The EFQC Enquirer: 13 March 2026

In this edition

EFQC Update

• EFQC on the Road – Connection, Collaboration and Celebrating Women in the Sector

Important Sector & Regulatory Updates

• NDIS Quarterly Report: What the Latest Data Says About the Provider Market
• Regulatory Reform Roadmap Update: Mandatory Registration for SIL from July 2026
• ACCC Report Highlights Consumer Rights Issues in the NDIS
• Buying or Selling an NDIS Business: What Happens to Registration?

Ask the Experts

• Ask the Experts —  Thinking of Home Care? What NDIS Providers Need to Know First” Melinda Burgess, Associate, Engels Floyd Quality Consulting

EFQC Update

EFQC On the Road — Connection, Collaboration and Celebrating Women in the Sector

It has been a wonderful and inspiring month for the Engels Floyd Quality Consulting team, with opportunities to connect with colleagues across the sector, strengthen our own team, and celebrate the contributions of women in our community.

EFQC Team Connect Day — Strengthening Our Support for the Sector

Recently, the EFQC team and several of our national network of technical associates came together in Melbourne and online for our Team Connect Day.

These sessions are an important opportunity to step back from day-to-day work and focus on the bigger picture — discussing emerging sector changes, sharing insights from our work with providers, and ensuring we continue to deliver consistent, practical support to NDIS and human services organisations across Australia.

Investing time in collaboration and planning helps us strengthen our shared approach and continue supporting providers navigating an increasingly complex regulatory environment.

Pictured: Engels Floyd team members at Team Connect Day in Melbourne. February 2026.

Celebrating International Women’s Day

March also brought wonderful opportunities to celebrate International Women’s Day and connect with many inspiring women working across the disability, health and human services sectors.

Cassie Day International Women’s Day Luncheon

We had the pleasure of attending the International Women’s Day luncheon hosted by Cassie Day in Adelaide.

We heard from some incredible speakers who shared powerful reminders about the importance of caring for ourselves — not just as professionals, but as people. In the midst of busy schedules and constant “doing,” it was a valuable pause to reflect and reconnect with what truly matters.

It was also lovely to reconnect with Nike and the fantastic team from Senami, along with many colleagues doing meaningful work across the sector.

City of Playford International Women’s Day Event

Another highlight was attending the International Women’s Day event at the Stretton Centre, hosted by the City of Playford, Adelaide.

The room was filled with inspiring women sharing stories, ideas and encouragement. A standout moment was hearing from Kelly Jamieson, founder of Edible Blooms, who generously shared her journey in business and many practical insights.

Thank you to Rachel Kammerman and the Stretton Centre team and the City of Playford for hosting such a positive and uplifting morning.

Events like these are a great reminder of the importance of connection, collaboration and supporting one another across the sector.

Important Information

1. NDIS Quarterly Report: What the Latest Data Says About the Provider Market

The latest NDIS data confirms what we are seeing across the sector — a rapidly growing provider market, increasing compliance scrutiny, and a clear shift toward stronger regulation of higher-risk supports.

The National Disability Insurance Agency (NDIA) has released the NDIS Quarterly Report for Q2 2025–26, covering 1 October to 31 December 2025. While the report contains a broad range of Scheme data, one of the most interesting insights for providers is the size and structure of the NDIS provider market — and the growing focus on integrity and compliance.

A growing Scheme and growing demand

The NDIS now supports 761,442 participants nationally, an increase of almost 10,000 participants (around 1.3%) since the previous quarter, continuing the steady growth of the Scheme.
As the participant base grows, so too does the provider market delivering those supports.

Registered vs unregistered providers

The data highlights a key feature of the NDIS market — the significant number of unregistered providers operating alongside registered providers.

• 17,982 registered providers were active in the quarter, meaning they received payment for delivering NDIS supports.
• In total, 276,581 providers delivered supports when both registered and unregistered providers are included.
• 259,179 of these providers were unregistered, operating through plan-managed or self-managed arrangements.

This demonstrates the scale of the broader NDIS marketplace and the large proportion of services delivered outside the registered provider framework.

Increasing integrity and compliance activity

Alongside market growth, the NDIA continues to strengthen integrity and compliance oversight.

• More than 2,000 problematic providers have been disrupted through Fraud Fusion Taskforce activities targeting fraud and non-compliant claiming.
• In the six months to December 2025, the NDIA reviewed over 34,000 high-risk claims worth more than $110 million, rejecting 66% before payment.

These measures highlight the NDIA’s ongoing focus on ensuring that NDIS funding is used appropriately and that provider practices meet regulatory expectations.

What this means in practice

1. The provider market is large — but increasingly scrutinised
With more than 276,000 providers delivering services, the NDIS market remains highly competitive. However, the increase in integrity checks and fraud investigations signals a stronger regulatory environment.

2. Registration is becoming more important
While many providers currently operate unregistered, upcoming reforms — including mandatory registration for Supported Independent Living (SIL) providers — indicate a gradual shift toward greater regulation of higher-risk supports.

3. Governance and compliance matter more than ever
Providers should ensure their policies, systems, documentation and claiming practices are robust, particularly as NDIA integrity programs and compliance monitoring continue to expand.

2. Regulatory Reform Roadmap Update: Mandatory Registration for SIL from July 2026

The NDIS Quality and Safeguards Commission has updated its Regulatory Reform Roadmap, confirming the next stage of reforms aimed at strengthening quality, safety and integrity across the NDIS provider market.

One of the most significant updates for providers is the confirmation that mandatory registration for Supported Independent Living (SIL) providers and platform-based providers will begin from 1 July 2026.

These changes are part of a broader regulatory reform program responding to longstanding concerns about quality, safeguarding and provider oversight in the NDIS.

What is changing?

From 1 July 2026, two key reforms will begin:

• Mandatory registration for SIL providers and platform providers
• Introduction of new SIL Practice Standards

Importantly, providers currently delivering SIL supports in an unregistered capacity will not be required to be fully registered by 1 July 2026. However, they will need to take action during the transition period if they want to continue delivering SIL services in the NDIS market.

This means providers should be preparing not only for registration, but also for compliance with the new SIL-specific Practice Standards that will apply from the same date, subject to transitional arrangements.

Why these reforms are being introduced

The reforms are designed to address longstanding issues identified across the sector, including:

• inconsistent quality of SIL services
• safeguarding concerns in supported living environments
• integrity risks in higher-risk support types

The Commission has indicated that these reforms aim to strengthen participant protections and ensure greater accountability across providers delivering complex supports.

What providers should be doing now

With the 1 July 2026 start date now
confirmed, the key message for providers is clear — preparation should begin now, not mid-2026.
For organisations currently delivering SIL, or planning to enter the market, the next 6–12 months should focus on:

• Strengthening governance arrangements
• Reviewing policies, procedures and systems
• Ensuring day-to-day practice aligns with expected standards
• Preparing for NDIS certification audits, not just documentation requirements

Providers who begin preparing early will be in a much stronger position when the transition period begins.
Staying informed

The NDIS Commission has also released updated information through its Reform Hub, including a Regulatory Reform Roadmap and FAQ resources outlining the pathway for these changes.
Providers are encouraged to monitor these updates to stay informed about timelines, transition arrangements and expectations for the new SIL Practice Standards.

Need support preparing for NDIS registration?
At Engels Floyd Quality Consulting (EFQC), we support providers across Australia with:

• NDIS provider registration and certification pathways
• Preparing for registration
• Policy and system development aligned with NDIS Practice Standards
• Audit readiness and governance frameworks

If you are considering registration, preparing for mandatory registration changes, or want to ensure your organisation is audit-ready, get in touch with the EFQC team to discuss how we can support you.

3.  ACCC Report Highlights Consumer Rights Issues in the NDIS

The Australian Competition and Consumer Commission (ACCC) has recently released a report examining consumer rights issues in the NDIS, raising concerns about some business practices across the sector.
The report, ACCC observations on consumer issues in the NDIS, highlights that some providers may not be meeting their obligations under the Australian Consumer Law (ACL). When this occurs, it can put NDIS participants at risk and undermine trust in the disability support market.

Key issues identified

The ACCC report identified several areas of concern in relation to provider practices, including:

• Misleading advertising, such as claims that services are “NDIS approved” or “100% NDIS funded” when this is not accurate.
• Unfair or unclear service agreements, making it difficult for participants to understand their rights and obligations.
• Failure to honour consumer guarantees, which apply to all services delivered under Australian Consumer Law.

The report also raises concerns about more serious issues, including:

• Charging for services that were not delivered
• Misleading claims about Specialist Disability Accommodation (SDA)
• Scams targeting NDIS participants
• The impact of these practices on vulnerable groups, including First Nations participants.

Why this matters for providers

While most NDIS providers operate ethically and deliver high-quality supports, the ACCC report highlights the importance of ensuring that business practices meet both NDIS requirements and Australian Consumer Law obligations.

For providers, this means ensuring that:

• Marketing and promotional material is clear, accurate and not misleading
• Service agreements are transparent and fair
• Participants clearly understand what services are being delivered and what they are being charged for
• Internal systems support accurate billing and record keeping

The broader regulatory picture

The ACCC report also reflects a broader trend across the NDIS — increasing scrutiny of provider practices from regulators.

Alongside the work of the NDIS Quality and Safeguards Commission and NDIA integrity programs, the ACCC’s involvement highlights that providers must consider both disability regulation and consumer protection law when operating in the NDIS market.

What providers should do now

For providers, this report is a timely reminder to review key aspects of their operations, including:

• Marketing and advertising practices
• Service agreements and participant contracts
• Billing systems and documentation
• Complaint and feedback processes

Ensuring these systems are clear, compliant and participant-focused helps build trust, transparency and strong provider reputations in the sector.

4. Buying or Selling an NDIS Business: What Happens to Registration?

A common assumption in the NDIS market right now is that you can simply “buy” an NDIS registration when purchasing a provider business. In reality, it is more complicated than that.

As the sector matures, we are seeing increasing activity in the buying and selling of NDIS businesses, and with that, more situations where providers are surprised by what the NDIS Quality and Safeguards Commission requires once ownership changes.

Recent guidance from the Commission reinforces an important point: NDIS registration is linked to the provider entity and its key personnel — not just the business name or service offering.

What happens when ownership changes?

When there is a change in ownership, control, or key personnel, registered providers must notify the NDIS Commission through the Commission Portal. The Commission will then assess whether the provider continues to meet the suitability requirements for registration.

As part of this process, providers may be asked to provide supporting evidence, which can include:

• Evidence of the business sale or transfer
• Updated ABN, ACN or provider entity details
• Details of new directors, owners or key personnel
• Resumes or CVs demonstrating relevant sector experience
• Evidence of qualifications where relevant to the supports delivered
• Updated organisational or governance structures

This allows the Commission to determine whether the provider — and the people responsible for running the organisation — remain suitable to deliver NDIS supports.

Why registration doesn’t automatically transfer

While NDIS businesses can certainly be bought and sold, NDIS registration is attached to the legal entity that holds the registration — not the business name or client base.
This is where confusion often arises.

In some transactions, the buyer purchases the shares in the existing company. In this case, the legal entity remains the same, so the NDIS registration usually stays with that company. However, because the ownership or control of the organisation has changed, the provider must still notify the NDIS Commission so it can assess whether the new owners, directors or key personnel are suitable to operate the registered provider.

In other situations, the buyer purchases the assets of the business — such as participants, staff, systems and branding — but operates them through a different company or legal entity. In these cases, the existing NDIS registration cannot simply transfer to the new entity, and the buyer may need to apply for NDIS registration in their own right.

The key point is that NDIS registration follows the legal provider entity, not the business itself. This is why providers considering buying or selling an NDIS business should seek advice early and ensure the Commission is notified of any relevant changes.

Why this matters for providers

This is an area where we are currently seeing a lot of confusion across the sector, particularly where buyers assume registration automatically continues with the purchase of a business.

The Commission’s guidance makes it clear that registration is ultimately about the suitability of the provider entity and the people responsible for delivering supports.

Ask the Experts

Thinking of Home Care? What NDIS Providers Need to Know First” Melinda Burgess, Associate, Engels Floyd Quality Consulting

Many NDIS providers are exploring aged care as their next growth opportunity. But before making the leap, it’s important to understand how different the sector really is.

Across the sector, many NDIS providers are starting to explore aged care — particularly home care services. At first glance, the two sectors appear similar. Both support people to live safely and independently in their own homes.

However, aged care operates within a different regulatory environment and often requires a different level of organisational maturity.

To help unpack what providers should know before entering the sector, we asked our resident Engels Floyd Home Care expert, Melinda Burgess, to answer some of the questions we hear most often.

What Providers Are Asking

Q: Why are so many NDIS providers considering home care?

Melinda:

There are a few drivers.

Demand for home-based aged care continues to grow as more Australians choose to remain living independently at home for longer. Government investment in home care has also increased significantly.
For many disability providers, aged care feels like a natural extension of their mission — supporting people across different stages of life. It can also create additional revenue streams and improve workforce utilisation.

However, it’s important to recognise that aged care is not simply an extension of NDIS services. It operates under a different regulatory framework and requires different governance, financial and compliance systems.

“Aged care is not simply an extension of NDIS services — it requires different governance, financial systems and organisational maturity.”
— Melinda Burgess

Q: What is the biggest misconception providers have when entering aged care?

Melinda:

The most common assumption is:
“We’re already regulated under the NDIS — how different can aged care be?”

The answer is: quite different.

NDIS experience is definitely valuable, particularly around governance, risk management and person-centred practice. However, aged care places stronger emphasis on areas such as:

• clinical governance
• financial sustainability
• prudential oversight
• service-level regulation and transparency

In aged care, regulators are assessing not just compliance — but whether your organisation has the capability and maturity to safely deliver care.

Q: What organisational changes are typically required when providers diversify?

Melinda:

Diversification rarely affects just one part of an organisation. It usually requires changes across three key areas.

Governance
Boards and leadership teams must demonstrate strong oversight of care quality and safety, including clearer accountability for clinical outcomes.

Workforce capability
Staff must have the right qualifications, scopes of practice and training to safely deliver aged care services.

Financial systems
Aged care places greater emphasis on financial governance, sustainability and robust reporting.
For most organisations, diversification is not simply adding a new service line — it is a strategic organisational shift.

Q: What major regulatory changes should providers be aware of?

Melinda:

One of the biggest changes is the new aged care provider registration model, that commenced late 2025.
Under this model, providers must apply for specific registration categories depending on the services they intend to deliver — ranging from home and community services through to residential care.

Higher-risk categories require more comprehensive audits against the Strengthened Aged Care Quality Standards, which place significant emphasis on governance, care quality and clinical oversight.
Providers must demonstrate commitment, capability and capacity before registration is approved.

Q: How different are the aged care standards compared to the NDIS Practice Standards?

Melinda:

There are areas of alignment. Both systems require strong governance, incident management, complaints systems, workforce oversight and continuous improvement.

However, there are some important structural differences.
For example:

• aged care registration is service-level, while NDIS registration is organisation-level
• aged care audits are typically on-site and publicly reported
• the regulator allocates the assessment team, rather than providers selecting their auditor

These differences mean providers should expect a different style of regulatory oversight and scrutiny.

Q: What should providers ask themselves before entering aged care?

Melinda:

Before making the move, organisations should pause and ask a few key questions:

• Why are we considering diversification?
• Are we prepared for more regulation, not just different regulation?
• Do we have the governance, workforce and financial capability to operate in two regulatory systems?
• What would success in aged care look like in three years?

If diversification is approached strategically and with the right preparation, it can create strong long-term opportunities.

Final Thoughts

Expanding into home care can be a strong opportunity for NDIS providers. Demand continues to grow, government investment is increasing, and many disability providers already have solid foundations in person-centred care.

However, aged care is a different regulatory and operational landscape. Providers who succeed are those who approach diversification as a strategic transition — not simply growth.

If you are considering expanding into home care, the Engels Floyd team would be pleased to help you understand the requirements and assess your organisation’s readiness.