ASQA's current regulatory priorities signal a continued shift away from narrow, document-based compliance checks towards a broader examination of provider integrity, governance, operational control and the quality of outcomes delivered to students.
For 2026-27, ASQA has identified four interconnected priority areas:
- provider governance, market conduct and non-genuine operations;
- quality, sufficiency and fitness-for-purpose of training delivery;
- integrity of qualifications and competency outcomes; and
- transparency, accountability and assurance in complex and international delivery models.
These priorities should not be viewed as isolated audit topics. Together, they reflect a central regulatory question:
Can the provider demonstrate that it is genuinely governed, adequately resourced, educationally credible and in effective control of its operations?
ASQA's current qualification-integrity work and risk-based regulatory approach indicate that scrutiny may extend beyond policies and strategies to the evidence of what actually occurred in practice.
1. Provider governance, market conduct and non-genuine operations
Governance is no longer adequately demonstrated by an organisational chart, a set of meeting templates or a general statement that the CEO is responsible for compliance.
Effective governance requires evidence that governing persons:
- understand the organisation's regulatory and operational risks;
- receive reliable information about provider performance;
- question or challenge adverse trends;
- oversee financial and operational sustainability;
- monitor student outcomes and complaints;
- maintain oversight of agents, contractors and third parties;
- review significant compliance concerns;
- ensure corrective actions are implemented; and
- understand the organisation's obligations as a registered training provider.
ASQA's Risk Management Practice Guide emphasises identifying, managing and reviewing risks to students, staff and the organisation. It also highlights the need for governing persons to understand the provider's financial position, performance and cash flow.
Evidence providers should review
Providers should be able to produce meaningful evidence such as:
- current governance roles, delegations and reporting lines;
- governing-person suitability and conflict-of-interest records;
- board or executive meeting minutes;
- risk registers showing active review;
- compliance and quality dashboards;
- internal audit and self-assurance reports;
- financial and operational performance reports;
- records of decisions, actions and follow-up;
- complaints and incident trend reports;
- third-party and education-agent monitoring records; and
- evidence that governing persons receive and respond to material information.
Meeting minutes should show more than reports being "noted". They should demonstrate consideration, challenge, decisions, assigned actions and subsequent follow-up.
2. Quality, sufficiency and fitness-for-purpose of training delivery
The existence of a compliant Training and Assessment Strategy does not prove that sufficient training was delivered.
Providers need to demonstrate that the training model:
- reflects the requirements of the training product;
- is appropriate for the student cohort;
- provides adequate time for instruction, practice and feedback;
- includes sufficient practical learning;
- is supported by suitable facilities, equipment and resources;
- is delivered by an adequate and available workforce;
- accommodates the needs of students requiring support; and
- is implemented consistently across locations and delivery modes.
The 2025 Standards for RTOs took effect on 1 July 2025 and focus on the quality of student and employer outcomes. ASQA's supporting practice guides provide examples, known risks and self-assurance considerations rather than prescribing one standard operating model for every provider.
Evidence providers should review
Relevant evidence may include:
- approved and current Training and Assessment Strategies;
- course and unit timetables;
- trainer schedules;
- attendance and participation records;
- learning-management-system activity;
- practical workshop or simulation records;
- workplace-placement records;
- trainer-to-student ratios;
- cancelled and replacement session records;
- learner-support and catch-up arrangements;
- completed learning activities;
- student feedback; and
- records showing how delivery concerns were identified and addressed.
Providers should reconcile planned hours and activities with the training students actually received.
3. Integrity of qualifications and competency outcomes
ASQA has undertaken substantial regulatory action against providers found to have issued qualifications without appropriate training or assessment. ASQA reported that, as at 31 March 2026, more than 43,000 qualifications or statements of attainment had been cancelled through its qualification-integrity work.
Qualification integrity depends on the reliability of the entire student evidence chain, not only the final certificate.
Providers should be able to demonstrate that:
- the student was properly enrolled;
- required training was delivered;
- the student participated in the training;
- assessment evidence is authentic;
- practical skills were directly and adequately assessed;
- assessors applied the assessment requirements correctly;
- reassessment was genuine and appropriately recorded;
- all unit requirements were satisfied before completion;
- results were authorised before certification; and
- certification records are accurate and traceable.
Warning signs requiring internal review
Providers should investigate circumstances such as:
- unusually short enrolment-to-completion periods;
- high completion rates unsupported by student evidence;
- identical responses across multiple students;
- insufficient practical observation;
- generic or retrospective assessor comments;
- missing submission and assessment dates;
- assessment completed before training commenced;
- certificates issued before all units were completed;
- unsupported credit transfer or RPL decisions; and
- trainer or assessor activity that appears operationally implausible.
4. Complex and international delivery models
Complex operating arrangements can make it difficult to determine who is actually controlling training, assessment, recruitment and student support.
Higher-risk arrangements may include:
- third-party delivery;
- multiple campuses;
- common-ownership groups;
- centralised shared services;
- education-agent networks;
- contracted trainers;
- online and offshore delivery;
- partner organisations;
- franchised or licensed operating models; and
- arrangements where premises, staff or resources are shared between providers.
The registered provider remains accountable for the quality and integrity of the services delivered under its registration.
ASQA's Information and Transparency Practice Guide also requires providers to be transparent where experts or third parties undertake recruitment, training or assessment services.
Evidence providers should review
Providers should confirm that they can demonstrate:
- clear contractual responsibilities;
- approval and due diligence before engagement;
- ongoing monitoring;
- access to student and operational records;
- control over trainers and assessors;
- oversight of marketing and recruitment;
- consistency across locations;
- escalation and corrective-action processes;
- termination arrangements; and
- evidence that the registered provider directs and controls delivery.
What providers should do now
Providers should not wait for a regulatory notice before reviewing these areas.
A practical readiness review should ask:
- Does governance evidence show active oversight?
- Are major operational and student risks visible to governing persons?
- Can actual training delivery be reconciled with the TAS?
- Can every qualification be traced to sufficient training and assessment evidence?
- Are agents and third parties actively monitored?
- Is the provider genuinely in control of every location and delivery model?
- Are internal findings corrected and followed through?
- Can the provider explain how it knows that its systems are working?
Conclusion
ASQA's 2026-27 priorities reinforce an important principle: compliance is not demonstrated by documents alone.
Providers need a connected evidence base showing that governance, training, assessment, student support and regulatory controls operate effectively in practice.
A mature provider should be able to demonstrate not only what its policies require, but also:
what occurred, how it was monitored, what was identified and what action was taken.
E-Skills support
E-Skills Australia assists providers with:
- governance and risk reviews;
- internal audits and self-assurance;
- board and management reporting;
- training and assessment reviews;
- qualification-integrity checks;
- third-party and CRICOS assurance; and
- regulatory rectification planning.
Speak with E-Skills about a governance and regulatory risk review.