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Frequently Asked Questions

  • The fundamentals remain the same: trainers and assessors must hold an approved training and assessment credential (currently the TAE40116 Certificate IV in Training and Assessment or its successor) and have current vocational competence for the subjects they deliver and assess[26]. In other words, every trainer needs both pedagogical qualifications and experience/qualifications in the specific industry area of each course. ASQA’s 2025 updates didn’t remove these core requirements, though minor clarifications were made in the new Standards.

  • No. They must be able to demonstrate vocational competence at least to the level of the training product being delivered[27]. This can be shown through holding an equivalent or higher qualification in the same field, and/or through recent, relevant industry experience. For example, a trainer delivering a Certificate IV in Plumbing doesn’t need that exact Certificate IV if they have a related higher qualification or significant industry experience demonstrating they have mastered those skills. The key is evidence – mapping their quals and experience to the course’s requirements.

  • A combination of documents can be used. Commonly, you would keep on file: higher or equivalent qualifications (degrees, diplomas, etc.), mapping of experience (a detailed resume or log of work roles and tasks that correspond to unit outcomes), records of recent industry practice (letters from employers, projects completed), and any portfolios of work or professional licenses. The evidence should collectively cover the full breadth and depth of the unit or qualification outcomes that the trainer will deliver/assess.

  • Yes – but only under the direct supervision of a qualified trainer/assessor. The Standards allow industry experts who don’t hold the training credential to assist with training in their area of expertise[29]. However, they cannot determine assessment outcomes. The RTO must document how a qualified trainer exercises oversight: planning the lessons, mentoring the expert, and quality checking the delivery. The intensity of supervision should reflect the expert’s experience and the risk involved – higher risk or inexperienced experts need closer supervision.

  • RTOs must ensure trainers/assessors undertake continuous professional development in two key areas: (1) VET knowledge and practice – e.g. attending TAE workshops, participating in validation sessions, learning new assessment techniques; and (2) industry currency – staying up to date in the field they teach. A good PD plan might include attending industry conferences, doing short courses, engaging in industry networks, or returning to industry for brief stints[32]. The expectation is that PD is planned and regular (at least annually) and that it covers both teaching skills and technical industry skills. Document all PD activities in a log with dates and descriptions as evidence.

  • Maintain a currency log for each trainer, with entries of activities that keep them current. This could include recent employment in the industry, attending manufacturer or vendor training on new equipment, active membership in industry associations or committees, participating in industry projects, or even things like reading industry journals (with reflection notes). The log should be supported by evidence where possible (letters from employers, certificates of completion, notes from site visits, etc.). Essentially, you’re painting a picture that your trainers know the present-day workplace expectations and technology in their field.

  • Each trainer’s file should be a one-stop collection of documents proving they meet all requirements. Typically, it would include: a certified copy of their training and assessment credential (e.g. TAE40116 certificate), copies of vocational qualifications they rely on, a current CV detailing industry experience, the industry currency log with supporting evidence as discussed, records of any professional development completed (with evidence/certificates), their position description or role statement with the RTO, any supervision agreements (if they are under supervision or supervising someone), and a current matrix mapping which courses/units they are approved to deliver and assess and how their quals/experience justify each. Keeping this file up to date is crucial for audits.

  • At least annually. Many RTOs align this with the performance review cycle or prior to scheduling the upcoming year’s classes[35]. You should also update profiles whenever there’s a significant change – for example, if you add a new qualification to scope (you’d ensure relevant trainers have the credentials/currency for it), or if a trainer’s circumstances change (new qualification attained, or they left an industry role which might affect currency). Regular review ensures that if ASQA audits you or asks for evidence, you can confidently demonstrate all trainers remain suitably qualified and current.

Assessment Design, Integrity & Validation

  • A compliant assessment system is one that validly and reliably assesses all required outcomes of a unit or qualification. In practice, this means:

    • Every unit’s assessment tools must cover all elements, performance criteria, required knowledge and skills, etc., with tasks that allow the student to demonstrate competency.

    • Evidence collected must be sufficient, authentic, current, and valid – align with the rules of evidence.

    • Assessments must be applied consistently by all assessors (standardization is key).

    • The RTO should have a process to review and improve assessments (validation and moderation – see below).

    In summary, compliance isn’t about having paperwork for its own sake, but about ensuring your assessment genuinely measures student competence and is applied fairly across the board.

  • Yes. Mapping is explicitly required under the Standards. You should maintain clear mapping documents that show exactly where each requirement of the training package is assessed. This means mapping every element, performance criterion, knowledge evidence, performance evidence, and assessment condition to specific questions or tasks in your assessment tool. During audit, ASQA will ask for mapping to verify that nothing is missed. Good mapping also helps in validation and when updating assessments for new training package versions.

  • You need a multi-faceted approach to ensure the work is the student’s own. Common strategies:

    • Verify identity for assessments (especially online) – e.g. use student ID checks, unique login credentials, or supervise key assessments in person.

    • Have students sign a declaration of originality for each assessment submission.

    • Use plagiarism detection software for written work.

    • Design tasks that are less prone to cheating (contextualized to the student’s workplace or requiring personal reflection).

    • Consider oral questioning or viva voce exams to confirm knowledge in person after a written submission.

    • Consider oral questioning or viva voce exams to confirm knowledge in person after a written submission.

    Also, educate students up front about academic integrity. A clear policy plus consistent enforcement (with consequences for cheating) will deter misconduct.

  • Validation is a post-assessment quality review process, whereas moderation is a pre- or during-assessment consistency check.

    • Validation involves reviewing assessment tools and decisions after assessments have been completed. An independent validator (or team) looks at a sample of assessments to confirm that the tool effectively measured the required outcomes and that assessor judgments were sound. It’s about the quality of the tool and process.

    • Moderation is the process where assessors compare and discuss their assessment decisions either before marking (agreeing on how to interpret criteria) or during/after marking individual assessments to ensure consistency among assessors. It’s about reaching a shared understanding so that regardless of who assesses, the standard is the same.

    In short: validation = checking the assessment design/results; moderation = making sure assessors are on the same page for judgments.

  • The Standards (as of 2025) require that every training product (qualification or skill set) undergo validation at least once every five years, with at least 50% of products validated within the first 2.5 years of the cycle[37]. Additionally, you should do earlier or more frequent validation where there are risk triggers – for example, if lots of students fail a particular unit, or an industry change occurs, or ASQA identified issues previously. Many RTOs schedule validation more regularly (e.g. annually by cluster of courses) to ensure compliance and continuous improvement.

  • Validation must be done by people who are not directly involved in the delivery or assessment of the particular instance being validated, and who collectively have: vocational competency in the subject matter, current industry skills, and assessment expertise (credentialled assessors). In practice, this often means you’ll have at least two people: one with deep subject matter knowledge (and ideally holding the TAE as well), and one with strong assessment experience (like a lead trainer from another course or an external consultant). They can be internal staff as long as they weren’t involved with the delivery/assessing of that student cohort, or completely external. What’s important is that the validation is impartial and robust.

  • Yes. The Training and Education (TAE) qualifications have an additional requirement: if you’re validating the assessments for a TAE program (like the Cert IV in Training and Assessment), the validation must include at least one person independent of the RTO. Essentially, you need an external set of eyes in the mix to ensure objectivity, given the high-stakes nature of those credentials. Typically, RTOs swap with another RTO to validate each other’s TAE assessments or bring in an external consultant.

  • You should have a validation report or record that captures key details: which course/unit was validated, who participated (names, qualifications/roles), what sample of assessments was reviewed, what the findings were (e.g., any gaps in mapping, any issues with how questions were interpreted, whether assessor judgments were appropriate), and what actions were decided. Also track the completion of those actions. If you found, say, that an assessment question wasn’t actually covering part of a performance criterion, an action might be “revise Question 5 to address X.” Later, you should show that was done and maybe re-validate that part. These records demonstrate to ASQA that you systematically check and improve your assessments.

  • Moderation meeting minutes and outcomes are one form of evidence. For example, keep records of periodic assessor meetings where they compare student responses and align their marking decisions. Other evidence: having benchmark answers or marking guides that assessors use, records of dual-marking or co-assessment (two assessors independently mark a sample then compare results), and evidence of assessor professional development or calibration workshops. Essentially, document any process you use to standardize assessment decisions. If you have multiple campus locations, ensure cross-campus moderation is done. Clear decision-making rules (like rubrics) provided to all assessors also help – and saving those rubrics as evidence shows you set consistency expectations.

  • Treat it like a mini project: document the change, implement it, and control the versions[42]. Specifically, after validation finds an improvement:

    • Treat it like a mini project: document the change, implement it, and control the versions. Specifically, after validation finds an improvement:

    • Update the mapping document if needed.

    • Mark the new version with an updated version number/date.

    • Retrain assessors on the new tool (ensure everyone knows about the changes and how to apply them).

    • Communicate the effective date – e.g., “Use new version for all assessments starting next term.”

    • Keep the old version archived, with a note on why it changed (the validation record as evidence).

    • Monitor the first few uses of the new tool to ensure the issue is resolved and no new issues have been introduced.

    Monitor the first few uses of the new tool to ensure the issue is resolved and no new issues have been introduced.

RPL & Credit Transfer

  • Recognition of Prior Learning (RPL) should be a thorough yet streamlined process. Good practice includes: providing clear upfront information to candidates about what RPL involves, using structured evidence guides or application forms so candidates know what evidence to submit, including an interview or workplace visit if needed to gather additional evidence, and ensuring assessors apply the same principles of assessment and rules of evidence as they would for normal assessment. Essentially, RPL is just assessment – but it should be flexible in allowing different types of evidence (work experience, transcripts, references). A quality RPL process maps that evidence to unit requirements and is as rigorous as other assessment pathways, while avoiding unnecessary hoops for the candidate.

  • Yes, RTOs can set fees for RPL services, but they should be transparent, fair, and reasonable. Many RTOs charge per unit or a flat application fee. The key is not to make RPL cost-prohibitive – fees should reflect the effort involved by the assessor in reviewing evidence, not discourage qualified individuals from applying. Also, be mindful of any funding contract requirements: some funded programs might not allow charging extra for RPL or have set rates. Always disclose RPL fees clearly in your marketing and enrollment info.

  • Credit Transfer (CT) is straightforward if done right[45]: when a student provides a statement of attainment or qualification showing they’ve completed an equivalent unit at another RTO, you verify the document (ensure it’s authentic and the unit code matches or is deemed equivalent) and then simply record a “CT” outcome – no further assessment needed. Best practices: have a standard form for students to request credit, maintain a mapping of superseded units to current ones to quickly check equivalencies, and adjust the student’s training plan accordingly. Importantly, once CT is granted, ensure your student management system counts it as competency achieved (and you don’t include them in unnecessary training or assessment for that unit).

  • In that case, it’s not a direct credit transfer. You should treat it as RPL or gap training. Perhaps offer the student an RPL for the current unit where they supply evidence of the prior learning and any work experience, then assess what gaps exist. You might find they only need to demonstrate a couple of missing elements or updates (gap assessment). Do not record it as “CT” if the training package does not list the units as equivalent[46]. Only true equivalents (as per training.gov.au or mapping guides) count for credit transfer; anything else is prior learning to be assessed.

  • If a piece of evidence addresses multiple requirements, that’s fine, but make sure you map it to each outcome separately and confirm it sufficiently meets each one. The concern is using one piece of evidence to tick off everything without scrutiny. To avoid that[47]: ensure the RPL assessment tools require evidence for all distinct tasks/knowledge. For example, a work portfolio might cover a range of skills – break down which parts of the portfolio apply to which criteria. If the same piece of evidence is used for two requirements, note why it’s genuinely relevant to both. Use holistic assessment (combining requirements in one task) but back it up with thorough mapping. Ultimately, an RPL should be as robust as normal assessment – multiple forms of evidence complementing each other to cover all bases.

Enrolment, LLN & Marketing

  • You must determine if each learner has the language, literacy, numeracy (LLN) and digital skills needed for the course, but there isn’t a one-size-fits-all test mandated. Many RTOs use an LLN assessment tool (like an ACSF test) at enrolment, which is good practice. However, the format can vary depending on the course and student cohort. The key is: for every student, you have a process to ensure they won’t be set up to fail due to LLN or digital skill gaps. If a student has already provided evidence (e.g. Year 12 English or an IELTS for internationals), you might not need to re-test English but perhaps check their numeracy if it’s critical for the course. Flexibility is fine as long as you document how you determine LLN capacity and support needs. For online learning, checking digital literacy (like ability to navigate the LMS, use basic software) is increasingly important too.

  • Quite a lot – and it should all be in line with the Standards for RTOs and, for internationals, the National Code. At a minimum, before a student signs up you must tell them: the course code and title and what qualification or outcome it leads to, any entry requirements or pre-requisites, the delivery mode (classroom, online, blended), the course duration and schedule (how long, timetable info), an overview of the assessment methods, full fees (tuition and any non-tuition costs like materials or uniforms) and your refund policy, what support services you offer (academic or personal), and any specific requirements like work placements or equipment they need. Essentially, students should have a clear picture of what they’re committing to, what it will cost, and what support they can expect. This is both a consumer protection measure and a compliance requirement.

  • The marketing standards require that RTOs present information accurately and ethically. Some key rules: always use the correct course code and title as per training.gov.au (no invented names that could mislead), include your RTO code on all materials, use the National Recognised Training (NRT) logo only as permitted (and never in connection with non-accredited training), and do not guarantee outcomes that you can’t control (for example, don’t promise a job or migration outcome unless it’s an actual requirement of a visa). Also avoid misleading statements like “100% success rate” if it’s not substantiated. In inducements, be careful – things like “free laptop” promotions are allowed but you must ensure you’re not inadvertently suggesting a government subsidy covers that if it doesn’t. In short: be factual, current, include all required identifiers, and no gimmicks that could be deemed misleading by a regulator or the ACCC.

  • It’s wise to have a documented marketing approval process This might involve a checklist and a designated staff member (or committee) who reviews each new brochure, website update, or social media post against compliance requirements. Maintain a version register of marketing materials – noting when each item was approved and by whom. Also implement a periodic review, especially after any change in scope or regulations: for example, if units change, update the flyers immediately. Essentially, treat marketing content like controlled documents. Many RTOs train their marketing team in compliance basics and require a compliance manager or CEO sign-off on any public materials to catch issues before publishing.

  • If an international student shows up with an English language test result (IELTS, PTE, etc.) that meets entry requirements, you should still confirm numeracy and digital skills if relevant. The English test likely covers general language ability but not things like numeracy. Also, even with a good IELTS score, a student might struggle with vocational vocabulary or writing styles needed for your course – so an initial LLN indicator task can help you identify any additional support they need. Essentially, use the English test as one input (you might not do a full LLN test for English again), but do ensure the student’s overall capabilities – including numeracy or computer skills for online coursework – are assessed. And remember, reasonable adjustments can be made, but you need to identify needs first.

Student Support, Wellbeing & Inclusion

  • RTOs are expected to take proactive steps to identify and support learners with additional needs. This means at enrollment or commencement you should gather info on any language, literacy, disability, or other support needs (through questions or an LLN test, etc.), and then provide reasonable adjustments or services. Support can include academic support (like study skills or extra tutoring), disability accommodations (adjusted equipment, extra time, accessible materials), and referral to external services (counseling, welfare support). The aim is to give each student a fair chance to succeed. You should also orient them on how to seek help. Importantly, document any support plan or adjustment provided, to show you did everything reasonable to help the student complete the course.

  • The level of support should be scaled to the risk and duration of the course. For a short course or one delivered mostly online, you might not have ongoing weekly check-ins, but you still need to ensure students know how to get help. For online learners: provide clear contact details for technical support and academic queries, maybe run a brief virtual orientation so they aren’t isolated. For short intensive courses: ensure they have a contact for any personal issues even if the timeframe is short, and that safety measures are in place for in-person practicals. Essentially, clear points of contact and timely communication are key. If a course is short, you might provide an upfront info pack with all support options spelled out, since there’s less time for issues to surface organically.

  • If your RTO’s courses include work placements, you have a duty of care to vet those arrangements. Good practices: screen host employers (check they have appropriate facilities, supervision, and have not had adverse incidents), set up written agreements outlining roles (including who handles insurance, what induction is given, etc.), and prep students with a thorough induction on workplace health and safety (WHS) and expected conduct. Maintain contact during the placement – e.g. require students to report issues promptly, and have an RTO staff member do check-ins or visits. If a student voices a concern about safety or bullying or anything at placement, act quickly: that might mean intervening with the host or moving the student. Prompt resolution is critical to avoid harm and to meet your compliance obligations under the Standards/National Code.

  • Inclusion means making sure your training is accessible and fair for all learners, regardless of background or ability. Practically, this involves: using language and examples in training materials that are culturally sensitive and inclusive; ensuring physical accessibility (or reasonable adjustments) for learners with disabilities; avoiding bias in assessment tasks; allowing flexible delivery where possible to cater to different needs (without compromising outcomes); and training your staff in inclusive practices. It also means fostering a classroom environment (face-to-face or online) where diversity is respected – set expectations for respectful behavior. From a compliance perspective, inclusion ties into both disability standards and the obligation to provide support – but it’s also just good education practice leading to better outcomes.

  • While not every RTO offers financial assistance, it’s good practice to have measures for students struggling to pay fees. This could include offering payment plans, being transparent about all fees so no unexpected costs arise mid-course, and if a student hits hardship, possibly deferring their studies or directing them to external support (like government financial counseling or emergency relief services). Ethically, if a student cannot pay due to unforeseen hardship, work with them – maybe pause their training until they can sort it out rather than cancelling immediately (compassionate consideration aligns with good practice). Of course, ensure any approach doesn’t compromise assessment integrity (e.g. don’t extend course duration so long that their skills become not current). And make sure your refund policy is clear on what happens if they withdraw due to hardship.

Governance, Risk & Self-Assurance

  • The Standards for RTOs require that executive officers and high managerial agents of the RTO are accountable for everything the RTO does. In practice, this means leaders must set the tone for integrity (no cutting corners), allocate enough resources to compliance (e.g. staffing, systems), and actively monitor the RTO’s performance. Regulators expect that CEOs and owners don’t just delegate compliance to a manager and forget it – they need to regularly review reports on quality indicators, audit findings, student outcomes etc., and ensure issues are addressed promptly. Essentially, leadership should foster a quality culture and intervene early when problems arise.

  • Yes – developing a risk register is now considered best practice and is implicitly expected under self-assurance approaches. A risk register lists all the major risks (academic, operational, financial, safety, reputational) that could affect your RTO, an assessment of their likelihood and impact, current controls you have, and any additional treatments needed. For example, a risk might be “Trainer turnover leading to subpar delivery.” You’d note likelihood, impact, and what you do to mitigate (competitive salaries, backup trainers, etc.). Review the register at management meetings, update it regularly. It shows ASQA that you’re proactive and systematic in managing risks.

  • Self-assurance means you don’t wait for ASQA to tell you there’s a problem – you have systems to continuously monitor and improve your own compliance. To demonstrate this: have an internal audit schedule (e.g. reviewing some aspect of operations quarterly), collect data like student feedback, completion rates, employer satisfaction, etc., and analyze it for trends. Implement an annual internal review against the Standards and document the findings and actions. Also show evidence of changes you made off your own bat – e.g. “We noticed assessment issues in our internal review, so we updated the tools and retrained staff, and now outcomes improved.” ASQA loves to see that cycle of review -> action -> improvement with evidence of impact. Additionally, keep records of meetings or reports where compliance is discussed (minutes, action lists). It paints a picture of a self-regulating RTO.

  • Conflicts of interest can arise, for example, if a staff member has a secondary role or personal interest that could affect decisions (like an assessor assessing their family member, or an RTO manager owning another company that supplies services). RTOs should have a conflict of interest policy and register. The policy should require all staff (especially management and trainers) to declare any actual or potential conflicts. Then, practical separation measures might be used: e.g. if a conflict is declared, that person is removed from decisions in that area (alternative assessor assigned for that student, etc.). Document all disclosures and how they were managed. Regulators expect transparency and fairness – e.g. if you have a partnership with another organisation, you shouldn’t treat their students differently unless disclosing why. Particularly with third-party arrangements or workplace-based assessments, ensure assessors aren’t assessing their direct employees without oversight, etc. Having a COI register that is periodically reviewed is a good look for compliance.

  • ASQA (and funding bodies) need to be confident you’re financially stable enough to deliver what you promise to students. Demonstrating this can include: regular budgeting and cash flow monitoring, keeping evidence that you meet any formal financial conditions (like if ASQA asks for an annual audit report, have that done). Internally, leadership should review financial reports often – e.g. monthly management accounts showing you can cover costs. Maintain adequate tuition assurance or bank guarantees if required. If you identify financial challenges (e.g. lower enrollments), show you take timely action – maybe reducing costs, finding investment, etc. The key is not to wait until you’re insolvent. Documented oversight might include Board meeting minutes discussing finances, correspondence with your accountant, etc. If ASQA ever inquires, you can produce those as evidence that you actively monitor and manage financial viability in the interests of students.

Third Parties, Scope & Transitions

  • A third-party arrangement is when another organisation or individual is engaged to deliver services on behalf of your RTO. This can include recruiting students, providing training or assessment, or student support, under your RTO’s name and registration. It does not include your own direct employees – it has to be an external party. For example: if you hire a company to deliver training in another state for you, or use an education agent to recruit overseas students, or subcontract practical training to a specialist company – all these are third-party arrangements. You must have a written agreement in place and notify ASQA of these arrangements. Note that arranging work placements for students isn’t considered a third-party delivering training (since the employer isn’t delivering your course, just providing experience), but if they start assessing or training, then it becomes one.

  • The written agreement with any third party should clearly spell out: the roles and responsibilities of each party (who does what – including compliance with Standards), quality expectations (e.g. that training must meet your RTO’s requirements), rules around marketing (the third party must use your approved info, etc.), data and privacy obligations (they must handle student info appropriately and share data with you), requirements for reporting back to you and allowing you to monitor them, steps for rectifying any issues found, and conditions for terminating the agreement. Essentially, the agreement should mirror the fact that you (the RTO) remain ultimately responsible for everything – so the third party agrees to cooperate with audits, provide records to you, and so on. ASQA provides a sample or list of clauses to consider – following that is wise.

  • You can’t just “set and forget” with a third-party doing some of your training or recruitment. You need a plan to systematically monitor them. This might include: conducting regular site visits or class observations, sampling student assessments they’ve done to check marking quality, reviewing their training resources, checking their marketing materials to ensure they’re accurate and have your RTO code, analysing student outcomes and feedback coming from that third party’s cohort, and holding review meetings with the third party to discuss any issues. Keep records of all monitoring activities and any corrective actions taken. If complaints arise involving a third party, address them promptly and decisively – and record the outcome. Remember, from ASQA’s perspective your RTO is responsible for the third party’s compliance, so your oversight needs to be active and documented.

  • Yes, but with conditions. An education agent or partner can advertise your courses, but they must clearly identify your RTO as the provider and use approved marketing content. That means any marketing the third party does should mention your RTO’s legal or trading name and RTO code, and it should not be misleading or make unauthorised promises. You should provide the third party with vetted course information to use. Also, your agreement should make clear they can’t use the NRT logo unless it’s in the context of your RTO and an approved ad. You remain responsible for what’s communicated – so it’s wise to pre-approve all marketing by third parties. Many compliance issues have arisen from agents overpromising (like “Enroll with us, get a guaranteed job or visa!”) – that kind of conduct breaches Standards and potentially consumer law, and you’d need to act against that agent.

  • When you apply to ASQA to add a qualification or unit to your scope, you must show you’re ready and able to deliver it. Evidence typically includes: resumes and credentials of suitable trainers/assessors you have for the new course, details of facilities and equipment (e.g. a campus or workshop that meets requirements, or access arrangements if off-site), a list of learning resources and assessment tools you’ll use (often demonstrating you’ve mapped them to requirements), records of industry consultation or engagement that you did to ensure the course meets industry needs, and perhaps a business plan or financial projection showing you can sustain delivery of the course. ASQA wants to be confident you won’t put students at risk by taking on a course you can’t handle. Essentially, treat an add-to-scope application like a mini-registration – think of all the aspects of delivery and have evidence for each.

  • The general rule is: once a training product (qualification or unit) is superseded, you have a 12 month transition period to finish training (for a full qualification – sometimes less for single units). During this time you should transition current students into the new version as soon as feasible, or complete them in the old one if they’ll finish within that time. You must stop enrolling new students into the superseded course after it’s officially superseded, unless ASQA approves an extension (which is rare and only for specific teach-out needs). “Teach-out” beyond the transition period is allowed only for students who were enrolled prior and only if absolutely necessary, and even then, ASQA expects minimal numbers. Communicate clearly with students about transitions – nobody should be disadvantaged by a qualification update. Keep resources for the superseded and new side by side during the year, and ensure staff understand the differences.

Records, Data & Certification

  • A third-party arrangement is when another organisation or individual is engaged to deliver services on behalf of your RTO. This can include recruiting students, providing training or assessment, or student support, under your RTO’s name and registration. It does not include your own direct employees – it has to be an external party. For example: if you hire a company to deliver training in another state for you, or use an education agent to recruit overseas students, or subcontract practical training to a specialist company – all these are third-party arrangements. You must have a written agreement in place and notify ASQA of these arrangements. Note that arranging work placements for students isn’t considered a third-party delivering training (since the employer isn’t delivering your course, just providing experience), but if they start assessing or training, then it becomes one.

  • The written agreement with any third party should clearly spell out: the roles and responsibilities of each party (who does what – including compliance with Standards), quality expectations (e.g. that training must meet your RTO’s requirements), rules around marketing (the third party must use your approved info, etc.), data and privacy obligations (they must handle student info appropriately and share data with you), requirements for reporting back to you and allowing you to monitor them, steps for rectifying any issues found, and conditions for terminating the agreement. Essentially, the agreement should mirror the fact that you (the RTO) remain ultimately responsible for everything – so the third party agrees to cooperate with audits, provide records to you, and so on. ASQA provides a sample or list of clauses to consider – following that is wise.

  • You can’t just “set and forget” with a third-party doing some of your training or recruitment. You need a plan to systematically monitor them. This might include: conducting regular site visits or class observations, sampling student assessments they’ve done to check marking quality, reviewing their training resources, checking their marketing materials to ensure they’re accurate and have your RTO code, analysing student outcomes and feedback coming from that third party’s cohort, and holding review meetings with the third party to discuss any issues. Keep records of all monitoring activities and any corrective actions taken. If complaints arise involving a third party, address them promptly and decisively – and record the outcome. Remember, from ASQA’s perspective your RTO is responsible for the third party’s compliance, so your oversight needs to be active and documented.

  • Yes, but with conditions. An education agent or partner can advertise your courses, but they must clearly identify your RTO as the provider and use approved marketing content. That means any marketing the third party does should mention your RTO’s legal or trading name and RTO code, and it should not be misleading or make unauthorised promises. You should provide the third party with vetted course information to use. Also, your agreement should make clear they can’t use the NRT logo unless it’s in the context of your RTO and an approved ad. You remain responsible for what’s communicated – so it’s wise to pre-approve all marketing by third parties. Many compliance issues have arisen from agents overpromising (like “Enroll with us, get a guaranteed job or visa!”) – that kind of conduct breaches Standards and potentially consumer law, and you’d need to act against that agent.

  • When you apply to ASQA to add a qualification or unit to your scope, you must show you’re ready and able to deliver it. Evidence typically includes: resumes and credentials of suitable trainers/assessors you have for the new course, details of facilities and equipment (e.g. a campus or workshop that meets requirements, or access arrangements if off-site), a list of learning resources and assessment tools you’ll use (often demonstrating you’ve mapped them to requirements), records of industry consultation or engagement that you did to ensure the course meets industry needs, and perhaps a business plan or financial projection showing you can sustain delivery of the course. ASQA wants to be confident you won’t put students at risk by taking on a course you can’t handle. Essentially, treat an add-to-scope application like a mini-registration – think of all the aspects of delivery and have evidence for each.

  • The general rule is: once a training product (qualification or unit) is superseded, you have a 12 month transition period to finish training (for a full qualification – sometimes less for single units). During this time you should transition current students into the new version as soon as feasible, or complete them in the old one if they’ll finish within that time. You must stop enrolling new students into the superseded course after it’s officially superseded, unless ASQA approves an extension (which is rare and only for specific teach-out needs). “Teach-out” beyond the transition period is allowed only for students who were enrolled prior and only if absolutely necessary, and even then, ASQA expects minimal numbers. Communicate clearly with students about transitions – nobody should be disadvantaged by a qualification update. Keep resources for the superseded and new side by side during the year, and ensure staff understand the differences.

CRICOS Compliance

  • CRICOS stands for the Commonwealth Register of Institutions and Courses for Overseas Students. Any RTO that wants to educate students on Australian student visas must be registered on CRICOS[. In other words, if you intend to enroll international students (non-residents) who hold a student visa, it’s legally required under the ESOS Act that your institution and each course are CRICOS-registered. If you’re not on CRICOS, you cannot offer courses to those visa holders. Even if you have one student visa applicant among mostly local students, you’d need CRICOS registration to include them. CRICOS registration entails meeting additional standards focusing on the welfare and support of overseas students.

  • To get CRICOS registration, your RTO must first be an ASQA-registered RTO (you cannot go CRICOS if you’re not already an RTO in good standing). The application is made to ASQA and is quite detailed. You’ll need to prepare evidence covering all aspects of intended delivery to overseas students, including demonstrating that: the courses you want to offer are suitable for international students (full-time, with appropriate sequencing and duration), you have qualified staff and adequate facilities, robust support services (like orientation and academic support programs for internationals), and processes for monitoring student attendance/progress and ensuring their welfare (since younger or far-from-home students may need extra care). There are also fees involved for the application and ongoing per-student levies. After submission, ASQA will likely conduct a site audit or a thorough desk audit to ensure you can meet the ESOS Act and National Code requirements before granting CRICOS registration.

  • In summary, an RTO seeking CRICOS approval must prove it can fully support international students academically and pastorally. Key requirements include:

    • Suitable Courses: The course must be nationally recognized (as all RTO courses are) and delivered face-to-face for at least 20 hours per week (distance learning is limited – at least two-thirds of the course must be face-to-face).

    • Qualified Staff & Facilities: You need trainers experienced in teaching non-native English speakers (or support for them), and classrooms, equipment, and resources sufficient for possibly larger classes or diverse needs.

    • Support Services: Show you have an orientation program, ongoing academic support (like English language assistance if needed), and personal support (counseling or welfare officer available).

    • Monitoring Systems: Outline how you will monitor student attendance (if applicable) and course progress, and what intervention strategies you’ll use if a student falls behind (which is a National Code requirement).

    • Financial Viability & Fee Protection: You must participate in the Tuition Protection Service (TPS) and have a sound financial basis – basically convincing ASQA that you won’t suddenly collapse and leave students stranded. Evidence might include financial reports and business plans for the international cohort.
      ASQA assesses all this to be confident you’ll comply with the ESOS framework. Only when satisfied will they grant CRICOS registration (often for up to 5–7 years, similar to RTO registration).

  • CRICOS registration is typically granted for up to 7 years (often aligning with your RTO registration period). Before it expires, you must apply to ASQA to renew if you want to continue enrolling international students. The renewal application should usually be submitted around 90 days before expiry (ASQA will remind you). In the renewal, ASQA will review your track record over the current registration period – they’ll consider any audits, compliance issues, or sanctions that occurred, as well as student outcomes like completion rates. Essentially, you need to show you have been compliant and will continue to meet all requirements. As always, it’s critical to diarize your CRICOS end date; operating past your expiry (even inadvertently) is a serious breach. Start preparing well in advance: gather evidence of continuous improvement, compliance with reporting, etc., to support a smooth renewal.

  • Yes. CRICOS registration is course- and location-specific. This means whenever you want to offer a new qualification to overseas students, or open a new campus or training location for international delivery, you must apply to ASQA for a CRICOS change. You can’t automatically start offering a course to internationals just because it’s on your domestic scope. The application for adding a course will involve providing evidence similar to an initial registration (facilities for that course, timetable showing 20 hours/week, support arrangements, etc.). Adding a new location involves showing that site meets requirements (e.g. has enough space, appropriate amenities, and local support access). Only once ASQA approves the course or campus and updates your CRICOS registration can you start enrolling students there. It’s important not to jump the gun – doing so would mean students are studying in an unapproved setting, which is a breach of the ESOS Act.

  • CRICOS providers operate under a special framework designed to protect international students – chiefly the ESOS Act 2000 and the National Code 2018, plus any relevant regulations and (if applicable) the ELICOS Standards 2018 (for English language courses). In addition, as an RTO, you still must comply with the regular Standards for RTOs 2015/2025 for your vocational delivery. So essentially you have an extra layer of rules for anything involving overseas students. The ESOS Act sets out broad requirements like registration, tuition protection, and the legal obligations to report certain events. The National Code then provides 11 detailed standards on how to recruit, enroll, support, and monitor international students (we cover some of those in other FAQs). If you deliver ELICOS (English Language Intensive Courses for Overseas Students), the ELICOS Standards come into play too. All these are enforced by ASQA (for VET providers) or TEQSA (for higher ed), and breaches can lead to enforcement action similar to domestic non-compliance, in addition to potentially immigration consequences for students.

  • The ESOS Act imposes several core obligations aimed at protecting students and ensuring quality. Key ones include:

    • The ESOS Act imposes several core obligations aimed at protecting students and ensuring quality. Key ones include:

    • Provide the education as advertised – if you can’t, you must arrange refunds or transfers (this ties into Tuition Protection Service – ensuring student fees are safe or refundable if you fail to deliver).

    • Monitor student visa compliance: specifically monitor their attendance (if required) and course progress. You must have systems to track this and identify if a student isn’t meeting requirements.

    • Report certain events via PRISMS: e.g., if a student doesn’t commence, if they breach visa conditions (like poor attendance or progress after your interventions and appeals), if they defer or you suspend them, or if they change courses, etc. Timely reporting is mandatory.

    • Keep thorough records for each student: contact details (and update within 7 days of changes), academic records, etc., and be ready to provide these to regulators.

    • Adhere to the National Code standards – which cover marketing, student support, etc., effectively making them obligations under ESOS once you’re registered.
      In short, the ESOS Act makes sure providers do what they promise, look after students, and keep authorities informed of any issues affecting a student’s study or wellbeing.

  • The National Code of Practice for Providers of Education and Training to Overseas Students 2018 – usually just called the National Code – is a set of nationally consistent standards all CRICOS providers must follow. It’s established under the ESOS Act, and compliance with it is mandatory. The National Code covers pretty much the day-to-day operations concerning international students. It’s crucial because it translates ESOS Act principles (which are broad) into specific requirements. For example, it tells you what information you have to give students before enrollment, how to manage student transfers between providers, how to handle students under 18, etc. If you breach the National Code (say, by not having an appropriate complaints process or by not monitoring attendance when you should), it’s considered a breach of your conditions and can result in ASQA sanctions or conditions on your CRICOS registration. Thus, understanding and implementing the National Code is central to CRICOS compliance – it’s not optional or a guideline; it’s enforceable.

  • The National Code 2018 has 11 standards, each dealing with a critical aspect of managing international students. In brief, these standards cover:

    1. Marketing Practices – how you advertise to students must be ethical and accurate.

    2. Student Recruitment and Enrolment – ensuring students meet entry requirements and get all necessary info before enrolling (including conditions and their rights).

    3. Formalisation of Enrolment / Written Agreements – you must have compliant written agreements (enrollment contracts) with very specific refund policies and terms.

    4. Education Agents – how you engage and monitor agents recruiting on your behalf.

    5. Younger Overseas Students – extra welfare arrangements if you enroll students under 18 (like approved accommodation and guardianship).

    6. Student Support Services – you must provide adequate orientation and support services (academic and personal) to international students.

    7. Overseas Student Transfers – rules for when you can or cannot enroll a transferring student who hasn’t completed 6 months of their principal course, and when you must release your students.

    8. Student Visa Requirements (Attendance and Progress) – you need policies to monitor course progress (and attendance for sectors that require it, like ELICOS or high school), and implement intervention strategies if needed.

    9. Deferring, Suspending or Cancelling Enrolment – acceptable grounds and processes for deferral, suspension, or cancellation, including informing students of impacts on visas.

    10. Complaints and Appeals – you must have an internal complaints and appeals process and students must also be able to access an external appeals body (often the Ombudsman) if internal processes fail.

    11. Additional Requirements – mostly administrative, like not conflicting with other laws (immigration law etc.), and some provisions like providing information to the TPS Director when required.

    Together, these standards aim to ensure overseas students get clear info, proper support, fair treatment, and pathways to resolve issues – and that providers actively manage their responsibilities at each step.

  • Before enrolment (and ideally before any contract is signed or payment made), you must supply comprehensive, truthful information so the student can make an informed decision. This typically includes:

    • The course details: its content, duration, qualification level, and any professional outcomes (like licensing) if relevant.

    • The full costs: tuition fees, any non-tuition fees (like materials, admin fees), and estimates of living costs if you provide that info (often required for visa understanding), plus clear refund terms in case things change.

    • Entry requirements: both academic (prior education, prerequisites) and English language requirements, or other specifics (e.g. must already have a certain license if doing a training course that requires it)

    • The location and facilities: campus address(es) where training will occur, and a description of facilities/equipment available there.

    • Key policies: especially your refund policy, the circumstances under which they can defer/suspend or you might cancel their enrolment, and information about their rights (like access to complaints and appeals).

    • Key policies: especially your refund policy, the circumstances under which they can defer/suspend or you might cancel their enrolment, and information about their rights (like access to complaints and appeals).

  • The written agreement (the enrolment contract between your RTO and the student) is a critical document and must be signed before or at the time of accepting fees from the student. It needs to include:

    • Course details: name, CRICOS code, duration, start date and location of the course.

    • All fees: tuition and non-tuition, with a clear schedule (e.g. how much is due on enrolment, how much each term, etc.). Also, it should list the circumstances of refunds – for both provider default (if you can’t deliver the course) and student default (if the student withdraws early, etc.), and the refund amounts or calculation method in each case.

    • All fees: tuition and non-tuition, with a clear schedule (e.g. how much is due on enrolment, how much each term, etc.). Also, it should list the circumstances of refunds – for both provider default (if you can’t deliver the course) and student default (if the student withdraws early, etc.), and the refund amounts or calculation method in each case.

    • Terms and conditions: including the student’s rights and responsibilities, such as their obligation to maintain visa conditions (attendance/progress), and their entitlement to a refund or not in various scenarios.

    • Deferral/Suspension/Cancellation policies: under what grounds the student can defer or suspend their studies, or under what grounds you might cancel their enrolment (academic misconduct, non-payment, etc.).

    • Complaints and appeals: reference to the internal process and external appeals available.
      It should also state that the student is required to update their address, and other visa-related obligations (though those are often in an attached schedule or in the handbook). Essentially, the written agreement protects both parties: it’s evidence the student knew what they were agreeing to and what protections they have. Ensure it’s signed (by under-18 student’s parent/guardian if applicable) before taking money – that’s a common audit finding if not done.

  • Yes – absolutely. Every piece of material (printed or digital) used to promote courses to overseas students must include your RTO’s CRICOS registered name and CRICOS provider number. This is a legal requirement to ensure transparency. For instance, on your website’s footer you might put “RTO Legal – CRICOS Provider 01234A”. Similarly, if you publish a brochure or social media post about enrolling international students, make sure the CRICOS code is there. This lets students and regulators verify that you are authorized. Failing to include the code is a compliance breach and easily spotted by regulators. Along with the provider code, ensure any mention of course names uses the CRICOS registered course title and code as well. And of course, marketing content should not be misleading – no false guarantees of jobs or residency, etc., that could give a wrong impression.

  • If you use education agents to recruit international students, the National Code Standard 4 applies. Key obligations:

    • You must have a written agreement with each agent outlining their responsibilities, your expectations (like honest marketing, adherence to the National Code, no unethical practices), and the conditions under which you can terminate the agreement.

    • You are responsible for monitoring your agents. That means you should regularly review the quality of students they refer (are they genuine, or ending up in trouble?), perhaps collect feedback from students about their agent, and check that the agent’s advertising is accurate. If an agent is not doing the right thing – e.g., giving migration advice without a licence, or falsifying documents, or misinforming students – you are expected to act (correct them, retrain them, or terminate them for serious breaches).

    • Keep an updated list of your agents (name, legal entity, location) and, under ESOS, this list should also be entered in PRISMS and usually published on your website. Transparency is key.

    Keep an updated list of your agents (name, legal entity, location) and, under ESOS, this list should also be entered in PRISMS and usually published on your website. Transparency is key.

  • Keep an updated list of your agents (name, legal entity, location) and, under ESOS, this list should also be entered in PRISMS and usually published on your website. Transparency is key.

  • Generally, no – not without a release or meeting specific exceptions. The National Code Standard 7 says a student must complete at least 6 months of their principal course (usually the main course in a package, e.g., the diploma following an English course) before they can move to another provider, unless certain conditions are met. So, if a student of yours wants to transfer out early, you should have a policy to assess their request. You’re expected to grant a release if the transfer is in the student’s best interests – for example, if they have compassionate or compelling reasons, or if the current course is not suitable and another is (maybe the student was mis-advised and needs a different level). If you refuse, it must be on reasonable grounds (like “Student hasn’t tried the support services we offered yet” or “Transfer is for a similar course at the same level with no valid reason”). And you must inform them of their right to appeal your refusal. If a student complains externally, the Ombudsman will check if you followed your policy fairly.
    On the flip side, if you are considering accepting a student from another provider who hasn’t completed 6 months with them, you must check PRISMS for a release (or ensure an exception applies, like the first provider’s course is no longer offered). If no release and no exception, you must not enroll them. Always check the dates and course codes on PRISMS before issuing a CoE to transferring students.

  • You need proactive systems for monitoring that overseas students meet visa conditions for academic progress (and attendance, if applicable). For course progress: set clear academic expectations each study period (e.g., “must pass at least 50% of units each term”). Regularly review results – perhaps mid-term and at end of term. If a student is struggling (failing assessments, not submitting work), implement an intervention strategy early: counsel them, create a support plan (extra classes, tutoring, a reduced load if possible under visa rules). Document these interventions and communications. For attendance: if you deliver VET, the National Code doesn’t mandate attendance monitoring unless required by a regulator or for ELICOS, etc. But if you do have an attendance requirement (some EAL courses or state requirements), set up daily/weekly rolls and calculate attendance percentages. Many RTOs track attendance even in VET because it helps engagement. If a student falls below attendance thresholds or is absent a lot, issue warning letters and meet with them to see what’s wrong. The aim is to support students to meet requirements, not just to punish – but ultimately if a student fails to meet progress or required attendance despite warnings and support, you’ll have to report them via PRISMS. The keys are: early intervention, thorough documentation, and fairness in giving them chances to improve.

  • By default, for purely VET courses, the National Code does not require attendance monitoring – only course progress is mandatory. The exception is if ASQA or another ESOS agency specifically imposes an attendance condition on your registration (maybe due to concerns, they could require you to monitor attendance at 80%). Also, if you offer any ELICOS or school sector courses, those have attendance requirements. But for standard VET, you focus on academic progress. However, many RTOs still take attendance for good practice and internal tracking, as it can help indicate engagement. If you do choose to track attendance (even if not required), it’s wise to follow common practices: for example, issue warning at 90% and 80% attendance to prompt intervention, even if not going to report it. If you’re not monitoring attendance at all, ensure you heavily monitor progress – because a student could technically have high attendance but failing, or vice versa, and you need to catch issues either way. In summary: monitor progress, and if you monitor attendance by choice or condition, stick to the typical threshold (80%) and processes for consistency, but know that for VET it’s usually not required unless specifically mandated.

  • “Satisfactory course progress” means the student is successfully completing their coursework at an acceptable rate. Unlike attendance, there’s no one-size benchmark set by the National Code; each provider must define it in their academic progress policy. Commonly, RTOs use a rule like “students must pass at least 50% of units in each term” or “not fail the same unit twice” or something similar. The idea is the student should be on track to finish their course within the scheduled duration. If your course is 1 year (2 semesters), maybe you expect at least half the units passed by end of first semester. Communicate your progress requirements clearly to students in orientation. At the end of each study period (e.g., term or semester), identify anyone who hasn’t met the requirement – these are now “at risk” or unsatisfactory progress students. That triggers your intervention process (extra support etc., described below). If a student continues to not meet progress requirements over consecutive periods despite interventions, that would escalate to being formally unsatisfactory and reported.

  • You must implement an intervention strategy as soon as you identify a student at risk of not meeting progress. For example, if mid-term their marks are poor or they failed a unit in Term 1, act then – don’t wait for them to fail Term 2 as well. An intervention could include: additional tutoring or study sessions; English language support if language is an issue; study skills workshops; personal counseling if non-academic issues are affecting them; or adjusting their course load (maybe let them repeat a unit while reducing new units, if visa allows). Document a plan with the student – what steps will be taken, over what timeframe, and what improvement is expected (e.g., pass all units in next term). Then monitor them closely in the following term. If they improve and now meet requirements, great – keep supporting as needed. If not, and they hit the point of unsatisfactory progress (usually failing to meet for 2 consecutive study periods), you must go to the next step: issue them an Intention to Report letter, informing them that you intend to report them to immigration for unsatisfactory progress and that they have 20 working days to access your internal appeals process[104]. Follow your written policies here carefully. If they appeal, you maintain their enrolment during the internal (and if sought, external) appeal. If the appeal is unsuccessful or they don’t appeal in 20 days, then you proceed to report via PRISMS. Throughout, keep evidence of all counseling, emails, support provided, and the academic results – ASQA will want to see you gave the student every reasonable chance.

  • Reporting is a serious step and should happen after all intervention and appeal processes are exhausted. Specifically, if a student has been identified as not meeting progress/attendance requirements, you notify them (intention to report) and if they: (a) don’t appeal within 20 working days, or (b) appeal and it’s unsuccessful (including any external appeal, if they went that far), then you must proceed to report. The National Code says you must wait until the internal and external complaints/appeals are finished before reporting – this is to ensure procedural fairness. Once that’s done, you log into PRISMS and enter the appropriate student breach report (unsatisfactory progress or unsatisfactory attendance). This will send a notice to the Department of Home Affairs, and typically the student will be contacted about their visa. Note: for attendance, “unsatisfactory” is generally defined as <80% attendance unless you have a documented reason to consider 70% acceptable in a case where the student is otherwise excelling (the National Code allows a bit of discretion in not reporting at 80% if, for example, the student’s attendance dipped slightly but academic progress is good – some providers use that). For progress, it’s usually failing the defined progress rules across two consecutive study periods. The golden rule: never report before allowing appeal, and always report if the student has run through the process and still fails. Also maintain evidence of all those steps, because ASQA will check if you correctly followed them in case of audit or if the student complains.

  • Students on a subclass 500 visa have a number of conditions, and while it’s the student’s responsibility to comply, RTOs must be aware of them and support compliance. Key ones:

    • Enrolment in a CRICOS course full-time (Visa Condition 8202): They must remain enrolled in a CRICOS-registered full-time course. As the provider, ensure they don’t drop to part-time or take breaks in study unless under an allowed deferral/suspension.

    • Satisfactory course progress and attendance (8202): That’s what we’ve been discussing – you monitor and report as required.

    • Overseas Student Health Cover (OSHC) (8501): They must maintain health insurance coverage for the duration of their visa. While the student must buy it, providers often facilitate the first time. At orientation, check that they have their OSHC card or certificate. If not, assist them in getting it immediately. It’s good to keep a record that you advised them of OSHC obligations and perhaps sighted their policy.

    • Work limitation (8105): Students can work no more than 48 hours per fortnight during study periods (this was 40 hours, changed to 48 in 2022). During scheduled breaks, they can work full-time. You don’t have to police their work hours, but remind them that over-working can jeopardize their visa and academic performance. If you notice a student falling asleep in class or grades slipping and suspect overwork, have a chat – it’s about support rather than enforcement on your part.

    • Address and Contact Updates (8533): Students must notify you of any change in their residential address, phone, email within 7 days of the change. You should have a procedure (like a form or online portal) for them to update details, and regularly remind them. Keep their current address on file – ASQA will check that you have a mechanism and records for this.

    • Welfare for Under 18 (if any): If you ever have an under-18 student and you’ve taken on welfare responsibility, there are conditions around accommodation/guardianship. Typically not common for RTOs unless you run youth programs, but if so, you must ensure appropriate arrangements and that those younger students maintain them (and notify any changes).

      In practice, incorporate these points into your orientation presentation or handbook. And maintain processes: e.g., run a report every term to see whose visa might be expiring, remind them to renew OSHC, etc. A strong partnership approach helps students comply with these conditions, which in turn helps you maintain compliance as a provider.

  • For visa purposes, full-time study in VET is generally interpreted as a minimum of 20 scheduled course contact hours per week. That’s why CRICOS registration requires showing a timetable of at least 20 hours/week of classes, workshops, or supervised learning activities. It ensures students are actually engaged in study nearly full-time. Regarding online learning: the National Code allows an international student to do no more than one-third (1/3) of their total course online or by distance, and they must take at least one face-to-face subject in each compulsory term/semester. This was relaxed during COVID as a special measure, but in 2025 the normal rule is in force. So, if your course has 12 units, no more than 4 can be delivered fully online. And if you have 4 terms, each term the student should have at least one unit that has in-person classes. This means you need to carefully structure any blended delivery. Always ensure your CRICOS timetable shows compliance: e.g., even if you have an online component, schedule it such that it’s no more than ~6-7 hours out of 20 (one-third) per week on average. Exceeding these limits can land you in trouble in an ASQA audit and can affect students’ visas if detected. So while incorporating some e-learning is fine, keep the bulk in person. Also note: after COVID, some students expect more online – you must manage those expectations because the law is strict here. We advise clearly informing students that at least two-thirds will be face-to-face and attendance is expected accordingly.

  • International students often need extra support beyond academics, and Standard 6 of the National Code requires that providers give access to orientations and support services. At minimum, you should have:

    • An Orientation Program when they commence, to help them adjust (covering info about the course, campus facilities, city info, safety, etc.).

    • Academic support: this could be in the form of study skills workshops, English language assistance, or one-on-one tutoring if a student is struggling.

    • Personal/welfare counseling: either on-site or via referral, someone students can talk to about personal issues, stress, mental health, accommodation difficulties, etc. You might not employ a full-time counselor, but have arrangements with external counseling services or train a student support officer to handle basic issues and refer serious ones.

    • Career or accommodation assistance: e.g., provide information about finding part-time work within legal limits, or lists of local rental agencies or homestay options for accommodation.

    • A designated Student Contact Officer (or team) who is the “go-to” for international students for any problems. This person’s contact details should be given to students and they should be available and approachable.

    • Critical incident policy and procedures: in case of any serious incident (accident, death, etc.), you have a plan to support the student(s) involved (this ties into Standard 6 too).

    All staff should know how to direct a student to support services. The overarching goal is ensuring students have a safe and supportive experience. Often, a supported student is more likely to succeed academically (and less likely to fall foul of visa conditions). Regulators will check that you tell students about available services (e.g., in orientation and in the student handbook) and that you actually provide them. Document the services: e.g., keep a log of counseling sessions (without breaching confidentiality – maybe just numbers), or student attendance at study skills sessions, etc., to evidence you do this. In summary, don’t just focus on compliance and forget the human element – a happier, well-adjusted student body generally equates to compliance being naturally easier too.

  • Yes, an orientation is not only good practice but expected under Standard 6. Orientation typically happens right before or at the start of the course and should cover:

    • Academic information: the structure of their course, timetable, attendance/progress rules, key dates (holidays, exam weeks), and academic policies (like plagiarism, how assessments work, etc.).

    • Campus tour and facilities: show them classrooms, library/computer labs, student common areas, etc., so they know where to go.

    • Support services overview: introduce who the student support officer is, how to reach them; explain available tutoring, English help, counseling services, etc. Provide contact info in writing (like an orientation handbook).

    • Living in Australia tips: cover basics like public transport, banking, healthcare, safety (e.g., how to contact emergency services, personal safety tips), local laws that might differ from home (like road rules, work rights), and their legal rights (tenancy rights if relevant, fair work info if they plan to work, etc.).

    • Remind them of visa “do’s and don’ts”: e.g., must maintain enrolment, work hours limit, need current address on file, maintain OSHC, attendance/progress requirement – a lot of this they heard before, but orientation is a good time to reinforce it.
      Many providers give a welcome pack or handbook with all this info for later reference. Also, some run fun ice-breaker activities to help students meet each other – which is great for building peer support networks. A thorough orientation not only helps compliance (students understand the rules and help available) but improves student satisfaction and likelihood of success. If ASQA audits, they may ask students “Did you receive an orientation and what did you learn?” – so make it count.

  • A critical incident policy outlines how you will respond to serious crises involving students (like an accident, natural disaster, death, or serious injury). Yes, it’s required under the National Code’s support standards. The policy should detail:

    • What is considered a critical incident (provide examples like those above).Immediate response procedures: e.g., who takes charge at the scene, emergency numbers to call (ambulance, police), how to secure the area if needed, basic first aid until help arrives.

    • Immediate response procedures: e.g., who takes charge at the scene, emergency numbers to call (ambulance, police), how to secure the area if needed, basic first aid until help arrives.

    • Immediate response procedures: e.g., who takes charge at the scene, emergency numbers to call (ambulance, police), how to secure the area if needed, basic first aid until help arrives.

    • Reporting: how to document the incident and the actions taken.

    • Review: after the incident, evaluating how it was handled and any improvements to procedures.

    Also, assign roles: e.g., designate a Critical Incident Team or at least responsible officers (maybe the CEO or Student Services Manager leads it). All staff and students should be made aware (in orientation or staff induction) that such a policy exists and basic procedures (like if there’s a fire, follow evacuation plan, etc.). We hope such incidents never occur, but having a plan is a must – and ASQA will want to see that policy and evidence that staff know about it. Additionally, if something severe happens and ASQA asks later, they’ll expect to see you followed your policy to care for students’ welfare. It’s part of prioritizing student safety and well-being even in extreme situations.

  • It’s a condition that students must have OSHC, but as a provider, you’re not required to buy it on their behalf – just to ensure they have it. In practice, many providers do facilitate OSHC: often during admissions, you’ll ask if they want you to arrange the policy (usually with a preferred insurer) and then collect the premium with tuition fees. This can be convenient for students. However, it’s optional – students can arrange their own OSHC. What’s not optional is that when they start, they must hold a valid OSHC policy covering their stay. You should verify this at orientation: e.g., ask to see their OSHC card or certificate. If a student somehow arrives without one, advise them immediately on how to get it (some might erroneously think travel insurance suffices – it doesn’t). If you ever have under-18 students for whom you’ve taken on welfare responsibility, then yes, typically you would organize their OSHC as part of that duty because you are effectively acting as their guardian. But for adult students, your role is to inform and check. Keep records that you did check OSHC (like a copy of their card expiry date) to show compliance. The main point: the student breaking OSHC condition could lead to visa issues, and while Home Affairs enforces that, ASQA expects you to assist by educating students about it and verifying.

  • Students can work part-time on a student visa, currently up to 48 hours per fortnight during study periods, and full-time in designated breaks. As an RTO, you are not required to monitor or report how many hours they work. That’s the student’s responsibility and a Home Affairs enforcement matter. However, from a support perspective, it’s wise to remind students not to overwork. Many are tempted to work long hours, which can affect their attendance and progress. So during orientation or in meetings, emphasize the importance of balancing work and study: “Your main purpose here is to study; working too much can lead to failing subjects or visa cancellation if you break the rules.” If you suspect a student is working more than allowed (e.g., they always seem tired or unavailable), you can counsel them. But you don’t have to, say, collect their timesheets or anything – that’s beyond your remit. Focus on their academic performance; if that drops due to work, address it through your academic monitoring (e.g., include a question in intervention meetings: “Are you working too many hours? Let’s find a solution.”). Ultimately, you have no obligation to track jobs, but you should keep the academic focus. Encouraging them to stay within 48 hours/fortnight isn’t just for legal compliance, but for their own success and well-being.

  • PRISMS stands for the Provider Registration and International Student Management System. It’s an online portal that CRICOS providers use to issue Confirmations of Enrolment (CoEs) and to report changes in student enrolment to the government. When your RTO gets CRICOS registration, you get access to PRISMS and training on it. Key functions in PRISMS include:

    • Creating eCoEs: Once an international student meets your entry requirements and pays initial fees, you generate an electronic CoE through PRISMS. This document is needed for their visa application. You input details like course duration, fee received, etc.

    • Reporting student events: Through PRISMS you notify the Department of Education/Home Affairs if a student’s enrolment changes – e.g., if they don’t commence (no-show), if they withdraw or defer or you suspend them, if they finish early, or if you are reporting a breach (unsatisfactory progress/attendance). These reports ensure the government is aware of the student’s current status and can take visa action if needed.

    • Updating provider info: You also use PRISMS to keep your courses and agent details current. For instance, when you add a new CRICOS course or a new campus, those get recorded in PRISMS. Agent management (adding/removing agents) is done here too.

    Using PRISMS accurately and timely is crucial – failing to report something like a student not showing up can lead to you harboring a ghost student on paper (which is bad for compliance and national integrity). Also, PRISMS has checks like reminding you of visa expiries, etc., which help you manage compliance. Staff who handle PRISMS must be trained and often only certain staff get login permission because whatever is done in PRISMS is official. Always double-check entries for accuracy (e.g., correct dates, spelling of names matching passport). Remember, PRISMS data directly affects visas. If you cancel a CoE on PRISMS, the student could get a visa cancellation notice swiftly. It’s a powerful tool, use it carefully and in line with ESOS requirements.

  • CRICOS providers must report various student-related events through PRISMS to keep the government updated. Key things include:

    • Student enrolment details (CoE issuance): As mentioned, when a student pays and finalizes enrolment, creating a CoE is effectively reporting that you have enrolled that student.

    • Non-commencement: If a student we expected to start does not show up by the start date (and hasn’t formally deferred), we must report that they did not commence. This usually involves cancelling their CoE on PRISMS indicating non-commencement, which alerts immigration.

    • Termination of enrolment: If a student’s enrolment ends early – whether because they withdrew on their own, or you canceled their enrolment due to misconduct or non-payment, or they transferred out with a release – you report the end of their enrolment. PRISMS will ask for a reason code (e.g., withdrawal, disciplinary termination, transfer, etc.).

    • Course changes: Any changes to the course or study plan. For instance, if you grant a student a deferral or suspension of studies (maybe for illness or other compassionate reasons), and that pushes their course end date out, you must update PRISMS with a new end date and the reason (deferment/suspension). Similarly, if a student finishes early (perhaps fast-tracked or got RPL that shortens the course), you report that with a new earlier end date.

    • Other reportable events: If a student’s visa status changes (though typically Home Affairs informs you if a visa is canceled after you report unsatisfactory progress, etc.), or if you find out the student has changed their address and you can’t reach them – address updates themselves aren’t reported via PRISMS, but failing to be able to contact a student might coincide with other reporting like non-attendance.

    Essentially, any time a student’s status changes from what’s on their CoE, PRISMS should be updated. This ensures that the student’s visa conditions align with their actual situation. For example, if you reported a student’s course is done, their visa may shorten accordingly; if you extend their course, their visa might need extension. The coordination is crucial. Keep in mind, administrative errors in PRISMS can cause big headaches for students (e.g., if you accidentally cancel a CoE when they’re actually there, it could trigger visa cancellation). So be diligent: double-check before hitting ‘submit’. If mistakes happen, there are processes to rectify them, but best to avoid them. Always maintain copies or printouts of PRISMS confirmations for your records as evidence of timely reporting.

Have questions about RTO compliance, ASQA processes, or CRICOS requirements? Below we provide plain-English answers to some of the most common queries we hear. Use the index to jump to a topic, or scroll down to read through and deepen your understanding of the VET regulatory environment.

FAQ Index:

  • Trainer & Assessor Requirements Recent changes, required credentials, demonstrating vocational competence
  • Assessment & Validation Compliant assessment systems, mapping, managing plagiarism, validation vs moderation
  • RPL & Credit Transfer Best practices for RPL, efficient credit transfer, avoiding evidence pitfalls
  • Enrolment & Marketing LLN testing, required pre-enrollment info, marketing rules, approving marketing materials
  • Student Support & Inclusion Support expectations, wellbeing for short/online courses, inclusion and hardship support
  • Governance & Self-Assurance Leadership accountability, risk registers, demonstrating self-assurance, conflict of interest control, financial viability
  • Third Parties & Scope Defining third-party arrangements, required terms, monitoring partners, adding courses to scope, teaching out superseded products
  • Records & Data Records retention, data reporting (AVETMISS, USI), annual declaration, issuing certificates
  • CRICOS Compliance (VET) CRICOS basics, registration process, key requirements, renewal, adding courses/locations
  • ESOS & National Code ESOS obligations, National Code overview, standards and provider obligations
  • International Student Management Information to give before enrolment, written agreement requirements, use of agents, publishing agent list
  • Student Transfers & Attendance Rules for transferring before 6 months, monitoring attendance and progress
  • Intervention & Reporting Intervention & Reporting
  • Student Visa Conditions Key visa conditions (full-time study, progress, OSHC, work hours, address updates) RTOs should know
  • CRICOS Operations Full-time study definition, online learning limits, required support services, orientation programs, critical incident policy
  • Miscellaneous OSHC arrangements by providers, student work hours monitoring, PRISMS use and reporting obligations

(If you don’t see your question here, feel free to contact us – we’re happy to provide guidance or a referral where appropriate.)

Trainer & Assessor Requirements