Part 1- How compliance and quality assurance are two separate but intertwined concepts

When you plan to run a registered training organisation (RTO), you may find it difficult to know:

  • the complete regulatory framework and environment
  • your legal obligations and
  • everything else required to run a successful, compliant Registered Training Organisation.

Take compliance and quality assurance, for example, you may have heard about them, but do you know what they mean?

What is compliance?

Numerous legislation, regulations and guidelines in Australia regulate the way we run an RTO such as:

  • Australian Consumer Law (ACL),
  • the Racial Discrimination Act 1975,
  • the Sex Discrimination Act 1984,
  • the Disability Discrimination Act 1992,
  • the Age Discrimination Act 2004,
  • the Child Protection Act 1999,
  • the Work Health and Safety Act 2011,
  • the Australian Human Rights Commission Act 1986,
  • the Privacy Act 1988 and
  • the National Vocational Education and Training Regulator Act 2011.

This is not an exhaustive list. These legislation, regulations and guidelines specify the framework and the obligations to operate an RTO.

A number of these obligations are applicable on all business entities that operates within Australia and are overseen by the Australian Securities and Investments Commission (ASIC).

The law does not allow you to be an officeholder or manage a company (without court consent) if:

  • you are currently bankrupt
  • you are still subject to a personal insolvency agreement or composition under the Bankruptcy Act 1966, or
  • have been convicted of offences like fraud or breaching your duties as an officeholder.

If you are member of ACPET or other industry bodies, they may also have codes of conduct and specific guidelines that you must follow to continue to be a member. These requirements and obligations come under “compliance”. Failing to meet all state and federal guidelines for compliance can result in serious consequences for your registered training organisation (RTO). Along with altering your company’s legal status, which may leave you vulnerable to lawsuits, government agencies may conduct audits, enact fines or even dissolve your business entirely.

What is quality assurance?

Standard 2 of the SRTOs 2015 (Standards for Registered Training Organisations, 2015) states that the operations of the RTO must be quality assured. Quality assurance refers to “meeting and delivering intended performance according to certain benchmarking standards”.

Let’s look at Standard 2:  Clause 2.1 – 2.4

2.1 The RTO ensures it complies with these Standards at all times, including where services are being delivered on its behalf. This applies to all operations of and RTO within its scope of registration.
2.2 The RTO:

    • Systematically monitors the RTO’s training and assessment strategies and practices to ensure ongoing compliance with Standard 1; and
    • Systematically evaluates and uses outcomes of the evaluation to continually improve the RTO’s training and assessment strategies and practices. Evaluation information includes but is not limited to quality/performance indicator data collected under Clause 7.5, validation outcomes, client, trainer and assessor feedback and complaints and appeals.

2.3 The RTO ensures that where services are provided on its behalf by a third party the provision of those services is the subject of a written agreement.
2.4 The RTO has sufficient strategies and resources to systematically monitor any services delivered on its behalf, and uses these to ensure that the services delivered comply with these Standards at all times

While Standard 2 of SRTOs 2015 addresses the key client criteria of quality training and assessment strategies and practices there are many other quality considerations that make up a quality-assured RTO business.

Every RTO must have a system (often referred to as a ‘business or quality management system’) to manage its operations. The system should provide the basis for quality assuring a business.

Quality assurance is maintained by ensuring that:
  • The organisation understands the relationship and differences between Quality Management systems, Quality standards and Regulatory standards.
  • Understand how a properly implemented business (quality) management system can help improve fundamental business performance well beyond just meeting compliance/regulatory requirements
  • Use quality assurance techniques to help review their existing system and processes
  • Revitalise their existing quality management system
  • Organisation participate in professional networking with colleagues across RTOs and wider industry.

To be continued…

Obligations of Registered Training Organizations in Terms of Reporting

Under the Standards for Registered Training Organisations 2015, all RTOs are obliged to provide accurate and complete data.

All ASQA-registered training organisations RTO must meet mandatory annual data submission requirements, including:

  • Submitting the annual declaration on compliance to ASQA
  • Submitting total VET activity (TVA) data, including the reporting of unique student identifier (USI) data.

There is a limited number of exemptions for some short courses and eligible RTOs, however, if you are delivering training under a funding agreement you are required to report all of your contracted delivery to the relevant Department.

Organisations are, therefore, responsible for a number of reporting requirements under the Standards for Registered Training Organisations 2015. The reporting requirements include:

The annual declaration on compliance

The Standards require each RTO to provide ASQA with an annual declaration on their RTO’s compliance.
The annual declaration must be signed by the principal executive officer/chief executive officer registered with ASQA as listed on

If you are the RTO CEO or PEO, ASQA will notify you by email of your obligation to complete the declaration and provide you with a link to the online form. You can check your details on to ensure that ASQA has access to your current email address to ensure you receive this invitation.

When you submit the declaration, you are confirming to ASQA that you:

  • Systematically monitor your RTO’s compliance
  • Implement preventive and corrective actions where considered necessary.

The declaration also asks you to confirm that records pertaining to your RTO, as reflected on, are accurate and up to date.

Reporting requirement: Total VET Activity (AVETMISS and USI) 

The Australian Vocational Education Training Management Information Statistical Standard (AVETMISS) for VET Providers is a national data standard that ensures the consistent and accurate capture of VET information about students, their courses, units of activity, and qualifications completed. It provides the mechanism for national reporting of VET activity.

Provides information through NCVER to Industry stakeholders about:

  • Statistical information captured for national reporting
  • Unique Student Identifier and all award issuance activity conducted in the previous year

Reporting requirement: Quality Indicators 

These include learner and employer survey data to collect evidence-based and outcome-focussed continuous quality improvement, and assist the VET Regulator to assess the risk of an RTO’s operations:

Other information you must submit:

You must collect AVETMISS-compliant records for all students, and for all competency enrolments and outcomes achieved, throughout the calendar year.

Early in the following year, you must report this data to the National Centre for Vocational Education Research (NCVER) unless you have previously done so through existing contractual arrangements.

RTOs should refer to NCVER’s publications AVETMISS 7.0 VET Provider Collection Specifications and AVETMISS data element definitions which describe the AVETMISS data to be collected.

There are a number of student management systems that can record and produce AVETMISS data files for reporting. A register of data entry tools and student management systems is available on the NCVER website.

NCVER has developed a free AVETMISS data entry tool for RTOs with less than 100 students and an AVETMISS validation software for RTOs to validate their data before submission. Both tools are available on the NCVER website.

For further information, and a range of fact sheets, about Total VET Activity data, please see the:

Visit ASQA website for more information

Part 2- Contextualising of assessment resources

Contextualisation of training packages, accredited curricula and learning resources can be achieved without compromising the Standards for Registered Training Organisations (RTOs) 2015.

Contextualisation is the addition of industry-specific information to tailor the Standards for Registered Training Organisations (RTOs) 2015 to reflect the immediate operating context and thereby increase its relevance for the learner. Contextualisation is ultimately defined as; the activity undertaken by a Trainer/Assessor to make units of competency, accredited curricula or learning resources meaningful to the learner.

How to contextualise units of competency?
Contextualisation is a process that we use to create learning/assessment opportunities that are more relevant to our learner. When we do this, we link the Unit of Competency to the client’s needs using language that they understand.

Contextualisation is achieved by including, modifying or substituting text within units of competency and usually within the assessment requirements including performance evidence, knowledge evidence and assessment conditions.

It is about providing training and assessment that is specific to an enterprise or individual learner.

Any modifications to a unit of competency must maintain the integrity of the industry skill and portability requirements, including all legislative licensing and any other regulatory requirements.

The following are some suggestions for contextualising units of competency to make them more relevant for specific industries or workplaces:

  • Refer to the guidelines in the relevant training package. Usually, it will be possible to replace generic terms and general descriptions of equipment or processes and procedures with specific examples. For example, a guide working at Uluru may learn and demonstrate body language appropriate to the Pitjantjatjara people. There would be little point in that guide being required to learn and demonstrate body language appropriate for working among the Jewish community at the Sydney Holocaust Museum.
  • Analyse the generalised statements about the range of work and job tasks specified in the units of competency. These may need to be aligned to a particular job profile and translated to highlight particular tasks and levels of performance that are relevant to a particular workplace.
  • Identify the kinds of evidence that candidates may be able to provide in their job roles to satisfy the requirements of a particular unit of competency.
  • Prepare evidence plans for the candidates, showing how they might collect the identified kinds of evidence.

Let’s have a look at some examples:

  • If the Competency mentions Machinery, then we could use the exact name of the machine used.
  • If the Competency mentions Equipment, then we could use the names of each item of equipment
  • If the Competency mentions Location, then we could use the exact location, eg, Shed 1, kitchen bench, etc
  • If the Competency mentions Relevant Procedures, then we could use the exact title of the procedure manual
  • If the Competency mentions Relevant Personnel, then we could use the names of the people and their positions

Contextualise, but Follow the Rules
When it comes to contextualisation, we can be very creative. But, we need to make sure that we do not change the standards required of us. Remember: we must always follow the Qualification Packaging Rules of the Training Package.

When contextualising units of competency, teachers and trainers:

  • Must not remove the number and content of elements and performance criteria
  • May add specific industry terminology to performance criteria where this does not distort or narrow the competency outcomes
  • Changes should not diminish the breadth of application of the competency and reduce its portability
  • May add detail to the assessment requirements, where these expand the breadth of the competency but do not limit its use.
  • To make sure that we still follow the Training Package rules, we can read the Training Package itself, or we can get the advice of others, including:
  • Skills Service Organisations (SSOs) and Industry Reference Committees (IRCs) responsible
  • Our colleagues within the training industry or within the industry for whom we are delivering the training
  • Accessing the Support Resources available for each Training Package at TGA ( can also give us some great ideas of what is appropriate.

When we are contextualising, it is a good idea to speak with the client to make sure that we really are going to link the Unit of Competency to the participants’ actual work.

When we are contextualising, it is a good idea to speak with others to make sure that we really are going to be delivering the Unit of Competency in accordance with the Training Package rules.

Part 1- Contextualising of assessment resources 

Contextualisation of training packages, accredited curricula and learning resources can be achieved without compromising the Standards for Registered Training Organisations (RTOs) 2015. Contextualisation is the addition of industry-specific information to tailor the Standards for Registered Training Organisations (RTOs) 2015 to reflect the immediate operating context and thereby increase its relevance for the learner. Contextualisation is ultimately defined as; the activity undertaken by a Trainer/Assessor to make units of competency, accredited curricula or learning resources meaningful to the learner.

WHAT is contextualisation?

Contextualisation means adjusting units of competency or packaging certain units of competency together to meet the needs of the enterprise or the learner. 

WHY is contextualisation so important?

Contextualisation gives VET providers the flexibility to create a meaningful program for learners whilst ensuring standards are met, and an accredited AQF qualification is obtainable. Contextualisation can make learning more realistic by providing real life and actual workplace examples. Contextualisation also accommodates specific industry needs.

WHAT are the rules for contextualisation?

Contextualisation must comply with the guidelines for contextualisation. Contextualisation must not change the unit of competency’s elements or performance criteria. It can only provide additional information to the range of assessment conditions and assessment requirements in a unit of competency. You must meet the requirements of foundation skills provided under the Australian Core Skills Framework (ACSF) which places mandatory facilitation and assessment compliance requirements associated with: Learning, Reading, Writing, Oral Communication, Numeracy and Digital Technology. 

It must not limit the breadth or portability of the unit/s.

HOW do you contextualise?

There are two ways in which contextualisation occurs:

  1. Delivery of units of competency to reflect a local need by providing additional options or contextualizing assessment to meet the needs of the learner group being assessed.

  2. Packaging units together using elective options to achieve particular outcomes


WHY do you need to contextualise assessments?

Contextualising assessment resources ensures that candidates are able to apply their skills and knowledge in a work setting and can be assessed as competent for a particular work context.

WHO is responsible for contextualising assessments?

Registered Training Organisations (RTOs) are responsible for:

  • identifying the target audience/ or client group for whom use of the assessment resources will be relevant
  • adapting and contextualising learning resources and, in particular, assessments, to address group and individual needs, relevant to industry and local conditions It is advisable that trainer/ assessors consider each assessment in the context of the specific industry sector and/or organisation and make adjustments or contextualise as necessary.


RTOs should contextualise in line with reasonable adjustment practices, ensuring that contextualisation will result in consistent assessment practices throughout the organisation.

Read more here