
(ASQA) IQ June publication provided critical regulatory guidance focusing on three primary operational domains: student diversity, inclusion and wellbeing; provider responsibilities during student work placements; and the regulatory position concerning the delivery of elective units.
It is important that providers understand what this means for their operations, governance and compliance.
So let’s unpack this a bit.
Starting with the delivery of ‘elective units’.
Prior to the release of the Standards for RTOs 2025 it was very clear what constituted an ‘imported’ unit. Simply it was an elective unit that met the packaging rules of a qualification and was imported from a different training package. For example, a unit that sits within the Business Services training package (BSB) delivered (in accordance with the packaging rules) in a Sports Services training package (SIS) qualification.
It made sense that units within a training package were not considered to be imported as they constituted a part of the broad intent of the training package. They were designed to contribute to skills within a sector regardless of the individual qualifications narrower focus or specialisation.
But now any unit that does not sit within the elective list for a qualification is deemed to be an imported unit.
What does this mean for providers?
Firstly, the Standards for RTOs 2025 and their governing legislation are not retrospective in their application. So any student who undertook an ‘imported’ elective unit prior to 1 July 2025 is not affected by this new interpretation.
Secondly, to continue delivering an ‘imported unit’ from 1 July 2025 the provider will need to add this unit to their scope.
Thirdly, for any student who has successfully completed the ‘imported’ unit since July 1 2025 the RTO will need to ensure they now have the ‘imported unit’ on their scope and will need to re-issue the unit outcome with a new date of re-issuance reflecting when the unit was added to scope.
If a student has completed their course of study since 1 July 2025 and undertaken the ‘imported’ unit within that timeframe the RTO will need to re-issue the qualification to the affected student, notifying the regulator once the matter has been addressed in full.
I won’t go into the potential impacts for a student where the qualification has formed part of their school studies, contributed to a pathway into higher eduction studies, met a licensing requirement for employment, or otherwise. There are simply too many variables to consider without a detailed assessment of the individual situation.
Moving on to work placement and provider responsibilities.
The regulator has placed greater emphasis on the obligations of the provider during such aspects of a student’s learning experience. This has particularly arisen in relation safety concerns at child care and aged care service providers more broadly.
Each state and territory has its own set of requirements pertaining to child safety (i.e Children and Young People and Working With Children). The specific requirements vary across the states and territories as there is no uniform national code.
Some industries require specific safety training prior to site access including construction blue card as an example.
Taking this a step further, workplace health and safety standards and codes exist across all states and territories and nationally to ensure the safety and well-being of all employees. This includes safety practices designed to reduce and manage the risk of injury, as well as emotional and sexual harm. It is important that providers ensure their supervising and assessing staff are fully cognisant with the requirements of the industry they are engaging with and hold any/all applicable certification and evidence of currency of training. The same applies to students who undertake placement. Furthermore, it is important that staff and students have an understanding of the host employers policies and expectations before a placement commences. Where the host employer has its own site orientation and safety training students and supervising/assessing staff must undertake this training in accordance with the host employers directions.
Labour exploitation is always a concern with work placements/internships and apprenticeships. This is something that needs to be addressed in the work placement handbook for students and host employers. It should also be monitored by the providers supervising staff throughout the duration of the placement.
All applicable insurances must also be current for both parties. Clear lines of reporting and communication including lodging and handling of complaints need to be articulated in full for all participating parties prior to a placements commencement.
Work placement is a valuable experience. But it is not something that should be treated casually. Screening potential workplaces and employer groups before formalising an agreement between the parties is without question the most important step in the process. It will assure that the experience for both the student and the host employer is rewarding and fulfils its intent.
Student diversity, inclusion and well-being
Student diversity, inclusion and well-being has almost become a throwaway catchall line in Australian tertiary education.
To break it down in accordance with the Victorian governments definition:
Diversity refers to the presence of differences within a given setting, encompassing aspects like race, gender, age, ethnicity, religion, disability, and sexual orientation. Inclusion is the practice of ensuring that all individuals—regardless of their background—feel valued, respected, and supported, with equal access to opportunities and resources.
Taking this as a baseline for a provider the expectation that its student cohort aligns with the definition is easier said than done. For example, delivering training to regional and remote communities can be limiting simply because of its population profile. For a provider, it is important they ensure, in line with course entry requirements, that they market their courses from an inclusive perspective, i.e whoever you are you have a right to study so long as you meet the courses entry requirements. This is where the catch is. What defines a courses entry requirements? Is it language, age, faith, physical ability, gender, English language skills, numeracy, etc? Providers must ensure that when defining a courses entry requirements they are not discouraging or excluding candidates unfairly, and that those requirements align with the guidance and intentions of the training package and individual courses as published.
So the student is at your institution, what happens then? Is the campus wheelchair accessible, do the classrooms have hearing loops, is there sufficient supervision and security? Does the provider have clearly accessible and easily understood policies about respect, inclusion, harassment & bullying, work place safety, harmony, etc? Are staff regularly trained in the providers mandated practices of inclusion? Is there a staff/student committee that is empowered in ensuring the experiences for all are respectful, supportive and inclusive? Are there clear and respectful processes in place, accessible to all, in relation raising concerns, making complaints, recommending improvements?
Remember, aside from the regulators intensions, every individual has a right to an eduction. Every individual has a right to be included, and to benefit from participating in a respectful, supportive and safe education experience.
To close
The Standards for RTOs provide an outline of expectations of what a provider needs to do in order to safely, respectfully and effectively deliver constructive and valuable knowledge and skills acquisition leading to enhanced employment opportunities. But a quality provider sees the Standards for RTOs as the baseline for doing business, not the absolute. Building on this baseline makes the provider more attractive to the market. Continually evolving practices and innovations in vocational education delivery ensure the providers ongoing success. Added up, Australians prosper.
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