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Standard 4.1
An NVR registered training organisation operates with integrity and maintains accountability for the delivery of quality services
Performance Indicators
An NVR registered training organisation demonstrates:
- the organisation and its governing persons are fit and proper persons, having regard to the Fit and Proper Person Requirements made under section 186 of the Act, as in force from time to time;
- its governing persons are suitable persons to oversee the operation of the organisation;
- its governing persons act diligently and make informed decisions which facilitate compliance with this instrument and any other instrument made under section 185 of the Act, as in force from time to time; and
- the governing persons lead a culture of integrity, fairness and transparency in the organisation’s delivery of services.
- You can demonstrate the due diligence you undertake to assure yourself that your RTO staff are fit and proper in respect of the public being able to have confidence in their suitability to be involved in VET delivery.
- You have up to date records of your RTO’s governing persons, being all executive officers, high managerial agents and any persons who exercise a degree of control or influence over the management or direction of your RTO.
- You are timely in submitting a Fit and Proper Person Declaration, in accordance with ASQA’s requirements.
- You can show how governing persons are driving the right culture and holding staff and others responsible for high-quality training delivery. The ways this is demonstrated may vary but governing persons can describe how a culture of accountability, fairness and transparency is fostered within the RTO and their expectations of staff, students and others (such as third parties) are conveyed and understood.
- You can demonstrate that governing persons make informed decisions about emerging technology, such as artificial intelligence (AI), including by considering how it might affect the integrity and quality of services before introducing it into training, assessment, or operations.
- You can demonstrate that discussions about AI include ethical considerations like fairness, privacy, and accessibility, and that these are factored into organisational decision-making.
- You can articulate how governing persons communicate and drive the vision, purpose, commitment and capability of the RTO.
- You have evidence of regular evaluation of your organisation’s governance structures and systems – for example by gathering feedback on how your organisation is perceived in terms of integrity and quality.
- You undertake external and peer reviews of your organisation’s governance and control structures, and initiate action plans to continuously improve your governance operations.
- Your governing persons can describe how they access the information they need to make informed decisions about the RTO’s compliance with the Standards, including identifying areas for improvement.
- You can show how you use data and evidence to support your RTO’s compliance and integrity, including:
- student enrolment, progression and completion data
- student feedback, complaints and appeals
- industry and employer feedback
- outcomes of self-assurance or review activities.
- Failing to adopt governance structures, processes and procedures that ensure your RTO staff are, and remain, fit and proper in respect of their particular roles in VET delivery. For example, failing to undertake due diligence checks as part of your general recruitment or selection practices, and intermittently throughout their engagement/ employment.
- Inadequate governance to manage risks and safeguard against improper or illegal conduct and prevent the RTO from being vulnerable to insider exploitation or criminal activities.
- Insufficient processes in place to ensure governing persons continue to meet the Fit and Proper Person Requirements.
- Shadow-directorship in an organisation that leads to a failure to recognise all governing persons with influence.
- Failing to detect and respond to behaviours or individuals in the organisation that are undertaking concerning or suspicious activity.
- Not requiring staff or governing persons to properly disclose their interests in other corporations or organisations.
- Not acting on feedback received from students, industry or the community related to the quality and integrity of RTO operations.
- Governing persons lack sufficient understanding of new technologies, such as AI, and approve their use without documented rationale or risk assessment and without understanding its potential impact on compliance, student outcomes, or organisational integrity.
Standard 4.2
Roles and responsibilities of NVR registered training organisation staff and third parties are clearly defined and understood
Performance Indicators
An NVR registered training organisation demonstrates:
- It supports staff members to understand the components of this instrument and any other instrument made under section 185 of the Act, as in force from time to time, which are relevant to each staff member’s role as an employee of the organisation;
- It informs staff members of any changes to regulatory or legislative requirements that may affect the organisation’s delivery of services;
- It has a system in place for ensuring any third parties meet the requirements of this instrument and any other instrument made under section 185 of the Act, as in force from time to time, and are aware of their obligations under these instruments; and
- the roles and responsibilities of persons engaged by the organisation are well understood and documented, ensuring accountable decision-making.
- You have systems in place to document and communicate lines of accountability, staff roles and responsibilities (including compliance obligations), and these are well understood within the organisation.
- You can demonstrate your processes to support staff, including those of third parties, to understand the 2025 Standards for RTOs, and to keep them up to date on any relevant changes to regulatory requirements that will impact their work.
- You can show that staff and third parties engaged by your organisation are made aware of appropriate AI use (e.g. maintaining privacy, transparency in delivery, assessment integrity) and that these expectations are reflected in written agreements.
- You can show how staff, including those employed by third parties, are supported to drive a culture of compliance and continuous improvement including providing opportunities for them to proactively raise issues and areas for improvement.
- Your staff can describe how they identify and report compliance risks, particularly where they may impact student wellbeing or outcomes.
- You can demonstrate your systems for monitoring and reviewing third party compliance – for example, you have evidence that your third parties are aware of, and meet, their obligations under the Standards, and have recorded the action you will take if they are not.
- Roles and responsibilities are not clearly understood by staff and/or reporting lines do not support the identification, escalation and resolution of compliance risks.
- Staff or third parties are unclear about who approves, uses or monitors AI.
- Purchased ‘off-the-shelf’ systems for managing compliance with the Standards are not contextualised to the organisation’s needs.
- Identified compliance or integrity risks are not addressed in a timely manner.
- Neglecting to ensure that this Standard is applied with sufficient rigour to third parties and their staff, and not maintaining a process for managing risks against the Standards associated with third parties.
- Third parties are not adequately monitored and use AI in ways that conflict with agreed obligations (e.g. undisclosed use in assessment or poor data handling).
Self-assurance questions
- How do you ensure governing persons are suitable, fit and proper and remain so throughout their engagement with your RTO?
- What systems and processes are in place to ensure governing persons are acting diligently and within their delegated authority?
- How do you ensure governing persons are familiar with the Standards and aware of their responsibility to monitor the organisation’s performance against them?
- How do you ensure that governing persons do not become overly reliant on AI to monitor compliance?
- What governance measures are in place to monitor emerging AI risks such as bias, privacy, and transparency, including where AI is used by third parties?
- Do your staff understand what information can and cannot be shared with AI tools, particularly where personal or sensitive data is involved?
- How does your organisation’s culture promote responsible, fair and transparent AI use (where AI is being used)?
- How does the organisation communicate and monitor its values and drive a culture of compliance and continuous improvement?
- What due diligence do you do during your recruitment and performance management of your RTO staff to ensure that they are fit and proper for their role?
- What systems and processes do you have in place to determine, communicate and monitor staff roles, responsibilities and accountabilities within the RTO?
- How do you ensure staff remain familiar with the Standards and any changes to regulatory requirements?
- How do you support staff to voluntarily report compliance and integrity risks?
- What systems and processes do you have in place to respond to and address compliance and/or integrity risks that are reported or identified?
- What systems, processes and monitoring activities do you have in place to oversee and ensure third party compliance with the Standards?
Case study
Driving quality through good governance
YYY Training Pty Ltd (YYY) delivers health and community services qualifications and has built a strong reputation for quality, integrity and student success.
YYY’s governing persons, including executive officers and high managerial agents, play an active role in oversight and decision-making. They review monthly reports on student progression, feedback, financial performance and compliance risks, and use this information to guide continuous improvement. Governing persons’ ongoing fitness and propriety is reviewed at least annually, and biennial external validation is undertaken to ensure leadership practices remain effective and responsive.
YYY ensures that staff understand how their work contributes to compliance and quality outcomes through clearly defined role descriptions, regular briefings and professional development opportunities. Trainers and assessors are made accountable for maintaining assessment integrity, while administrative staff understand their obligations relating to enrolments, fees and data security.
Open communication is encouraged through regular team meetings where leaders share regulatory updates and invite feedback. Following the release of ASQA's principles for the responsible use of AI, the CEO convened an All Staff meeting to discuss their implications and seek views on current and future AI use within the organisation. Staff, including those from their third-party partner, made useful suggestions that led to practical improvements, including enhanced guidance and governance processes for the use of AI in enrolment and assessment.
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What level of governance is considered reasonable for small RTOs?
Governance arrangements should be proportionate to the size, scale and complexity of the provider. Small providers are not expected to have the same governance structures as large organisations, provided they can demonstrate effective oversight of their operations, risks, compliance obligations and quality outcomes.
The focus is on whether those responsible for governance have sufficient visibility of the provider’s performance and are able to make informed decisions. This may be achieved through relatively simple arrangements, such as regular review of compliance, quality, risk and performance information, documented decision-making, and clear allocation of responsibilities.
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Does ASQA take a different approach to a regulatory activity where the RTO's management team leads and presents the evidence directly, rather than engaging a consultant to support the process?
We do not take a different approach based on whether a provider uses an external consultant or presents evidence directly. The expectation is the same in all cases. The focus is on whether the provider can demonstrate and explain its own systems and practices, not who prepared the material.
In practice, we expect that:
- the provider's management and key staff can clearly articulate how their systems work
- evidence of compliance is understood, not just assembled
- responses during the assessment are consistent, accurate and reflective of actual practice.
Engaging a consultant may be appropriate, but the provider remains responsible for its operations, decisions and compliance. A strong performance assessment demonstrates that compliance is embedded in day-to-day operations and understood by those responsible for managing and delivering them.
Where a consultant oversees, directs or exercises a degree of control or influence over the management or operations of the provider, they may be considered a governing person. In these circumstances, the consultant may be required to meet the same governance expectations as other governing persons, including demonstrating appropriate oversight, understanding the provider's risks and obligations, and taking accountability for the quality and integrity of its operations.