information that is too broad or unclear • inconsistent information across websit

One of the biggest risk areas I see in practice is this: How did the provider determine that this student should be enrolled in this course? Under Standard 2 of the National Code 2018 – Recruitment of an Overseas Student , providers must recruit responsibly and ensure overseas students are appropriately qualified for the course they are seeking to enrol in. This also means students must be given sufficient information to make informed decisions about studying with the provide

ASQA has already told the sector where they’re looking in 2026. Risk Area 1: Shortened Course Durations. One of the fastest ways is this: Running qualifications in timeframes unrealistic for the learner cohort. I continue to see this issue in audits and reviews — particularly where: • learners are new to the industry • the qualification is in a higher-risk sector • the course duration has been significantly shortened “fast tracked” • there is little evidence showing why

Under the Accountability requirements in the 2025 Standards, engaging a third party increases your risk if not managed appropriately. Areas of concern I continue to see in audits and reviews: • Not updating ASQA when third-party arrangements start, change, or end • Partnerships without checks if they are actually capable of delivering quality outcomes • Lack of evidence on verifying third party trainer credentials, background, and suitability • Overlooking if the third

Many RTOs believe they have transitioned to the Standards for RTOs 2025 — but updating documents alone does not demonstrate compliance in practice. In recent reviews I’ve conducted, the issue wasn’t intent — it was that operational evidence did not demonstrate the outcomes. This is exactly what ASQA is flagging in reports: “there is a policy however the evidence did not demonstrate the implementation of the Outcome Standard in practice” Common mistakes I’m seeing: 1. Po

Recent reregistration assessments have identified concerning non-compliances against Outcome Standard 4.3 under the Standards for RTOs 2025, requiring that any risks to VET students, staff, and the organisation are identified and managed, including real or apparent conflicts of interest. What ASQA is assessing here is whether your conflict-of-interest frameworks genuinely protect students, staff, and organisational integrity — in practice. Areas of concern I continue to see i

Recent performance assessments, ASQA has identified concerning non-compliances against Outcome Standard 3.1 under the Standards for RTOs 2025. Outcome Standard 3.1 requires that the workforce is effectively managed to ensure appropriate staffing to deliver the services the RTO offers and that staff have access to continuing professional development to perform their roles effectively. What ASQA is assessing here is whether your workforce model genuinely supports quality traini

From 3 - 31 March, CEOs of RTOs regulated by Australian Skills Quality Authority must submit their Annual Declaration on Compliance. This is the first ADC against the Standards for RTOs 2025 and is directly relevant to Compliance Requirement – Accountability. When the CEO clicks submit, they are confirming that the organisation has: ✔ Transitioned to SRTO 2025 ✔ Implemented the new requirements ✔ Is operating in compliance with those obligations This is a legal declaration

I’ve noticed discussion emerging on 3 linked questions on vilification and anti-semitism. What concerns me is not the wording — but the governance implications These are under Outcome Standard 2.5 Diversity, Inclusion & 2.6 Wellbeing. 1️⃣ Policy & Code of Conduct Question Do you have published or readily available a policy or code of conduct for staff or students dealing with vilification, including anti-semitism? Answer options: ✔ Yes – staff only ✔ Yes – students only ✔

Up to October 2025, ASQA identified continued non-compliance in performance assessments for registration management against Outcome Standard 1.8 under the RTO Standards 2025. Outcome Standard 1.8 requires that facilities, resources and equipment for each training product are fit-for-purpose, safe, accessible and sufficient. What ASQA is assessing here is whether your delivery environment genuinely supports competency for students. Areas of concern I continue to see in audits

On 20 January 2026, the National Code of Practice for Providers of Education and Training to Overseas Students Amendment (Education Agent Commissions) Instrument 2026 was registered. The amended National Code took effect the day after registration. What’s changed Standard 4 of the National Code has been amended to ban the payment of education agent commissions for the recruitment of a student who is transferring from another provider. This applies to: – percentage or flat-fee

Outcome Standard 1.1 requires that training is engaging, well-structured and enables VET students to attain skills and knowledge consistent with the training product. Up to October 2025, ASQA found 15 providers non-compliant against Outcome Standard 1.1 under the RTO Standards 2025. What ASQA is assessing here isn’t what’s written in your documents — it’s what’s actually happening in delivery. Areas of concern I’m seeing in training delivery: • Training delivery modes not al