🚨 ASQA is flagging conflicts of interest as an ongoing compliance and governance risk for RTOs and CRICOS providers

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 in audits:

• Trainers signing assessments for related students

• Trainers external business taking RTO students for work placement inappropriately

• Related parties to RTO persons signing voluntary industry currency letters for trainers 

• Certificates issued for trainer in RTO by related party without assessment evidence 

• Education agents or third parties influencing enrolments without transparent oversight

 • Directors or staff holding financial interests in related entities without disclosure

 • No documented conflict of interest policy or procedure

 • No registers or declarations maintained for staff, trainers, or governing persons

 • No segregation of duties or monitoring for risk areas

 • Staff or third parties unaware of what needs to be disclosed and how

Conflict of Interest Compliance Checklist:

 ✅ Is there a documented Conflict of Interest policy and procedure?

 ✅ Do all staff have access to current guidance on managing conflicts?

 ✅ Are there annual declarations and an active conflict register?

 ✅ Are actual, potential, or perceived conflicts assessed and managed?

 ✅ Is there a culture promoting disclosure of conflicts internally?

 ✅ Are third parties monitored for conflicts that could affect operations or students?

 ✅ Are escalation pathways and auditing processes documented?

Compliance Tips:

 • Implement a Conflict of Interest framework with clear processes for declaration, assessment, management, and escalation

 • Ensure all staff, trainers, and governing persons understand their obligations and how to disclose conflicts

 • Monitor both internal and third-party conflicts proactively

 • Promote a culture of transparency and integrity in all operational decisions

 • Document monitoring, review, and governance actions to provide audit evidence

Think about it:

 If ASQA reviewed your policies, registers, staff declarations, and work placement arrangements — would they clearly demonstrate that your RTO identifies, discloses, and manages conflicts of interest effectively?

Need help?

If you’re unsure whether your conflict-of-interest framework meets Outcome Standard 4.3, need a solution ! compliance@rtostandards.com.au