Managing Material Change Notifications

E-Skills Australia assists RTO, CRICOS and ELICOS providers to assess, prepare and manage material change notifications and related regulatory documentation.

A material change may arise when there is a significant change to the provider’s ownership, governance, financial position, management, delivery arrangements, locations, scope, student operations, third-party arrangements or overall capacity to continue delivering education services.

These changes need to be considered carefully. Providers must understand whether the change is notifiable, what information needs to be prepared, what evidence may be required, and how the change may affect compliance, risk and regulatory confidence.

E-Skills helps providers prepare clear, structured and evidence-supported material change submissions that explain the change, its impact and the controls in place to manage it.

Material Change Notification Services

We can assist with:

Assessment of whether a change may be material or notifiable
Preparation of material change notifications
Supporting statements and explanatory documents
Ownership and control change documentation
Governance and management change summaries
Financial viability and business impact information
New campus or delivery location change support
Scope, course or delivery model change support
CRICOS and international student impact considerations
Third-party, partnership or subcontracting change support
Risk assessment and mitigation planning
Student transition or teach-out planning where required
Evidence collation and regulator-ready presentation
Follow-up responses to regulatory information requests

A Clear and Structured Approach to Material Changes

Understand the Change

We review the proposed or completed change, including what has changed, why it has occurred, when it occurred and which parts of the provider’s registration or operations may be affected.

Assess Compliance and Risk Implications

We consider how the change may affect governance, ownership, financial viability, staffing, resources, course delivery, students, locations, quality systems and regulatory obligations.

Prepare the Notification

We assist with preparing a clear material change notification, including background information, explanation of the change, impact assessment and supporting evidence.

Organise Supporting Evidence

We help providers compile relevant documents such as ASIC records, organisational charts, governance records, financial summaries, policies, risk assessments, student communication plans or resource evidence.

Support Regulator Follow-Up

Where further information is requested, we can assist with preparing responses, clarifying evidence and strengthening the provider’s submission.

Common Material Changes We Assist With

Providers may need support with material changes involving:

Change in ownership or control
Change in directors, CEO or key management personnel
Business acquisition, restructure or sale arrangements
Financial viability or sustainability concerns
New campus, site or delivery location
Significant change to delivery model or student cohort
Addition or removal of significant courses or scope areas
CRICOS capacity, course or location changes
Third-party delivery or partnership arrangements
Change in governance structure or management oversight
Significant compliance, audit or operational issues
Changes affecting students, staff, resources or delivery capacity

Material Changes Should Be Clear, Timely and Evidence-Based

A material change notification should do more than simply advise that a change has occurred. It should help the regulator understand the nature of the change, how it affects the provider, and how the provider will continue to meet its obligations. A strong notification should clearly address:

What has changed
Why the change occurred
When the change occurred or will occur
Who is affected by the change
How students and staff will be supported
How governance and compliance oversight will continue
What risks have been identified
What controls or actions are in place
What evidence supports the provider’s position

Suitable For Providers Managing Significant Change

This service is suitable for:

RTOs managing ownership, governance or scope changes
CRICOS providers making changes to courses, locations or student capacity
ELICOS providers changing delivery arrangements or operating model
Providers undergoing business sale, acquisition or restructure
Providers changing directors, CEO or senior management
Providers needing to assess whether a change is notifiable
Providers preparing evidence for regulator review
CEOs, directors and compliance managers seeking independent guidance before notifying a change