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Are RTOs able to provide RPL for their own trainers and assessors?

The VET Quality Framework or the Standards for Registered Training Organisations 2015 do not prevent RTOs from providing and granting RPL and issuing AQF qualifications or statements of attainment to their own trainers and assessors. However, RTOs must be able to provide evidence which demonstrates how competence was determined prior to issuing AQF qualification or statement of attainment. For example, the RTO must be able to demonstrate compliance with Clause 1.8, ensuring that assessment complies with the requirements of the training package, is conducted in accordance with the principles of assessment and rules of evidence. In addition, the trainer and assessor delivering the training and conducting assessment must comply with Clauses 1.13 – 1.16.

Are RTOs applying to add TAE Training Package products to scope required to provide independent validation if they have TAE40110 or TAE50111 on their scope now that they have been superseded?

If your RTO has the superseded TAE40110 Certificate IV in Training and Assessment or TAE50111 Diploma of Vocational Education and Training on scope it must provide evidence of independent validation of these TAE Training Package products.

Are there any particular training products that need to be validated more frequently?

ASQA has identified systemic risks with training in the following areas: equine, security, early childhood education and care, aged and community care, construction industry (‘white card’ training) and training and education (TAE). For the purpose of Clause 1.10, training products in these areas may need to be validated more frequently.

As a trainer and assessor, do I need to hold the unit TAELLN411 Address adult language, literacy and numeracy skills? (Clauses 1.13 - 1.16)

The Standards do not require trainers/assessors to hold specific units of competency within the qualification.

Until 1 January 2016, trainers and assessors must:

  • hold the TAE40110 Certificate IV in Training and Assessment, or its successor or
  • be able to demonstrate equivalence of competencies, or
  • hold a diploma or higher level qualification in adult education.

From 1 January 2016, trainers and assessors must:

  • hold the TAE40110 Certificate IV in Training and Assessment, or its successor, or
  • hold a diploma or higher level qualification in adult education.

For more information, refer to Clauses 1.13 - 1.16 of the Users' Guide.

As part of our strategy for training and assessment, my RTO clusters the assessment of units of competency. Do I need to offer Recognition of Prior Learning (RPL) in one unit of competency that is clustered with other units, or is there a discretionary el

Under the Standards for Registered Training Organisations (RTOs) 2015, your RTO must offer recognition of prior learning (RPL) to individual learners—unless the requirements of the training package or licensing requirements prevent this.

Offering RPL ensures the learner has the opportunity to participate in assessment that is flexible and fair. Where units, and assessments, have been clustered:

  • In developing the assessment tools, your RTO should have a mechanism for ensuring all requirements of each unit of competency are addressed—for example, a mapping process. An RTO could use this mechanism to identify which components of an assessment have been addressed by awarding RPL for a unit, and which tasks are still required to be completed.
  • It is possible the units have been clustered because of their similarities. A student may be able to demonstrate competency by RPL for all units in the cluster.

For further information, refer to Clauses 1.8 - 1.12 of the Users' Guide.

As part of the Rules of Evidence, under Currency, the Standards refer to ‘the very recent past’. What does this mean? (Clause 1.8)

The Standards require that evidence demonstrating current competency is from the present or the ‘very recent past’. The Standards do not specify the time that would be considered ‘very recent past’, as this may vary between industries.

However, trainers and assessors who have currently relevant skills and knowledge should be able to determine what constitutes ‘very recent past’ for their particular industry area. Your RTO must determine whether the evidence is recent enough to show the learner is competent at the time the assessor makes an assessment decision. For example, a computer programmer who has 10 years’ experience but has not been directly involved in hands-on programming work for the past three years may not have current skills in, or knowledge of, contemporary programming methods. However, the programmer may be able to update their skills and knowledge though a ‘gap training’ program.

This does not mean older evidence cannot be included in the evidence used to make an assessment judgement. However, older evidence must be supported by evidence that the person has the required skills and knowledge at the time of the assessment.

Can a superseded unit of competency be used toward recognition of prior learning (RPL) for a current unit of competency? (Clause 1.12)

Yes, a superseded unit of competency can be used as part of an RPL process toward the award of a current unit of competency.

However, currency is a particular risk with recognition of prior learning. Your RTO may be presented with evidence gathered over a number of years, including evidence of competency from a superseded unit of competency. This does not mean the superseded unit is not valid; however, you must ensure there is sufficient evidence of the person’s competence at the time you make the assessment decision.

For example, if a learner is applying for recognition of prior learning for the unit BSBWHS301A Maintain workplace safety and provides evidence of previously completing the unit BSBCMN311B Maintain workplace safety, your RTO should:

  • Consider all of the requirements of the unit BSBWHS301A and compare them to the skills awarded in BSBCMN311B (refer to the mapping information provided within the BSB07 Training Package for guidance).
  • Identify any additional forms of evidence the student could provide to demonstrate competence.
  • Ensure the total evidence provided by the learner shows she or he has current skills and knowledge in all requirements of BSBWHS301A.
  • Retain all evidence collected during the process.

Can an assessor work under supervision? (Clauses 1.17 - 1.20)

No, an individual working under the supervision of a trainer cannot determine assessment outcomes.

To conduct assessment, a person must either:

  • hold the TAE40110 Certificate IV in Training and Assessment, or its successor
  • hold a diploma or higher level qualification in adult education
  • hold the TAESS00001 Assessor Skill Set, or its successor, or
  • prior to 1 January 2016, be able to demonstrate equivalence of competencies.

Can an employer request a copy of a qualification issued to a learner, if the employer paid for the course? (Clauses 3.1 - 3.3)

You may only issue Australian Qualifications Framework (AQF) certification documentation to a learner who you have assessed as meeting the requirements of the training product.

You may issue a copy of a learner’s qualification or statement of attainment to another party, such as an employer, if the leaner has given written approval. You must be able to demonstrate, if required, that the learner approved the issue of a copy of their award to another party.

Can ASQA provide examples of best practice for checking the authenticity of online assessments?

Some examples of best practice for checking authenticity of online assessments might include: calling the learner and asking questions relating to assessment submitted or using the student’s webcam to take photos of the student at random intervals during the online assessment process.

Can ASQA refuse an arrangement an RTO has with a third party provider? (Clauses 2.3 – 2.4)

ASQA does not approve or reject third-party arrangements.

RTOs are simply required to notify ASQA when third-party arrangement for provision of training and assessment, education support services or recruitment of prospective learners commence or cease,

RTOs are required to ensure that provision of services under these arrangements meet all required standards. ASQA will examine this during audits or other regulatory activities.

Can I deliver a qualification in a shorter timeframe than listed in the AQF volume of learning? (Clauses 1.1 – 1.2)

Each learner must gain and be assessed against all the knowledge and skills described in the training package or accredited course. Depending on the circumstances and the characteristics of your learners, it may be possible to achieve this in a shorter period than that described in the AQF.

Your RTO may structure a course to be completed in a in a shorter time period than that described in the AQF. In this case, you will need to clearly describe, using a rationale based on the previous skills and knowledge and the needs of learners, how a specific learner cohort:

  • has the characteristics to achieve the required rigour and depth of training, and
  • can meet all of the competency requirements in a shorter timeframe.

Your description must take into account the need to allow learners to reflect on and absorb the knowledge, to practise the skills in different contexts and to learn to apply the skills and knowledge in the varied environments that the ‘real world’ offers before being assessed.

For more information, refer to Clauses 1.1 - 1.4 of the Users' Guide.

Can I enrol new learners in a qualification that has been deleted from the National Register, training.gov.au?

Clause 1.26(d) of the Standards for RTOs 2015 states that an RTO must not allow a new learner to ‘commence training and assessment in a training product that has been removed or deleted from the National Register’.

Can I include the NRT logo on my RTO website? (Clause 4.1)

Yes, the NRT Logo can be used to promote nationally recognised training on your website, provided that training is within your scope of registration.


  • Impressions must not be created that may lead an observer to conclude the NRT logo applies to all training provided by the RTO, if this is not the case.
  • Where training is being promoted and does not meet the requirements stipulated in the VET Quality Framework or is outside the RTO’s scope of registration, it must be made clear the NRT Logo is not associated with that training.
  • Use of the NRT Logo is only permitted where there is a direct relationship to an AQF qualification and/or unit of competency as specified within training packages or VET accredited courses.

Can I purchase TAE learning and assessment materials and submit these as the evidence for the resources, assessment materials and tools to be used?

Applicants must provide evidence that all resources are available to deliver the training products for which they have applied. The resources used must comply with all specific requirements of the TAE Training Package. Any gaps in the resources purchased must be addressed. Applicants must provide all resources—whether developed in-house or commercially purchased—for any of the requested units of competency as outlined in item 3 of the evidence requirements.

Can I validate my training products more often than every five years? (Clauses 1.9 – 1.11)

The validation requirements in the Standards are the minimum requirements your RTO must meet.

However, you may choose to validate your training products more frequently, particularly if you are operating in a dynamic industry environment, where emerging risk factors have been identified or where new assessment tools have been developed.

Can my RTO add a unit of competency from the TAE10 Training Package to its scope of registration? (Clauses 1.21 - 1.24)

Any RTO can apply to add any unit of competency to its explicit scope of registration, except for:

  • TAEASS401B Plan assessment activities and processes
  • TAEASS402B Assess competence, or
  • TAEASS403B Participate in assessment validation.

The above units of competency are part of the assessor skill set. You may only apply to add these units of competency to your scope of registration if your RTO has held registration for at least two years continuously.

Can my RTO collect fees in advance if it is not part of a Tuition Assurance Scheme? (Clause 7.3)

Your RTO may collect up to $1500 in prepaid fees from a learner without needing to take any action to protect those fees.

In addition, RTOs are only required to protect prepaid fees from individual learners. These requirements do not apply, for example, where an employer or organisation engages an RTO to provide training and/or assessment to its staff or members.

Can my RTO use social media to undertake marketing? (Clause 4.1)

Yes, you may use social media to undertake marketing. Your RTO number must be included and must be clearly visible on the home page of the account. Any advertising (e.g. a promotional post) must also include the RTO number. However, a reply to a customer enquiry does not require the RTO number.

Can my RTO use third-party evidence to assess competence? Is a written agreement required to use third-party evidence? (Clause 1.8)

Using third-party evidence is different to using a third-party provider to provide services on behalf of your RTO.

To inform a judgement about whether a learner has achieved competency, evidence is often collected by the assessor. However, other people (such as workplace supervisors) can also report what they see or hear to the assessor. Evidence collected in this manner is called third-party evidence (it is also sometimes called ‘supplementary evidence’).

A person collecting third-party evidence is not conducting any assessment. It remains the role of your RTO's assessor to make the judgement about whether competency has been achieved.

Your RTO does not require a written agreement to collect third-party evidence.

ASQA has developed a Fact Sheet about using third party evidence to assess competence. This tool provides valuable guidance as to how to develop an assessment system that will lead to the collection of quality evidence.

However, a third-party provider is any party who provides services under your RTO's registration, including undertaking assessment of training products.

Your RTO does require a written agreement to use a third-party provider.

Can terminology other than ‘complaint’ be used on a website? (Clause 6.1)

No. The Standards require you to have complaints and appeals policies, and to make these publicly available and easily accessible. The policies must also clearly state how to lodge a complaint and how it will be handled.

Can the NRT logo be included on a third party provider's website? (Clause 4.1)

If your RTO has a written agreement in place with a third party the NRT logo can be used on the third-party’s website. When a third party is advertising courses under an arrangement with an RTO, they are doing so on behalf of the RTO. Under these arrangements, any activity related to nationally recognised training undertaken by the third party is done on behalf of the RTO. Therefore, the NRT logo in these circumstances is actually being used by the RTO. The RTO must ensure all third party providers comply with all relevant requirements of the Standards at all times.

Can you provide some examples of how my RTO can authenticate online assessment? (Clause 1.8)

Showing authenticity in assessment means ensuring the evidence presented for assessment is the learner's own work.

ASQA does not prescribe the methods RTOs should use to ensure an assessment is authentic.

However, your RTO must consider how it will:

  • ensure that the evidence gathered "belongs" to the learner being assessed and that it provides evidence of that person's skills and knowledge, and
  • verify that the person you are enrolling, training and assessing is the same person that will be issued with a qualification or statement of attainment.

You may choose to utilise a mix of security measures to ensure authenticity.

One example might be:

  • confirming a student's identity by using an accredited third party to confirm the student is the person who registered for and completed the assessment, and
  • storing this confirmation with the assessment results.

There are many other security measures which RTOs can use.

Do applicants applying for initial RTO registration need to meet financial viability requirements?

Yes, every initial registration process includes an assessment of financial viability. All applicants for initial registration need to complete and submit a Financial viability risk assessment pack (DOC 912kb).

Financial Viability Risk Assessment Requirements means the requirements made under section 158 of the National Vocational Education and Training Regulator Act 2011.

An RTO is required to present an acceptable level of financial risk at all times. ASQA can require an RTO to submit to a financial viability risk assessment at any time. Each RTO’s financial viability risk is assessed by ASQA to evaluate the likelihood of business continuity and the RTO’s capacity to achieve quality outcomes.

Do complainants need to submit complaints to the RTO before contacting ASQA?

Yes, in most cases learners must exhaust the RTO's complaints and appeals process first, and provide evidence to ASQA that they have completed this process before submitting a complaint to ASQA. In exceptional circumstances ASQA may consider a student’s complaint without this evidence.

Do I have to issue a qualification or statement of attainment within 30 days, or will a record of results suffice? (Clauses 3.1 – 3.4)

You must issue the full AQF certification documentation that the student is entitled to within 30 calendar days of a student being assessed as competent in the training program they are enrolled in.

Do I need a separate training and assessment strategy for each learner cohort or can I develop one that covers multiple learner cohorts?

RTOs must develop and implement strategies for training and assessment for each training product they are registered for. If the needs of different learner cohorts require different approaches to the delivery of training and/or assessment, your RTO may need to develop multiple training and assessment strategies.

Do I need to engage with industry outside my organisation? (Clauses 1.5 – 1.6)

Yes, your RTO must engage with industry:

  • when developing strategies and resources
  • when developing training and assessment practices, and
  • to ensure your trainers and assessors have current and relevant industry skills.

In the delivery of all training products—including the TAE40110 Certificate IV in Training and Assessment—there are important stakeholders outside of an RTO and these should be consulted with. Your RTO must consider all of the bodies that have a stake in the services your RTO provides. These can include:

  • industry clients (employers)
  • group training organisations
  • industry organisations
  • industry regulators
  • industry skills councils or similar bodies
  • industry training advisory bodies, and
  • unions.

By engaging with a variety of industry stakeholders, you can be assured that:

  • your training and assessment practices and resources are relevant to the wider industry community, and
  • your graduates can immediately apply the outcomes from their training to relevant industry frameworks.

Do the evidence requirements for training and assessment qualifications also apply to units of competency from the TAE package?

All RTOs must meet additional evidence requirements when applying to add any of the following Training and Education (TAE) Training Package products to their registration:

  • TAE40116 Certificate IV in Training and Assessment
  • TAE50216 Diploma of Training Design and Development
  • TAE50116 Diploma of Vocational Education and Training
  • TAESS00011 Assessor Skill Set*
  • TAESS00010 Advanced Assessor Skill Set*

* ASQA does not register RTOs for skill sets. RTOs must register for individual units explicitly if they don’t have implicit unit registration courtesy of qualifications on scope.

RTOs must meet and provide the additional evidence requirements when applying to add a unit from the TAE training package to your scope of registration.

Does each member of a board of directors need to sign ‘fit and proper person requirements’? (Clause 7.1)

The National Vocational Education and Training Regulator Act 2011 defines anyone who manages the RTO, or owns more than 15 per cent of it, as an ‘executive officer’.

All executive officers and the ‘high managerial agent’ of a RTO must satisfy the Fit and Proper Person Requirements 2011.

These people must make a ‘fit and proper person’ declaration, in accordance with ASQA’s requirements, whenever their RTO:

  • applies for initial registration or to renew registration as an RTO, or
  • employs a new manager.