🚨 RTOs: Third Parties Are Still One of the Biggest Compliance Risks

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 party can genuinely support students (not just deliver training)

 • Third Party unaware of compliance requirements and obligations

 • Services commencing before agreements are formally signed

 • Students unclear about who is responsible for what

 • No clear pathway for students to give feedback or lodge complaints about third parties

 • Offshore partners operating without understanding Australian VET obligations

 • Too many third parties with no oversight structure in place

 • Monitoring is existing only as paperwork — with no real observation or proof

 • Third-party websites and marketing that don’t meet regulatory requirements

Third Party Compliance Checklist

·      Have you notified ASQA of ALL third-party arrangements (past & current)?

·      Do you have signed agreements in place before services commenced?

·      Have you completed and documented due diligence (capability, capacity, staffing)?

·      Do you have evidence of monitoring beyond checklists (e.g. observations, audits, records)?

·      Are your third-party marketing and recruitment practices compliant?

·      Are students clearly informed 

·      How are offshore partners trained in Australian VET and regulatory expectations?

·      Do you have dedicated resources overseeing third-party performance?

In the Annual Declaration of Compliance due by 31 March, this question matters more than most:

Have you engaged ANY third party (past or present) to deliver training, assessment, or other services? Even if the arrangement is no longer active — it still counts.

Compliance Tips: 

 ✔️ Formalise Third Party Governance

 Establish a documented framework that defines approval, onboarding, monitoring, and review processes — not just contracts.

✔️ Evidence What You See — Not Just What You Sign

 Monitoring must include observation, validation, and documented findings — not just completed checklists.

✔️ Centralise Control and Accountability

 Assign clear internal ownership for third-party oversight 

Need Help? 

If you’re unsure whether your third-party arrangements would stand up to scrutiny email: compliance@rtostandards2025.com.au and we will share our Third-Party Audit Checklist.